Pennsylvania seeks input on its compliance blueprint under the Clean Power Plan

The state of Pennsylvania, in the Sept. 12 Pennsylvania Bulletin, announced a series of listening sessions to be held this fall around the state as part of the preparation to write a state implementation plan under the Clean Power Plan.

On Aug. 3, the U.S. Environmental Protection Agency released the final Carbon Pollution Emissions Guidelines for Existing Stationary Sources: Electric Utility Generating Units (known commonly as the Clean Power Plan). The plan sets carbon dioxide emission standards for power plants and establishes customized goals for states to reduce carbon dioxide. Each state is required to develop a state-specific compliance plan to meet individual state targets set by the EPA or be subject to a federal plan.

Pennsylvania said its plan will be tailor-made for this Commonwealth’s economy and people, protecting indigenous resources and position as a net energy exporter. To develop a specific state plan, the Department of Environmental Protection will seek the comments and feedback of many stakeholders including the Legislature, industry and citizens throughout this process, with the goal of submitting a plan to the EPA by the Sept. 6, 2016, deadline.

To start this dialogue, the department will be accepting comments on the Commonwealth’s compliance with the EPA’s Clean Power Plan through Nov. 12, 2015. The department is soliciting comments on the Clean Energy Incentive Program component of the Clean Power Plan. The Department will also accept comments on the EPA-proposed federal plan that serves as a model rule for states developing state plans, accessible at http://www.epa.gov/airquality/cpp/cpp-proposed-federal-plan.pdf.

Specifically, the department is soliciting comments on the following questions for the state plan:

Compliance Targets/Timeline

  • Should the State Plan use rate-based (expressed in pounds of carbon dioxide emissions per megawatt-hour) or mass-based (total tons of carbon dioxide) targets?
  • How should allowances be allocated under a mass-based approach?
  • Should new natural gas plants be included within a mass-based target?
  • What methods should be used to measure compliance?

Participation in Trading

  • Should the Commonwealth adopt a trade-ready program without a formal multistate agreement?
  • Should the Commonwealth join a formal multistate trading collaborative?
  • Should the Commonwealth manage carbon emissions without trading at all?

Energy Efficiency and Renewables

  • How can the Commonwealth best use renewable energy in meeting its compliance obligations?
  • How can the Commonwealth best use energy efficiency in meeting its compliance obligations?
  • Should the Commonwealth participate in the Clean Energy Incentive Program?
  • Should the Commonwealth set aside allowances or credits to participate in the Clean Energy Incentive Program?
  • What other energy conservation measures could be considered?

Least-Cost Compliance and Reliability Issues

  • What compliance pathway represents the least-cost option for the Commonwealth?
  • How can the Commonwealth meet its objective of prioritizing indigenous resources?
  • How can the Commonwealth maintain a diverse fuel mix?
  • How can the Commonwealth protect the Commonwealth’s position as a net energy exporter?
  • How can the Commonwealth ensure electric reliability?

Vulnerable, Over-Burdened and Environmental Justice Communities

  • What specific communities of this Commonwealth may currently be experiencing adverse, disproportionate impacts of climate change and air pollution?
  • What specific communities of this Commonwealth may experience economic concerns over the implementation of the state plan?
  • What additional steps can be taken by the department to effectively reach out to these vulnerable communities to ensure that their concerns are taken into consideration?
  • How can the Commonwealth ensure that these communities are not disproportionately impacted by the state plan?

In addition to accepting written comments, the department will hold the 14 listening sessions, with the first on Sep. 15 in Harrisburg, and the last on Nov. 4 in Williamsport. A Sept. 22 session will be in Waynesburg in Greene County, which is a major center for coal production in Pennsylvania. The coal production and coal-fired power industries would be particularly hurt under the Clean Power Plan.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.