The National Association of Regulatory Utility Commissioners (NARUC) and the Eastern Interconnection States Planning Council have released a resource guide to help states overcome institutional barriers and coordinate on Clean Power Plan compliance.
The Multistate Coordination Resources for Clean Power Plan Compliance guide—which was funded by the Energy Department—includes a multi-state planning checklist, a legislative language examples checklist, and a sample memorandum of understanding for multi-state coordination. The planning checklist can help states organize decisions to assess benefits of multi-state coordination versus going it alone, NARUC said.
States do not need to enter into a multi-state compliance plan with a joint target, nor do they need to enter into as sophisticated and interdependent agreement structure as the Regional Greenhouse Gas Initiative to benefit from talking and coordinating, NARUC clarified.
“A range of interactions is possible, from simple awareness of each others’ plans to the transfer of emissions reductions between states that have individual-state plans and targets (not a multi-state plan to meet a joint target) when states have ‘common elements’ in their compliance plans,” it said.
According to NARUC Executive Director Charles Gray, the process of developing state implementation plans by the summer of 2016 will be “complex” and coordination may prove frustrating. “We can help reduce some of that frustration by providing a workable starting point,” he said.
A number of tools are being developed by entities to help states put together compliance plans. Organizations like the Midcontinent States Environmental and Energy Regulators and the Nicholas Institute at Duke University are developing modeling and conceptual multistate compliance pathways for adoption by the states, the document notes. Meanwhile, the National Association of Clean Air Agencies is developing a model compliance plan that states can customize to their own needs.
In comparison, NARUC’s guidance document is simply to help states create institutional bridges between public utility commissions, governors, energy advisors, and the lead agencies (generally, state air pollution control agencies) that are responsible for the creation and filing of state implementation plans.
—Sonal Patel, associate editor (@POWERmagazine, @sonalcpatel)