Dive Brief:
- A broad coalition of Midwestern energy participants has asked the U.S. Environmental Protection Agency to consider crediting states for early actions taken to curb emissions under the Clean Power Plan.
- The group has also asked the EPA to clarify that retirements occurring after the base year and before 2020 count toward compliance, regardless whether retirements occur due to compliance with multiple regulatory requirements.
Dive Insight:
The Midwestern Power Sector Collaborative is a broad coalition — state officials, investor-owned utilities, generation and transmission cooperatives, merchant generators, public power producers and environmental organizations. Launched last fall by the Great Plains Institute, the group filed consensus comments in November 2013. Because of the group's diverse viewpoints, their recommendations "take no position on the stringency of EPA’s proposal," they said.
The group has asked EPA to clarify how new natural gas is to be treated should a state wish to rely on new natural gas to help achieve its goals. A mass-based approach would count the natural gas plants’ emissions when determining whether the state meets its required emissions budget amount. Under a rate-based approach the emissions and generation of a new natural gas plant would be counted toward compliance with a rate-based goal.
And "in the design of the standards, EPA should consider ways to avoid stranding existing combined cycle natural gas assets in favor of new natural gas generation," the coalition said.
