GHG Daily
1/11/2016
In developing action plans to comply with the Environmental Protection Agency’s Clean Power Plan, carbon emissions standards for existing coal-fired power plants, states may find themselves comparing apples to oranges when it comes to the EPA’s implementation options, according to a report issued Jan. 6 by The Brattle Group. The report says, “under the CPP, the EPA provides states with several rate- and mass-based implementation options to choose from in setting their state plans. The authors find that the standards under each option do not result in equivalent emissions reductions or compliance costs.”
The Clean Power Plan requires states to develop action plans to meet federally set state-specific carbon emissions reduction goals. The new policy brief also finds that compliance outcomes under each state’s action plan will depend largely on the actions of neighboring states. Furthermore, the report concludes that because the EPA’s regulatory impact analysis relies on assumptions that are not “indicative of expected state-level impacts under alternative implementation approaches,” it is unlikely to provide useful information for states while they develop their plans.