Implementing EPA’s Clean Power Plan: Model State Plans

National Association of Clean Air Agencies

[Press ReleaseNACAA’s Implementing EPA’s Clean Power Plan: Model State Plans is a comprehensive resource designed to help states develop implementation plans to comply with EPA’s Clean Power Plan (CPP) and reduce greenhouse gas emissions from the power sector.  The Model does not recommend a single approach to meet the CPP’s requirements.  Instead, it presents a broad range of analytical materials and example regulatory language to help states identify and implement their own preferred approaches.

The Clean Power Plan was stayed by the U.S. Supreme Court on February 9, 2016 pending the final disposition of legal challenges to the rule.  Though EPA is precluded from implementing the CPP or enforcing any of its deadlines while the stay remains in place, many states continue to voluntarily plan for the rule’s potential implementation.

The Model’s extensive technical resources are organized into three sections:

  • The first section, An Overview of State Plan Requirements and Strategic Planning Decisions, comprises six chapters that provide an overview of the U.S. power sector, summarize the Clean Power Plan, lay out state compliance planning approaches, identify required plan components for different state plan types, and present the key decision points for state regulators.
  • The second section, entitled The Primary Plan Types and Example Plan Provisions, begins a more technical dive into implementation details to address both rate- and mass-based emissions standards approaches as well as the mass-based state measures approach.
  • The third section, Comprehensive Model State Plan Submittals, includes two complete example plan submittals – a model initial submittal and a model state plan submittal – that states may review and adapt or build on as they wish.  NACAA’s example plan design is a mass-based, trading-ready plan that covers existing sources plus a new source complement.

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