1. Clean Power Plan Compliance Pathways
Lissa Lynch
Georgetown Climate Center
September 10, 2015

2. State Plan Options Model Rule Streamlined Options Model Rule
Rate-Based
“Emissions Standards” Approach
Subcategorized Rates
Rate Goal
State-Wide
State-Defined Rates
Mass-Based
Existing Units Only
Existing Units + New Source Complement
“State Measures” Approach
State Measures Plan
Model Rule
Streamlined Options
Model Rule
Streamlined Options

3. Emission Standards vs. State Measures
Rate Emissions Standards Approach
Mass Emissions Standards Approach
State
Measures Approach
Steam
NGCC
All requirements on affected EGUs
State Measures
(alone or in combination with limits on affected EGUs)
Subcategorized Rates
State
Rate Goal
State Mass Goal
State Mass Goal

4. Rate-Based Approaches
Standards on Affected EGUs
Interstate Trading
Sub-categorized Rates
All NGCC: 771 lb/MWh
All fossil steam EGUs: 1,305 lb/MWh
Trading-Ready
Model Rule
State-Wide
Rate Goal
All affected EGUs:
EPA-established goal rate
Multi-state plan with joint blended-rate goal
Other State-Defined Rates
Any other rates
Requires projection that plan will achieve state goal
No interstate trading
Source: Section VIII.C.

5. Emission Rate Credits (ERCs)
Generation and savings eligibility:
State issues ERCs on MWh basis using 2-step process:
Provider submits eligibility form to state
Description of project; projection of MWh generation or savings; EM&V plan
Projections must be independently verified
After generation/savings, provider submits EM&V report to state
Results must be verified
Appropriate number of ERCs issued to tracking system to account held by provider
Compliance Period
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
Generation or energy savings during the compliance period
Zero-emitting energy and energy efficiency measures installed/implemented after Jan. 1, 2013
Source: Section VIII.K.

6. Resources Eligible for Credits
Eligible Resources
New Renewable Energy: wind, solar, geothermal, hydropower, biomass, wave & tidal
Demand-Side Management: zero-emitting actions that avoid electricity use
Transmission & Distribution measures that improve efficiency
Demand-Side Energy Efficiency: measures that reduce electricity use in grid- connected buildings/equipment
Nuclear: generation from new units and capacity uprates at existing units
Combined Heat and Power (with approved calculation method)
Resources
NOT Eligible for Credits
New, modified, and reconstructed EGUs covered under 111(b)
Measures that reduce emissions outside the power sector
Existing (pre-2013) measures
Source: Section VIII.K.

7. Geographic Eligibility
In-State Crediting
A rate-based state can credit in-state RE or EE measures
Rate-Rate Interstate Crediting: RE or EE
A rate-based state can issue ERCs for out-of-state RE or EE incentivized by the state as long as not double counted
Rate-Mass Interstate Crediting: RE only
Rate-based states can issue ERCs for certain out-of-state RE generation located in a mass-based state
Rate-based states cannot issue ERCs for out-of-state EE measures located in mass-based states
Sources: Section VIII.K. and VIII.L.

8. Crediting Fossil Generation
Crediting generation below performance standard
Subcategorized rates only: Gas Shift ERCs
NGCC
Emission Performance Rate
ERCs
ERCs
Based on difference between EGU’s reported rate and emission rate limit
NGCC
Based on emission reductions from incremental NGCC generation
Gas Shift ERCs
Steam
Source: Section VIII.K.

9. Rate-Based Approaches
Standards on Affected EGUs
Plan Requirements
Interstate Trading
EM&V Plan
Measurement & verification of EE/RE
Documentation of EE/RE
GS-ERCs
Sub-categorized Rates
NGCC: 771 lb/MWh
Fossil steam: 1,305 lb/MWh
Model Rule
Trading-Ready
State-Wide
Rate Goal
EM&V Plan
Measurement & verification of EE/RE
Documentation of EE/RE
Multi-state plan with joint blended-rate goal
EPA-established goal rate
Projection that plan will achieve goal
EM&V Plan
Measurement & verification of EE/RE
Documentation of EE/RE
Other State-Defined Rates
No interstate trading
Any other rates
Source: Section VIII.K.

10. Mass-Based Approaches
Mass-Based “Emission Standards” Approach
Existing Units Only
Existing Units + New Source Complement
Model Rule

11. Mass Goal for Existing Units Only
Standards on Affected EGUs
Plan Requirements
Interstate Trading
Emission budget trading program:
Emission monitoring & reporting
Allowance allocation
Allowance tracking
Address potential leakage:
Include new sources (New Source Complement presumptively approvable)
Supported demonstration
Existing Units Only
Surrender allowances equal to reported emissions (under emission budget trading program)
Model Rule
Trading ready
Source: Section VIII.J.

12. Existing Units + New Source Complement
Standards on Affected EGUs
Plan Requirements
Interstate Trading
Emission budget trading program:
Emission monitoring & reporting
Allowance allocation
Allowance tracking
Existing Units + New Source Complement
Surrender allowances equal to reported emissions (under emission budget trading program)
Trading ready
Source: Section VIII.J.

13. State Measures Approach
Mass-Based Goal
State
Measures
Plan
State Measures
(alone or in combination with
limits on affected EGUs)
Federally enforceable backstop
Source: Section VIII.C.3.

14. Multiple Options for Interstate Trading
Mass
Trading-ready
Individual plans with specified partner states
Multi-state plan with joint goal
Rate
Trading-ready
Individual plans with specified partner states
Joint ERC issuance
Multi-state plan with joint goal
Existing Units Only
Sub-categorized Rates
Existing + New Source Complement
State
Measures*
* requires adjustments for net import / export of allowances
State-Wide
Rate Goal
Sources: Section VIII.J.3. and VIII.K.4.

15. State Plan Options Model Rule Streamlined Options Model Rule
Rate-Based
“Emissions Standards” Approach
Subcategorized Rates
Rate Goal
State-Wide
State-Defined Rates
Mass-Based
Existing Units Only
Existing Units + New Source Complement
“State Measures” Approach
State Measures Plan
Model Rule
Streamlined Options
Model Rule
Streamlined Options

16. For questions or comments, please contact:
Thank You
For questions or comments, please contact:
Lissa Lynch
Resources:
Clean Power Plan summary webinar recording:
Summary of goal setting approach and new flexibilities in final rule: options-under-the-clean-power-plan.
Clean Power Plan Tool Kit: