By Thomas R. Burton
On August 3, the Obama Administration released the much anticipated final Clean Power Plan (CPP). The nation’s first ever standard to address power plan pollution has an ambitious overall goal of reducing CO2 emissions by 32% from 2005 levels by 2030. The plan’s third building block specifically calls for increasing generation from renewable energy sources. States are expected to develop and implement their own plans. They are to choose from either an emissions standards model, based on direct emissions requirements, or a state measures model, which employs a mix of measures, that incorporates the three building blocks.
States that do not file a plan with EPA by their September 2018 deadline will face a federally imposed model called the Federal Implementation Plan (FIP). The FIP the Administration currently proposes would realize similar emissions reductions through cap and trade. EPA would either assign an emissions cap or require states to meet a rate across their power plant fleet. Currently, EPA is accepting comments on the FIP and will decide on an approach next summer. It’s been characterized as both a guide path as states craft plans and also a warning for non-compliers.