Frank Swigonski and Caitlin Marquis

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EPA GHG REGS: While Oklahoma Just Says ‘No,’ Other States Say, ‘Maybe’ - and Move Toward Advanced Energy

Posted by Frank Swigonski and Caitlin Marquis on Jun 3, 2015 5:28:00 PM

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All links to bills lead to AEE’s PowerSuite. Click to sign up for a free 14-day trial. This blog post is excerpted from a newsletter that went out to members in late May. For the most up-to-date information on what's passing through legislatures, check them out in PowerSuite!

As legislative sessions start to wrap up in some states, AEE continues to track legislation that may impact compliance strategies. ALEC bills — legislation that requires approval of state implementation plans by the legislature — were introduced in 27 states so far. Ten bills were passed, but most of them with  language weaker than when they were initially introduced. Even in states hostile to the Clean Power Plan, stakeholders and regulators are quietly exploring compliance options. And some states are making moves toward greater use of advanced energy, which would make CPP compliance easy.

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Topics: EPA GHG Regs

EPA GHG REGS: State Bills to Thwart Compliance with the Clean Power Plan Run into Opposition - from Utilities

Posted by Frank Swigonski and Caitlin Marquis on Mar 30, 2015 4:36:34 PM

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All links to bills lead to AEE’s PowerSuite. Click to sign up for a free 14-day trial.

As the release of EPA’s final Clean Power Plan (CPP) approaches, utilities, regulators, and state officials across the country are weighing compliance options. After the final rule is released mid-summer, and after a lot more analysis and deliberation, states will craft implementation plans (SIPs) tailored to their particular circumstances. In some states, however, legislators have introduced bills aiming to slow or block their state’s compliance with the CPP. Increasingly, this legislation is meeting with resistance from stakeholders—most importantly, utilities.

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Topics: EPA GHG Regs

EPA GHG REGS: We Read the Comments, So You Don't Have To, Part 5: Industry Groups and Environmental Groups

Posted by Frank Swigonski and Caitlin Marquis on Jan 26, 2015 5:41:00 PM

After the comment period closed on December 1, the stats were in: EPA received more than 4 million comments on the Clean Power Plan from individuals, organizations, and state regulatory bodies. It would take 71 people working eight hours a day from now until June to read them all. But don't worry—our Carbon Policy Analysts identified the top comments and plowed through them. This is the fifth of five blog posts presenting AEE’s summary of and take on comments from a few key stakeholders: federal and state regulatory organizations, states, ISO/RTOs, utilities, and industry and environmental groups. This final post covers comments from industry groups and environmental groups.

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In its comments, AEE emphasized the greater role advanced energy technologies could play in the Final Rule, making suggestions ranging from strengthening the renewable and energy efficiency targets to providing guidance on EM&V to clarifying that a variety of advanced energy technologies will be accepted in state compliance plans. Many industry associations, NGOs and private-sector companies submitted their own sets of comments, some of which took positions that aligned closely with AEE’s. While AEE presented a unique perspective in its comments, a very diverse group of organizations and companies share its positions on many key issues.

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Topics: EPA GHG Regs

EPA GHG REGS: We Read the Comments, So You Don't Have To, Part 4: Utilities

Posted by Frank Swigonski and Caitlin Marquis on Jan 19, 2015 11:29:03 AM

After the comment period closed on December 1, the stats were in: EPA received more than 4 million comments on the Clean Power Plan from individuals, organizations, and state regulatory bodies. It would take 71 people working eight hours a day from now until June to read them all. But don't worry—our Carbon Policy Analysts identified the top comments and plowed through them. This is the fourth of five blog posts presenting AEE’s summary of and take on comments from a few key stakeholders: federal and state regulatory organizations, states, ISO/RTOs, utilities, and industry and environmental groups. This post covers comments from major utilities and utility groups.

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Utilities reacted strongly to EPA’s Proposed Rule. The Edison Electric Institute, which represents most of the country’s IOUs, filed 400 pages of comments; one of EEI’s key messages was that the rule fails to ensure reliable operation, which echos comments from states and ISOs/RTOs. Nearly all of the comments from individual utilities also contain some discussion of the Proposed Rule’s impact on reliability.

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Topics: EPA GHG Regs

EPA GHG REGS: We Read the Comments, So You Don't Have To, Part 3: ISOs and RTOs

Posted by Frank Swigonski and Caitlin Marquis on Jan 12, 2015 3:28:00 PM

After the comment period closed on December 1, the stats were in: EPA received more than 4 million comments on the Clean Power Plan from individuals, organizations, and state regulatory bodies. By one estimate, it would take 71 people working eight hours a day from now until June to read them all. But don't worry—our Carbon Policy Analysts identified the top comments and plowed through them. This is the third of five blog posts presenting AEE’s summary of and take on comments from a few key stakeholders: federal and state regulatory organizations, states, ISO/RTOs, utilities, and industry and environmental groups. Here, we cover the reactions of ISOs and RTOs.

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The chief concern of the Independent System Operators (ISOs) and Regional Transmission Organizations (RTOs) is how the Proposed Rule will affect reliability of the grid. These concerns were summarized in comments filed by the ISO/RTO Council (IRC) and signed by all nine ISOs and RTOs in the U.S. IRC proposed that the Final Rule require reliability assessments during the planning and implementation of state plans (SIPs), and that EPA should establish criteria for evaluating how SIPs will impact reliability. IRC also proposed that the Final Rule give more time to build new transmission infrastructure, not only for natural gas as proposed in the NODA, but also for electricity. Most importantly, IRC outlined a detailed proposal for an RSV, which would allow states to exceed their emission targets if reliability were threatened by an unforeseen event such as extreme weather or energy shortage.  IRC envisioned a well-defined process through which an ISO, RTO, or entity responsible for reliability would administer an RSV. The RSV process would be overseen by NERC.
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Topics: EPA GHG Regs