Single State Clean Power Plan Compliance Approaches with Interstate Elements

May 28, 2015

The Georgetown Climate Center has released a policy brief providing an overview of considerations for single-state Clean Power Plan compliance plans that would allow for the option of interstate trading of compliance instruments. This document examines how such programs could work under both rate-based and mass-based models of compliance.

States and stakeholders have expressed interest in interstate coordination to reduce compliance costs and align with the interstate nature of the electric grid and existing renewable policies. In recognition of the potential challenges to developing and submitting joint multi-state compliance plans, states and stakeholders have begun to explore the possibility of single-state programs designed to allow affected sources the option of using compliance instruments that are common across multiple states and could therefore facilitate interstate trading—also referred to as “opt-in,” “trading-ready,” or “common elements” approaches.

This overview is informed by conversations in and around the Georgetown Climate Center’s State, Power Company, and NGO Dialogue series. For additional resources on EPA's proposed regulations, please visit the Georgetown Climate Center's Clean Power Plan Tool Kit.

GCC_ComplianceApproacheswithInterstateElements_May2015.pdf