Supporting State Plan Compatibility and Interstate Compliance with the Clean Power Plan

July 7, 2015

The Georgetown Climate Center has released a working paper identifying opportunities for guidance and tools from the Environmental Protection Agency to support the development of state plans that are compatible with each other, and facilitate interstate compliance with the Clean Power Plan.

As states and stakeholders consider options to comply with EPA’s Clean Power Plan requirements to reduce emissions from the power sector, there is growing interest in developing individual state plans that give regulated entities the option of working across multiple states to achieve compliance. Interstate reduction strategies provide opportunities to reduce compliance costs, align with regional electricity markets, improve administrative efficiency, and respond to uncertainties and changes.

For a mass-based program, this working paper outlines a framework that would provide a streamlined way for states and regulated sources to opt into interstate compliance. While questions remain about whether and how a streamlined opt-in system could operate for a rate-based system, this paper identifies ways to support rate-based interstate compliance more generally.

Recognizing the benefits of a federal plan that integrates smoothly with the plans in place in other states, the working paper also identifies ways that the forthcoming federal plan could be compatible with individual state plans.

The suggestions identified in this working paper follow from a May 2015 policy brief examining considerations for single-state compliance plans that allow for optional interstate compliance. Both the policy brief and this working paper are informed by conversations in and around the Georgetown Climate Center’s State, Power Company, and NGO Dialogue series. This paper also builds on the Center’s earlier work with states on opportunities to align and link regional emissions reduction programs.

For additional resources on EPA's proposed regulations, please visit the Georgetown Climate Center's Clean Power Plan Tool Kit.

GCC_InterstateCompatibility_July2015_0-2.pdf