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M.J. Bradley & Associates Assists Stakeholders with Clean Power Plan Compliance Strategies
On August 3, 2015, EPA released the final rule to regulate CO2 emissions from existing power plants under Section 111(d) of the Clean Air Act. Overall, the Agency projects the final rule will achieve a 32 percent reduction in power plant CO2 emissions from 2005 levels by 2030. The program starts in 2022 with an eight-year interim period, and final targets in 2030. EPA requires states to submit their compliance plans by September 2016, but all states can request an extension to file final plans by September 2018. The rule provides states with flexibility to design compliance plans in ways that reflect state-specific characteristics.
MJB&A is working with a number of clients on their response to the Clean Power Plan and the development of compliance strategies. MJB&A is providing utilities and states with custom workshops on the rule, compliance evaluations, and modeling to further their understanding of this complex rule. These efforts represent stakeholders in multiple states across the U.S. with diverse power generation resources and compliance challenges. In addition to these individual efforts, MJB&A has made available a range of Clean Power Plan resources, including our Compliance Tool, which allows users to analyze state progress towards compliance with the Clean Power Plan rule under a range of electricity demand and generation scenarios and a variety of emissions reduction targets. Utilities, state/federal regulatory agencies, and advocacy organizations from 48 states are using the tool to explore compliance options. Specific Clean Power Plan topics MJB&A is currently assisting clients with include:
- Rate- versus mass-based compliance options
- Impact of new capacity additions, retirements, and energy efficiency savings on compliance scenarios
- Potential market implications of different regulatory approaches
- Addressing leakage under a mass-based approach
- Multi-state compliance options
- Early action crediting under the Clean Energy Incentive Program
- Allowance allocation and ERC program design options
- Emissions reduction requirements needed after accounting for state policies (RPS, EERS, etc.)
For questions on MJB&A's Clean Power Plan efforts, please contact:
Carrie Jenks, Senior Vice President
+1 978-369-5533
Chris Van Atten, Senior Vice President
+1 978-369-5533