EPA Moves Forward As Harvard Recognizes Billions of “Hidden” Clean Power Plan Benefits

UPDATE: EPA published its draft Clean Energy Incentive Program rule language in the Federal Register on June 30, 2016 – officially beginning the public comment period. EPA will accept public comments on this early-action part of the Clean Power Plan until August 29, 2016.

Despite the setback delivered by the Supreme Court’s stay, action around the Clean Power Plan continues. In fact, the Environmental Protection Agency’s historic regulation is on the verge of another public input period and is also the focus of a recent Harvard study.

What’s more, EPA has a new proposal out and an upcoming public comment period related to the voluntary early-action piece of the Clean Power Plan, known as the Clean Energy Incentive Program (CEIP). After hearing from stakeholders during a previous public comment period that ended in mid-December 2015, EPA has made some significant changes to the proposed CEIP. Most importantly, EPA has expanded the range of projects eligible for CEIP participation to include solar projects implemented to serve low-income communities

EPA’s CEIP is aimed at rewarding states that have already worked to decrease the carbon intensity of their energy sources and incentivizing states to move ahead with developing clean energy resources, especially those that benefit economically depressed communities. In the Clean Power Plan’s newest regulatory docket, EPA clarifies some pre-existing pieces of the CEIP and answers some questions left unanswered in the proposed CEIP that were identified in the over 5,000 comments EPA received and reviewed after the previous public comment period. EPA has provided a fact sheet highlighting key takeaways from the proposed CEIP rule and noting important changes or issues with respect to which EPA is specifically asking for more guidance from states, industry and the public at large.

Some of the most exciting new pieces in the CEIP mirror changes and suggestions made in SACE’s own comments submitted to EPA during the first comment period in December 2015.

Key proposed changes include:

  • Inclusion of solar projects that specifically benefit low-income communities as CEIP-eligible projects
  • Inclusion of demand-side energy efficiency programs as CEIP-eligible projects
  • A flexible approach for states to use in defining “low-income communities” in order to better fit economic makeup of individual states
  • Clarification on how EPA will provide “matching” compliance credits to states participating in the CEIP

In keeping with EPA’s efforts to-date in reducing a state’s administrative burden in implementing the Clean Power Plan, EPA has also provided examples of specific regulatory text that a state can use when incorporating the CEIP into the state’s larger compliance plan. Ultimately, state environmental agencies are tasked with creating a state’s compliance plan and working with utilities and customer stakeholders to craft a plan that provides optimum health and economic benefits and minimal negative impacts.

Which brings us to……….Harvard. Harvard researchers found that almost every region in the U.S. will begin to experience positive net benefits within 5 years after Clean Power Plan implementation begins, according to an article published in a peer-reviewed journal. According to the authors, previous efforts to quantify costs and benefits of the Clean Power Plan failed to recognize hidden costs and hidden benefits, such as improved labor productivity due to better air quality, associated with the implementation of the rule. In total, the study found at least $1 million in annual co-benefits for most counties in the country.

It’s particularly important to account for all potential health benefits realized thanks to implementation of a federal regulation aimed at climate change mitigation since health co-benefits make up the majority share of near-term economic benefits caused by carbon pollution reduction. As SACE highlighted in an event held in conjunction with Vanderbilt University shortly after EPA released the Clean Power Plan, there are significant health benefits associated with a marked reduction in carbon pollution, including reduction in respiratory illnesses, cardiac illnesses and a potential decrease in cancer rates.

As we saw in the last clean air battle between EPA and the coal industry, over the Mercury Air Toxics Standard, determining costs and benefits as accurately as possible before the implementation phase of the rule is crucial and can save future litigation headaches down the road.

Once the proposed CEIP rule is published in the Federal Register, the official 60-day public comment period will begin. EPA will host a public hearing on August 3, 2016 in Chicago. The public comment period is your chance to make your voice heard and push for more clean energy benefits in your state, especially clean energy projects and energy efficiency programs that serve economically vulnerable communities. Use your voice to help ensure all of us move one step closer to a clean energy future!

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