The EPA Clean Power Plan and State RPS Programs

May 18, 2016

by Edward A. Holt, Ed Holt & Associates, Inc.

Ed Holt of Ed Holt & Associates has written a wide-ranging new report on the relationship between EPA’s Clean Power Plan (CPP) and state RPSs. Among the topics covered are:

  • the options states have when they develop state plans
  • the role of RPS programs in helping states achieve emission targets under the CPP
  • EPA requirements for demonstrating state performance in meeting CPP emission standards
  • whether renewable energy certificates used for RPS compliance or voluntary claims are counting the same thing that is being used to measure CPP performance
  • how existing REC tracking system infrastructure could help market participants track ownership of CPP compliance instruments and help states verify their CPP performance
  • whether state RPSs would motivate incremental emission reduction benefits after implementation of the CPP
  • the interaction of the CPP with voluntary renewable energy markets
  • how the CPP may affect pre-existing clean energy contracts and state motivations for RPS harmonization.

This report was prepared for the RPS Collaborative by Edward A. Holt of Ed Holt & Associates, Inc. The RPS Collaborative is a project of the Clean Energy States Alliance (CESA).