Download EESI's Clean Power Plan Comments

On January 21, EESI submitted comments to the Environmental Protection Agency (EPA) on the Clean Power Plan’s Federal Implementation Plan (FIP) and model trading rules. EPA released the rules in draft form in August 2015 when it finalized the Clean Power Plan. The FIP will be required of states that either do not submit state plans, or submit insufficient plans. The model trading rules will provide guidelines for the many states expected to incorporate emissions trading with other states in their plans.


Deep Cuts to CO2 Emissions Will Require Diverse Technologies, Strategies

In its comments, EESI applauded the efforts of EPA and the Obama Administration to deal with carbon emissions from stationary power sources, but urged the administration to recognize the full array of tools available to states for reducing carbon pollution. Under the proposed FIP and model trading rules, energy efficiency in the built environment, combined heat and power (CHP), and biomass are not given adequate attention.

All sources of renewable energy will be necessary to achieve deep and lasting cuts to climate-warming greenhouse gases. An “all-of-the-above” renewable energy strategy, with energy efficiency as a “fifth fuel,” is the only feasible long-term option. Therefore, EESI urged EPA to revisit its consideration of biomass, CHP, and demand-side energy efficiency in both the model trading rules and the FIP. In addition, the evaluation, measurement & verification of state plans must not disincentivize the use of these diverse energy and efficiency strategies.


Minority and Low-Income Communities Require Special Consideration in Clean Power Plan

Minority and low-income communities will particularly benefit from the Clean Power Plan's reduction of carbon dioxide emissions and particulate pollution. Nevertheless, many have raised legitimate concerns regarding trading schemes and their impact on communities. Emissions trading could be used to delay the closure of highly polluting but cheap-to-operate fossil fuel plants. To ensure that minority and low-income communities do see significant benefits from the Clean Power Plan, EESI asked EPA to carefully consider ways to avoid the production of air pollution “hot spots” and to incentivize the use of zero-emitting or energy-efficiency measures.


EESI welcomes the Clean Power Plan as an important step in moving towards greater energy efficiency and lower greenhouse gas emissions. EESI hopes that careful consideration of its comments will help communities and states see the greatest benefit from the Clean Power Plan.


For EESI's full comments of the Clean Energy Investment Program, the full inclusion of biomass and demand-side efficiency measures in the Federal Implementation Plan, as well as environmental justice concerns, click here.