The EPA’s proposed Clean Power Plan (CPP) allows states to build their implementation plan on any combination of policies that the state deems appropriate to meet the carbon emission reductions. Fact sheets released by the EPA list a variety of potential mechanisms that states could use to comply with CPP, including:
Easy enough right? Looking past the daunting task of selecting a combination of strategies that would enable a state to comply with CPP, the question then becomes one of tracking and verifying compliance. This is especially important as states investigate joint implementation plans or market-based compliance strategies.Simply switching to generation with lower carbon emissions is easy enough to track: if coal generation is ramped down and replaced natural gas generation, carbon emission reductions can be easily calculated. But how do you track the avoided carbon emissions from demand-side management programs, or transmission efficiency improvements, or energy storage?