The Eastern Interconnection States’ Planning Council (EISPC) and the National Association of Regulatory Utility Commissioners (NARUC) have recently published a document designed to assist states interested in pursuing regional compliance with the Environmental Protection Agency (EPA) proposed Clean Power Plan.
The 20-page document “Multistate Coordination Resources for Clean Power Plan Compliance,” was published May 12. One of the sections is described as a “Wedding Planner’s Guide” for getting together with other states.
The goal of EISPC has been to encourage and support collaboration among states in the Eastern Interconnection on critical energy issues. NARUC acts as an umbrella organization for EISPC’s funding application to the Department of Energy (DOE) to support state coordination, involvement and direction-setting for Eastern Interconnection-wide planning efforts.
EPA issued its proposal in June 2014 to have states draft implementation plans to cut power sector carbon dioxide (CO2) emissions 30% by 2030. EPA is expected to publish a final version of the rule, already under legal challenge, later this summer.
EPA has cited the Regional Greenhouse Gas Initiative (RGGI) as an example of an effective multi-state approach toward reducing GHG emissions. But “these kinds of institutional arrangements remain elusive,” according to the report issued by EISPC and NARUC.
EISPC has set up a work group aimed at providing guidance to states that might at least want to “coordinate” with neighboring states – even if they don’t want to go so far as to set up a RGGI-like CO2-trading authority.
“In fact, simply providing an instrument that bridges the States as they are writing their plans may create visibility that enables States to avoid plans that are counterproductive to each other,” according to the report, which was published in May.
This project aims to lower barriers to coordination between states, particularly between public utility commissions, governors energy advisors, and the lead agencies (generally, the state air pollution control agencies) responsible for the creation and filing of state implementation plans for the EPA’s Clean Power Plan regulations of greenhouse gases from existing stationary sources under Section 111d of the Clean Air Act.
A number of tools are being developed to help states construct their compliance plans. For example, organizations like the Midcontinent States Environmental and Energy Regulators (MSEER) and the Nicholas Institute at Duke University are developing modeling and conceptual multistate compliance pathways for adoption by the states, and the National Association of Clean Air Agencies (NACAA) is developing a model compliance plan that States can customize to their own needs.
As for the EISPC, NARUC report it is primarily aimed at helping states in “getting out from behind your desks” and engage with other states with a minimum of effort and political risk exposure.
The EISPC work group aim to help states as “conversation starter and first point of reference,” according to the report.
The EISPC work group includes representatives from EISPC, NARUC and representatives of about a dozen states.
Among other things the EISPC package includes a sample memorandum of understanding (MOU) for states looking to cooperate on CO2 compliance.
More information about discussion documents is available from Miles Keogh, Director of Grants & Research at NARUC (202-898-2217) or email@example.com.