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Dec. 2 -- The nine states participating in the Regional Greenhouse Gas Initiative submitted comments Dec. 2 recommending that the Environmental Protection Agency use RGGI and its experiences over the past five years as a guide for upcoming national rules to reduce carbon dioxide from power plants.
The EPA rules under the Clean Air Act should allow states to demonstrate compliance on a regional and multiyear basis, according to the comments from the RGGI states. In addition, the rules should adopt an approach that applies to the energy system as a whole, permitting the use of energy efficiency, renewable power, and add-on controls as they become technically and economically available, according to the comments.
The RGGI states also urged EPA to ensure “equitable treatment to early movers,’’ so that states which have already made reductions in carbon dioxide emissions don't face “inequitable or disproportionate burdens’’ from the rules.
“The states participating in RGGI have demonstrated that significant emission reductions are feasible through a suite of clean energy activities, complemented by an enforceable emissions cap,’’ the comments said.
“EPA should consider this record of success in developing guidelines for state plans that require and empower states to achieve meaningful reductions through a comprehensive package of activities, including market-based emission budget programs like RGGI,’’ the states said.
The nine RGGI states submitting the comments to EPA Administrator Gina McCarthy were Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island and Vermont.
McCarthy, in a Dec. 2 speech at the Center for American Progress, said, “We are going to be very flexible on the implementation of this standard’’ (see related story).
“We are seeing engagement from the states right out of the gate on this issue,’’ she said.
“I don't need EPA to tell them what to do. I need EPA to set the charge and let them be doing the things and building on the success they've already had.’’
McCarthy said the EPA has reached out early to state regulators and hopes they are engaged to develop implementation plans that best suit their individual needs. However, the agency will issue federal plans for states that refuse to take action, she said.
“It's not the intent of the federal government to take over their duties, but if they don't perform as the Clean Air Act requires them to, we'll step in,’’ she said.
The RGGI recommendations are based in part on the initiative's experience using auction proceeds to fund energy efficiency programs, renewable energy and other types of programs.
“A system of emission reduction that is focused on the electricity system as a whole achieves the greatest emission reductions,’’ the comments said. “Programs within the system of emission reduction adopted by each RGGI state, such as energy efficiency goals and renewable energy standards, do not require emission reductions at any specific plant but focus on system-wide emission reductions.’’
“A system-based approach is not only best-suited to realize the emission reduction potential of cleaner energy supplies and energy efficiency, it fits precisely within [Clean Air Act] section 111(d)’s mandate to EPA to develop guidelines for states to implement the 'best system of emission reduction,’ ’’ the comments said.
The RGGI states recommended that the rules use a “single emission intensity target’’ as a way to provide equitable treatment to states that have already reduced their carbon dioxide emissions. Such a target could be set, for example, at 1,100 pounds per megawatt hour, as a system-wide average, according to the comments.
“That approach would require all states to reduce emissions, but it would be equitable to those states that have already made progress toward meeting the emission intensity target,” the comments said. “EPA could consider providing more time to states that have more work to do to meet the target.’’
Other recommendations offered by the RGGI states said:
• The rules should allow compliance on a regional basis, as a way to address the interstate issues raised by carbon dioxide emissions and align compliance with the regional nature of the electricity grid;
• The EPA should provide clear guidance for demonstrating the “equivalency of state programs’’; and
• The rules should ensure that state plans are legally and practically enforceable.
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The RGGI comments are available at http://www.rggi.org/docs/RGGI_States_111d_Letter_Comments.pdf.
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