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Handbook Provides Start-to-Finish Guidance on Clean Power Plan Compliance Process for Consumer Advocates
A handbook released today walks state consumer advocates through EPA’s Clean Power Plan, a complex rulemaking made all the more difficult to unpack due to the degree of flexibility provided to states. Effective participation of consumer advocates in the compliance process is essential to protect the interests of ratepayers.
The Clean Power Plan Handbook, written by Synapse for the National Association of State Utility Consumer Advocates, will serve as a resource for consumer advocates through each step in the compliance process, which Synapse refers to as “moments.”
The first moment, target setting, has already been completed by EPA to establish rate- and mass-based carbon dioxide emission limits for each state. The handbook breaks down the series of calculations EPA used to establish those targets.
The next step in the process is for states to develop compliance plans to be submitted to EPA. The Clean Power Plan is unusual in that it allows states to choose from a broad set of options to determine a compliance pathway; the handbook describes in detail the various compliance options and the implications each choice will have for multi-state cooperation and for compliance demonstration requirements.
Finally, states will need to demonstrate compliance in the interim compliance periods (2022-2024, 2025-2027, and 2028-2029), in the final compliance period (2030-2031), and biennially thereafter. The handbook lays out the compliance requirements and deadlines states will face depending on which compliance pathway they choose.
The handbook also presents a summary of the costs and benefits of complying with the final emission guidelines (as estimated by EPA) and discusses critical issues for consumer advocates to consider as they begin collaborating with other state agencies to implement the final Clean Power Plan.
The production of the handbook was made possible through the generosity of The Energy Foundation, a partnership of major foundations with a mission to promote the transition to a sustainable energy future by advancing energy efficiency and renewable energy. Related resources for consumer advocates funded through this grant include reports on best practices in planning for compliance and on modeling single- versus multi-state approaches to compliance.