Stakeholders described potential challenges associated with achieving reductions required by as early as 2020, when the compliance period begins. Stakeholders generally proposed either the allowance of credit for early reductions, which provides flexibility to defer other emission reductions until later, or phasing in building block 2 over time similar to blocks 3 and 4. EPA is requesting comments on these two approaches.
On October 28, the Environmental Protection Agency (EPA) made additional information and ideas available for public comment in a notice of data availability (NODA). EPA also proposed carbon reduction goals for fossil-fuel power plants located in Indian Country and U.S. Territories.
EPA’s press release indicates that the NODA is intended to help facilitate comments, which are due on December 1, 2014, by ensuring that all parties are aware of the key issues and ideas consistently raised by stakeholders. The NODA is an informational tool and does not alter the original proposal. The NODA release is intended to facilitate ideas and comments on major issues as EPA works toward a June 2015 final rule deadline.
The release also contains EPA’s supplemental proposal outlining carbon reduction goals for fossil-fuel power plants in Indian Country and U.S. Territories. This supplemental proposal sets specific goals for Indian country and territories through similar building block mechanisms and compliance timelines as the original Clean Power Plan proposal. Wisconsin does not contain any fossil-fuel fired generating units impacted by this proposal.
EPA’s NODA provides additional information on emerging technical issues and data related to rulemaking that have been consistently raised by stakeholders. The NODA discusses the trajectory or “glide path” of emission reductions from 2020 to 2029; aspects of the way building blocks are established; and the way the state goals are calculated. Read the full NODA here.
Stakeholders raised issues about the building block methodology, including the treatment of natural gas in building block 2 and the treatment of renewable energy in block 3. Several stakeholders indicated that EPA’s Best System of Emission Reduction (BSER) should recognize additional opportunities to utilize natural gas and alternative regional approaches to establishing renewable energy targets based on regional availability of renewable energy.
Finally, stakeholders raised concerns over the calculation of state-specific emission reduction goals, specifically related to inconsistent application of the formula and use of power plant emissions data from only the year 2012. EPA is seeking additional comment on alternative methodologies and data. EPA is also making available data for the years 201 and 2011 using the eGRID methodology.