On April 15, 2014, the White House Office of Management and Budget met with representatives from the Coalition for Innovative Climate Solutions to discuss EPA’s draft proposed rule establishing greenhouse gas performance standards for power plants under Section 111(d) of the Clean Air Act. Over the past few months, the Coalition has authored a series of white papers designed to provide EPA and the states with constructive input on how best to set such standards and met with a number of agency officials and relevant stake holders.
At the meeting, counsel for the Coalition, Bill Bumpers of Baker Botts LLP, identified and explained the key elements necessary for the standards to achieve cost-effective emission reductions from the electric power sector:
State flexibility to select the form for standards of performance (i.e., rate- or mass-based).
State flexibility to design creative, innovative emissions reductions programs, which could include non-jurisdictional activities implemented outside of power plants affected by the rulemaking.
Recognition of early GHG reduction actions, including plant retirements, renewable energy development and energy conservation programs.
Sufficient time to develop state plans and reasonable implementation and compliance periods.
Incentives for accelerating planned actions to reduce GHG emissions.
The Coalition for Innovative Climate Solutions is made up of electric generating companies located throughout the United States and reflecting the highly diverse nature of the electric generating industry.
The Coalition’s Core Principles can be viewed here, and the white papers are available here and here.