On October 23, 2015 the final EPA Carbon Pollution Emission Guidelines for Existing Electric Utility Generating Units (“Clean Power Plan”) were published in the Federal Register. Along with the Clean Power Plan, the EPA also published its Proposed Federal Plan and Model Trading Rules in the Federal Register. This triggered a 90-day public comment period for both of these documents as well as the EPA’s Draft Evaluation, Measurement and Verification (EM&V) Guidance and Clean Energy Incentive Program (CEIP).
Details for submitting comments are:
Deadline for comments on all documents is January 21, 2016.
Comments on the Proposed Federal Plan, Model Trading Rules, and CEIP should be submitted via email to a-and-r-Docketa@epa.gov, Attn: Docket ID No. EPA-HQ-OAR-2015-0199. Comments can also be submitted online via the Federal Rulemaking Portal at www.regulations.gov.
Comments on the EPA’s EM&V Guidance should be submitted via email to emvinput@epa.gov. Comments on the EM&V Guidance should NOT be included with comments on the Proposed Federal Plan, as the Draft EM&V Guidance is considered a separate document.
MEEA is currently developing its comments on the Proposed Federal Plan, Model Trading Rules, CEIP and EM&V Guidance, based on experiences in the Midwest.
It is expected that there will be a substantial number of comments submitted to the EPA as there were last year with initial release of the proposed Clean Power Plan. Some of the high level issues expected to be discussed on these documents include:
Federal Plan and Model Trading Rules: will the EPA add energy efficiency as a compliance mechanism in the Federal Plan and how will this be done?
Clean Energy Incentive Program: what definition of low-income will be used?
Draft Evaluation, Measurement, and Verification Guidance: how does the definition of a “common practice baseline” comport with a state’s definition of gross savings?
If you have any questions regarding the Clean Power Plan, its impact on MEEA’s 13-state territory and MEEA’s activities related to the Clean Power Plan, please contact MEEA’s Senior Policy Manager Julia Friedman, at jfriedman@mwalliance.org. Please visit our webpage to access MEEA’s Clean Power Plan resources.
