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Clean Energy Incentive Program Comments Due to the EPA by December 15, 2015

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By Nikhil Vijaykar, MEEA Senior Policy Associate

The U.S. Environmental Protection Agency (EPA) published its final Clean Power Plan (CPP) in the Federal Register on October 23, 2015. The Clean Power Plan is aimed at reducing carbon emissions from existing power plants. As a part of the final Clean Power Plan, the EPA provided a Clean Energy Incentive Program (CEIP) to reward early investments in renewable energy (RE) generation as well as demand-side energy efficiency (EE) measures in low-income communities, which generate carbon-free MWh or reduce end-use energy demand in the two years preceding the start of the CPP compliance period (2020-2021).  EPA will make additional “matching” federal credits available to states electing to participate in the CEIP, in order to further incentivize early reductions from RE and EE in low-income communities.

Public Comments on the Clean Energy Incentive Program

Although parties may no longer submit comments on the Emission Guidelines established by the CPP, EPA is accepting comments on the CEIP through December 15, 2015. Interested parties may submit their input using one of the following methods:

EPA Docket Center
Environmental Protection Agency, Mail Code: 28221T
Washington, D.C. 20460

Parties submitting comments should identify the Docket ID Number corresponding to the Clean Energy Incentive Program: EPA-HQ-OAR-2015-0734. MEEA will be submitting its comments on the CEIP to the EPA, based on its experience with energy efficiency policy and programs in Midwestern states.

EPA is specifically interested in hearing input on the following questions:

What should EPA consider when defining criteria, terms and requirements under the CEIP?

  • What definition(s) of ‘low-income community’ should be required for eligible energy-efficiency (EE) projects?
  • What criteria should be used to define eligible wind and solar projects, as well as eligible EE projects implemented in low-income communities? (e.g., by sector (residential, commercial, etc.) or by geography (where a project takes place and who benefits from it))
  • What should be the evaluation, measurement and & verification (EM&V) requirements for eligible projects; the requirements for M&V reports of quantified megawatt-hour (MWh); and the requirements for verification reports from an independent verifier?
  • How could EPA set criteria for states, tribes and territories for which goals have not yet been established in the final Clean Power Plan’s Emission Guidelines (EGs) to participate in the CEIP?
  • What commencement date is appropriate for a project to qualify as eligible for the CEIP?
  • How should ‘commence construction’ of an eligible wind or solar project and ‘commence operations’ of an eligible low-income EE project be defined?
  • Should CEIP allowances or emission reduction credits (ERCs) be available for projects in jurisdictions without affected entities (e.g. tribal lands and states without EGUs).  If so, how should the CEIP mechanism be designed to address these areas?

What should EPA consider regarding the timing and distribution of allowances under the CEIP?

  • How should the 300 million short ton CO2 emissions-equivalent matching pool be allocated among states participating in the CEIP?
  • How should the 300 million short ton matching pool be split between the two reserves: one for wind/solar, one for low-income EE?
  • When should EPA allocate matching allowances or emission reduction credits (ERCs) to a state, and when should awards from these allocations be made to eligible project providers?
  • How should matching allowances or ERCs that are allocated to a state but not awarded to eligible projects be redistributed among other states with unmet demand for matching allowances or ERCs, and when should this redistribution take place?

What should EPA consider when designing the mechanics of the CEIP?

  • What are the appropriate mechanisms a state (in the case of a state plan) or EPA (in the case of a federal plan) should use to review project submittals and issue early action allowances or ERCs?
  • How should the 300 million short ton CO2 emissions-equivalent matching pool be converted into ERCs, which are based on MWh?
  • What mechanisms should EPA consider for maintaining the stringency of rate-based emission standards during the compliance periods to account for the issuance of early action ERCs for MWh generated or avoided in 2020 and/or 2021?

CEIP Calls with EPA

EPA is hosting four calls prior to the comment deadline in order to gather input from key stakeholders.  This input will help EPA in designing further action specifying the design and implementation details of the CEIP.  During each call, EPA will provide a brief overview of the CEIP and then will invite participants to provide their input. EPA will give participants up to three minutes to present their remarks.

Call 1 was held on Tuesday, November 10, 2015, and focused on input from potential CEIP project providers.

 

The details of the forthcoming calls are as follows:

Call 2: Focus – Potential CEIP Project Partners. This call will focus on hearing ideas and input from groups that have a general interest in CEIP projects such as environmental justice groups, community groups, local governments, tribes, and environmental non-governmental organizations.

Date: Monday, November 23, 2015
Time: 7:00 – 9:00 p.m. EST
Participant Dial-in Number: (877) 290-8017
Conference ID#: 72559715

 

Call 3: Focus – Potential CEIP Credit Issuers. This call will focus on hearing ideas and input from states and tribes with affected power plants.

Date:  Monday, November 30, 2015
Time: 2:00 – 4:00 p.m. EST
Participant Dial-in Number:  (877) 290-8017
Conference ID#: 72560287

 

Call 4: Focus – General.  This call will focus on hearing ideas from stakeholders who were unable to attend one of the first three sessions.

Date: Tuesday, December 1, 2015
Time: 3:00 – 5:00 p.m. EST
Participant Dial-in Number: (877) 290-8017
Conference ID#: 72558409