Frank Swigonski and Caitlin Marquis

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EPA GHG REGS: We Read the Comments, So You Don't Have To, Part 2: States

Posted by Frank Swigonski and Caitlin Marquis on Jan 5, 2015 3:57:00 PM

After the comment period closed on December 1, the stats were in: EPA received more than 1.6 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 second 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 state utility commissions (PUCs and PSCs), air regulators (DEQs and DEPs), and lawmakers.

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While many states, including Washington, Minnesota, and New Hampshire, have praised the Clean Power Plan, others have raised technical and economic concerns with various aspects of the proposal, and 17 attorneys general submitted a joint comment letter outlining numerous legal objections to the Proposed Rule. AEE has not yet analyzed comments from every state. However, we have identified common themes submitted by state agencies in some key states which are watched closely by AEE. Below is a summary of comments from Arkansas, Arizona, Florida, Illinois, Michigan, Nevada, Pennsylvania, Texas and Virginia, focusing on themes found throughout comments from these and other states.
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Topics: EPA GHG Regs

EPA GHG REGS: We Read the Comments, So You Don't Have To, Part 1: State & Federal Regulator Associations

Posted by Frank Swigonski and Caitlin Marquis on Dec 22, 2014 2:46:00 PM

After the comment period closed on December 1, EPA received more than 1.6 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 first 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. First up, State and Federal Regulator associations.

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The North American Electric Reliability Corp. (NERC) released a report in early November calling for an analysis by regulators and power companies to determine whether the Clean Power Plan’s initial 2020 deadline can be met without threatening reliability. NERC’s report questioned whether there would be enough time to build natural gas pipelines and high voltage transmission lines for gas and renewables to replace coal generation. While NERC did not submit its own comments, the NERC report was cited by many organizations in their comments on the Clean Power Plan. AEE’s supplemental comments address this issue by demonstrating the ways that advanced energy technologies can enhance grid reliability while states shift generation to comply with the Proposed Rule.

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Topics: EPA GHG Regs

EPA GHG REGS: Post-Election State Roundup on the Clean Power Plan

Posted by Frank Swigonski and Caitlin Marquis on Nov 24, 2014 10:00:00 AM

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The midterm election saw energy and environment issues play front-and-center in many campaigns--but now that the votes have been cast, the implications of campaign rhetoric  remain uncertain. Amid discussion of Keystone XL, LNG exports, and possible compromise on energy efficiency legislation is speculation that the GOP-controlled Senate may target the EPA’s Clean Power Plan. At the state level, several gubernatorial transitions could also have implications for the implementation of the plan.

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Topics: EPA GHG Regs