The Most Controversial Aspects of the CPP: Interim Deadlines

Since the draft Clean Power Plan (CPP) was released in June 2014, one of the most controversial aspects of the plan has been the interim deadlines imposed on states. The EPA’s proposed plan calls for a 30 percent reduction in carbon emissions from 2005 levels by 2030 and sets state-by-state emission targets, beginning as early as 2020. Because of the way interim targets are designed, 80 percent of states must achieve more than half of their 2030 emission goals by 2020 (in less than five years) and 11 states must achieve 75 percent or more of their 2030 goals by 2020, in some instances just a couple of years after state compliance plans would have been approved.

Among many points of contention surrounding the draft plan, the interim deadlines have been the source of intense stress among states. Some states are lobbying for the right to create their own plans for demonstrating progress (i.e., complete flexibility to define the transition as it suits them), but up to this point the EPA has held the cards with regard to implementation and approval policies. Concerns have been raised about the deadline for demonstrating progress as early as 2020, and there have been suggestions that the plan could cause electric reliability problems across the country or significant increases in costs and rates. The EPA has repeatedly hinted that the interim goals will change, but the agency hasn't talked publically about what will replace them in a final rule due this summer.

In just the last couple of weeks, the EPA has intensified “hints” by suggesting that interim goals for existing power plants to comply could be softened before the rule is finalized this summer. EPA Administrator Gina McCarthy has publicly stated that changes to the 2020 date are “very, very much on the table.” At the same time, however, McCarthy has also been quoted as saying  “We clearly need to make sure there is trajectory towards a goal that is as far away as 2030 and that there is an ability to ensure that states are actively working on a trajectory to achieve that final goal.” Further, Acting Assistant EPA Administrator Janet McCabe recently suggested to a Senate committee that the administration is prepared to loosen the timeframe on early interim goals under the Clean Power Plan (CPP).

So adjustments to the interim targets are likely in the works, but what does this mean? The EPA could also simply move the starting year to 2025, but that wouldn't give states as much time to work on regional coordination, build power plants, and bulk up pipeline and power line infrastructure. And this issue is not just about convenience for states and impacted load-generating entities; the interim deadlines are being challenged in large part due to very significant concerns about impacts to reliability across the U.S. electricity grid that could result from the proposed timetable of the CPP.

It is important to remember that all new infrastructure must be planned, permitted, approved by state officials, reviewed for reliability impacts, and built. Completing a natural gas pipeline can take five years; the planning, siting, and construction of new natural gas power plants require four to eight years; and completing a transmission line can take up to eight years or more.
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