Commenting on Carbon

Deck: 

State PUCs take on EPA and its Clean Power Plan.

Fortnightly Magazine - March 2015
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Everything about the Clean Power Plan seems surreal. States complain of unfair treatment. Regulators read the proposed rule and sound warnings of a coming apocalypse.

If the plan should go into effect as proposed last summer by the U.S. Environmental Protection Agency (see Docket EPA-HQ-OAR-2013-0602, 79 Fed. Reg., 34, 830, June 18, 2014, hereinafter "Proposed Rule"), we could end up seeing oddities like these:

• The most coal-dependent states - nine out of ten of them (Ky., N.Dak., Wyo., W.Va., Mont., Neb., Iowa, Kan., and Mo.) - would face EPA-mandated cuts to CO2 emissions totaling less than the national per-state average (see Figure 1),

• Arizona, an average emitter (with 1.88 percent of all CO2 emissions covered under the plan), would face a mandated final cut of 5.16 percent - more than 2.5 times its share of the nationwide total (see Figure 2),

• Iowa, lacking a state RPS rule ("Renewable Portfolio Standard"), would be excused under the plan from adding more renewables, as it has already met its EPA-assigned "Block 3" target - 15 years early.

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