Regulatory Framework Options and State Measures: Evaluating Emission Standards and Compliance
Different regulatory framework options and state measures addressing emission standards for electric generating units. Assess the pros and cons of measures without emission standards, those with emission standards, rate-based approaches with varied rates, and using state-wide goals. Consider factors such as compliance projections, interstate trading implications, and equitability of burdens. Dive into the complexities of demonstrating compliance with mass-based goals and the challenges posed by existing options. Evaluate the readiness for trading and interstate cooperation, along with the enforceability criteria at the state level.
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Presentation Transcript
State Measures without Emission Standards Pros Affected EGUs not subject to federally enforceable requirements unless backstop triggered Cons Projection of compliance with mass-based goals required Still have to comply with mass- based goals Have to make up shortfall if fail to comply Unclear how to demonstrate no leakage if adopt existing EGU-only option State measures have to meet EPA enforceability criteria at state level (60.5780) No interstate trading (nothing to trade) Is this a benefit for the state? 2
State Measures with Emission Standards Pros ??? Cons Projection of compliance with mass-based goals required Still have to comply with mass- based goals Have to make up shortfall if fail to comply Unclear how to demonstrate no leakage if adopt existing EGU-only option State measures have to meet EPA enforceability criteria at state level (60.5780) Interstate trading requires import / export accounting 3
Rate-Based with Varied Rates Pros Rates can be tailored to distribute burdens of compliance more equitably Cons Will result in protracted debate about what rate structure is equitable (similar to allocation issue) Projection of compliance with goal required Interstate trading is not allowed 4
Rate-Based Using State-Wide Goal Pros Less stringent for NGCC Cons More stringent for coal-fired EGUs Is this a benefit for the state? Is this a detriment for the state? Not trading ready; interstate trading requires multistate plan 5
