States may want RPS tweaks for climate rule
The report digs into how states could count RPS achievements to meet the agency’s power-sector carbon limits.
“Fundamentally, under either mass-based or rate-based state plans, state RPSs can continue to operate as they have done previously,” the authors wrote, referring to the options EPA gives for meeting the climate targets. However, they added, “states may choose to increase their RPS targets or harmonize their eligibility rules” if the regulation survives legal challenges.
State RPS policies differ around the country and may not match EPA’s requirements exactly, said Ed Holt, a consultant who wrote the report as part of the group’s RPS Collaborative, which is funded by the Department of Energy and the Energy Foundation.
For one, EPA will only give states credit for incremental renewable energy added in 2013 and later. Many state RPS programs give credit to projects from before then.
For states that aim for an average rate of emissions, only energy produced between 2022 and 2030 will count under EPA’s rule. Some renewable power that comes online in 2020 and 2021 could get credit under the agency’s Clean Energy Incentive Program.
States could change their programs to match EPA’s requirements for simplicity’s sake, although that is not required. They may also want to consider whether they will need to increase their RPS targets to help with Clean Power Plan goals, Holt said.
RPS policies could play into state implementation plans differently, depending on what kind of plan states pick.
If a state chooses to cap carbon emissions, RPS programs could indirectly help states meet EPA goals by displacing fossil fuel power.
If a state aims for an average rate of emissions, a credit in an RPS program might qualify as a credit for Clean Power Plan compliance.
But the two types of credits must be tracked separately. States may need to build upon existing RPS tracking systems to make new Clean Power Plan credit trading systems, according to the report.
An RPS credit and a Clean Power Plan credit may represent the same unit of zero-carbon power, and it may be ineffective for two different entities to own credits for the same unit of power because they may not achieve the emissions reductions they intend, the report adds.