EPA Guide On State GHG Targets Raises Fears Over 'Race To The Bottom'

摘要

EPA's just released guide on how to convert states' rate-based greenhouse gas (GHG) targets to mass-based limits under the agency's proposed rule for existing power plants offers a series of "examples" for how to calculate the mass limits that many states say are crucial if they are to consider multi-state trading programs as a compliance option. But sources say the fact that the guidance, released Nov. 6, gives states options for how they make those calculations - and the assumptions they can use about future electricity demand - does little to assuage concerns that states will likely choose approaches that will weaken overall targets, driving a race to the bottom among states eager to limit any harmful economic impact from the rule. Relevant documents are available on InsideEPA.com. Seepage 2 for details. "As long as it's wide open as to what a state might choose, if a state has the option, they're going to look for which one they do best under, and that's going to lower stringency," says a source tracking the rule. And some regulators and power sector officials are concerned that allowing states to use inconsistent approaches could pose equity issues because some states could succeed in winning EPA approval of a more favorable conversion process than other states. Speaking a day before the guidance was released, Holly Rachel Smith, an assistant general counsel of the National Association of Regulatory Utility Commissioners, told a Nov. 5 event hosted by the Energy Bar Association that she has "heard some concerns about the transparency and fairness that would exist with regards to making that conversion."