Clean Power Plan Implementation: A State, Power Company, and NGO Dialogue
March 10, 2015
The Georgetown Climate Center hosted its fifth dialogue among states, power companies, and NGOs recently to explore options for compliance under the Clean Power Plan, which will be finalized this summer.
Participants at the March 10 meeting reviewed key findings from recent modeling efforts and discussed different approaches that states could take to develop compliance plans. The agenda focused on opportunities, in either a rate- or mass-based context, for states to develop individual state plans that would leave open the option of interstate trading.
Vicki Arroyo, Executive Director, Georgetown Climate Center
A. Stanley Meiburg, Acting Deputy Administrator, Environmental Protection Agency
Session 1—Key Insights from Recent Modeling Efforts In this session, participants involved in modeling efforts discussed key findings across their analyses, such as: the impacts of regional cooperation on compliance costs; the implications of implementing a mass-based approach versus a rate-based approach; and the potential for emission leakage depending on compliance approaches.
Session 2—Discussion of a Rate-Based State Plan Model and Options for Interstate Crediting Participants discussed a rate-based state plan approach that would allow for interstate trading of compliance credits. The discussion addressed options and considerations for how to determine the emission value of interstate credits, such as renewable energy or energy efficiency credits, and how an interstate rate-based crediting model could be advanced.
Session 3—Discussion of a Mass-Based State Plan Model with Optional Interstate Trading Participants discussed a mass-based state plan approach that would allow the state—or potentially affected sources in the state—the option of participating in an interstate trading market. This included discussion of what common elements individual state programs would need to include in order to allow participation in a centralized system, what centralized infrastructure is required, and what other guidance or support would be required.
Discussion with EPA on State Plan Development and Implementation
Acting Assistant Administrator Janet McCabe
Associate Assistant Administrator & Senior Counsel Joe Goffman
Session 4—Cross-Cutting Issues This session focused on the cross-cutting considerations that arise with both rate-based and mass-based programs, including: interactions between rate- and mass-based programs, the role of existing REC markets, and what potential national default rules or assumptions could address these issues.
California: Mary Nichols, Chairman, California Air Resources Board, and Craig Segall, Senior Staff Counsel, California Air Resources Board
Colorado: Martha Rudolph, Director of Environmental Programs, Colorado Department of Public Health and Environment
Maryland: Ben Grumbles, Secretary, Department of the Environment
Minnesota: David Thornton, Assistant Commissioner, Minnesota Pollution Control Agency
Missouri: Goldie Tompkins, Chief of Staff & Policy Advisor to Chair Robert Kenney, Missouri Public Service Commission
Montana: Dave Klemp, Bureau Chief, Air Resources Management Bureau, Montana Department of Environmental Quality
New York: Jared Snyder, Assistant Commissioner for Air Resources, Climate Change and Energy, New York State Department of Environmental Conservation, and Michael Myers, New York State Assistant Attorney General
Oregon: Colin McConnaha, Senior Climate Change Policy Analyst, Oregon Department of Environmental Quality
Pennsylvania: Hayley Book, Deputy Director, Office of Policy, Pennsylvania Department of Environmental Protection
Tennessee: Michelle Walker Owenby, Assistant Commissioner, Office of Policy and Planning, Tennessee Department of Environment and Conservation, and Barry Stephens, Director, Division of Air Pollution Control, Tennessee Department of Environment and Conservation
Virginia: Michael Dowd, Air Division Director, Virginia Department of Environmental Quality
Washington: Sam Ricketts, Director, Washington, DC Office of Washington State Governor Jay Inslee
Calpine: Yvonne McIntyre, Vice President, Federal Affairs
DTE Energy: Skiles Boyd, Vice President, Environmental Management and Resources