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EPA Releases NODA for Proposed Clean Power Plan

Posted By Doug Austin, Monday, November 3, 2014
On October 28, EPA issued a notice of data availability (NODA), related to the proposed Clean Power Plan.  Federal agencies routinely use NODAs to provide the public with an opportunity to consider and comment on emerging technical issues and data related to an ongoing rulemaking.  The notice responds to issues the EPA has already received in comments on the proposed rule.
Issues include allowing states to take credit for early actions to reduce carbon dioxide emissions from power plants, expanded use of natural gas-fired power plants and the possibility of setting a multiyear baseline for state emissions rates.
EPA's proposal would set interim emissions targets for states between 2020 and 2029 with a final emissions rate target to be achieved in 2030, which the agency refers to as the glide path.  Some states have expressed concern with that approach because it requires them to achieve the bulk of their emissions reductions early, leaving little flexibility for later emissions reductions.  The agency is seeking comment on an approach that would give states credit for early carbon dioxide emissions reductions achieved prior to when the 2020 interim targets take effect.
EPA is also asking whether state targets for transitioning electricity generation from coal-fired power plants to natural gas should be phased in.  While the EPA isn't requiring states to specifically shift generation from coal to natural gas, states have said they would be required to significantly increase generation from natural gas to meet the agency's interim targets. Facilitating that transition could require installing new pipelines or other infrastructure.
EPA is also exploring the possibility of setting renewable energy targets on a regional basis that would better reflect how the industry actually operates.  States have questioned how renewable energy investments would be credited — either to the state where the electricity is generated or to the state where that electricity is consumed.
EPA in its notice also said it would consider state requests for a multiyear baseline for the proposed emissions rates for states. The proposed rule requires states to achieve the emission reductions from a 2012 baseline, but EPA released emissions data from 2010 and 2011 as well after some states suggested using a multiyear baseline would provide a more accurate picture of power plant emissions.  States have said that a single year baseline may not reflect variations in power plant emissions that occur over time.  EPA said it had considered a multiyear baseline when it wrote the proposed rule but found that averaging out over multiple years would only produce minimal changes to the state emissions rate targets.
In addition to the notice of data availability, the EPA plans to issue additional guidance to states for converting their carbon dioxide targets from rate-based standard to a mass-based standard in order to facilitate emissions trading.  

To see the NODA, go to

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