“EPA . . . heard from a wide range of stakeholders that the EPA should authorize state plans to include a portfolio of actions… Plans that do directly assure that affected EGUs achieve all of the required emission reductions (such as the mass-based programs being implemented in California and the RGGI states) would also be approvable provided that they meet other key requirements, such as achieving the required emission reductions over the appropriate timeframes.”
So the bottom line is that EPA will let California, and the Northeast’s RGGI program, submit existing Cap and Trade Programs as part of their statewide or multi-state strategies. Each state will have to put together a plan similar to what has been historically done for traditional air pollution cleanup—think smog plans. These plans must then be approved by EPA. The proposal established June 2016 for submission of the plans (disregarding any successful legal challenges), with a 15 year implementation timeframe.
The statewide goal of a 30% reduction is from a 2005 baseline. To put some perspective around that number for a state like California, see below (all units in lbs CO2/MWhr):
- EPA Proposed 2030 Standard for California: 537
- California Grid Average in 2005: ~750
- California Projected Grid Average in 2020: ~506
With each California utility already subject to the AB 32 Cap-and-Trade Program, California’s Renewable Portfolio Standard (RPS), energy efficiency mandates, and other GHG reduction programs, it can be anticipated that a state-submitted plan will be a very complex compilation of existing programs to demonstrate California already has the programs in place to achieve the required reductions. EPA provided the following bullets showing the range of other activities around the country that will be able to be used to cut carbon pollution under this proposal.
- 47 states with utilities that run demand?side energy efficiency programs
- 38 states with renewable portfolio standards or goals
- 10 states with market?based greenhouse gas emissions programs
- 27 states with energy efficiency standards or goals
A 120 day comment period began upon publication in the Federal Register, as requested by Congress. EPA will also hold public workshops on the proposal throughout the country in the near future.
- July 29, 2014 – Public hearing will be held in Atlanta, Georgia and Denver, Colorado
- July 30, 2014 – Public hearing will be held in Washington, D.C.
- July 31, 2014 – Public hearing will be held in Pittsburgh, Pennsylvania
- June 1, 2015 – EPA will finalize rule
Therefore, this proposal is really just a milepost in a long regulatory process. So let the debate continue.
