EPA 111d finally here. But I have so many questions!

Last Monday, June 2, the EPA released its long awaited rules for its proposed carbon standards for fossil fuel power plants. I’ve been waiting for this for a while, and now (finally!) it’s moving forward and getting some national press.


This press, and this leadership from the federal government, this plan; these are good. But I’m left with so many questions. I’ll be patient. I know that states have a year to pull together their plans, and another year before anything is effective.

I admit I haven’t read the whole (645 page) report yet, or even the shorter, more readable (367 page) Regulatory Impact Analysis. (I know, get on it, Bob!) Since I was in Portland most of last week and I thought to myself “this is the perfect opportunity to ask my more informed colleagues about their initial impressions of the plan, and cut right to the chase.” Now my sample size was small, but on break at the CRAC meeting I had the opportunity to ask two (very wise, top of their class, highly informed) people their opinions, and I got in response two opposite answers. Well, if these two can’t agree on something this fundamental, then I’d better sharpen my pencil and read those thousand pages with a keen eye to figuring this out.

My question was: if we are to reduce carbon from end uses (ie, energy efficiency) can we get credit for the existing market activity, or must it be incremental activity. For example, in WA (and 25 other states) we have energy efficiency portfolio standards that require a certain level of conservation to be achieved like it or not. Can these achievements count towards this new federal plan for our state or not? Some say yes, some say no.

I have a few lists brewing that I will share shortly: observations, questions, a wish list, and a recommendations list. Stay tuned.