Clean Power Plan Compliance Pathways

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Presentation transcript:

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

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

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

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.

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.

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.

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.

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.

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.

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

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.

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.

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.

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.

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

For questions or comments, please contact: Thank You For questions or comments, please contact: Lissa Lynch 202-661-6548 lynch@law.georgetown.edu Resources: Clean Power Plan summary webinar recording: http://www.georgetownclimate.org/clean-power-plan-summary-of-the-final-rule. Summary of goal setting approach and new flexibilities in final rule: http://www.georgetownclimate.org/understanding-state-implementation- options-under-the-clean-power-plan. Clean Power Plan Tool Kit: http://www.georgetownclimate.org/clean-energy/clean-power-plan-tool-kit.