Guidance for Comments on the Proposed Federal Plan and Model Rules for the Clean Power Plan to Protect Voluntary Action

On November 19th we co-presented a webinar on the EPA’s Clean Power Plan (CPP), where we discussed the implications the plan will have on renewable energy markets in the U.S. There are several options being considered in the Proposed Federal Plan that will have lasting impact on these markets, and the EPA is accepting comments through January 21. We are asking that you consider submitting comments that support the inclusion of several program design elements.

The EPA has proposed two Federal Plans for the CPP. States that do not submit their own plan will be required to follow the Federal Plan. The two plans are also proposed as Model Trading Rules, which can be used by states when developing their own plans. The EPA may adopt a single Federal Plan and either a single Model Rule or two Model Rules (one for a rate-based target and one for a mass-based target).

Additional elements are needed in the proposed Federal Plan and Model Rules in order to avoid negative impacts to voluntary demand for and private investment in renewable energy. The good news is that there are proven regulatory mechanisms that have already been implemented in California and the Regional Greenhouse Gas Initiative in the Northeast U.S. to support and enhance the existing voluntary renewable energy market and deliver actual emissions reductions for voluntary investors.

Center for Resource Solutions has prepared guidance to stakeholders for comments on the EPA’s proposed Federal Plans and Model Rules to support continued investment in and growth of voluntary renewable energy. These recommendations have been endorsed by several other public interest nonprofits and clean energy industry stakeholders (as listed on the guidance) with knowledge of the important role that voluntary renewable energy purchases have had in driving recent clean energy development in the United States. We ask that you incorporate these recommendations into your comments on the proposed Federal Plan and Model Rules, which are due January 21, 2016.

To see the guidance, visit Guidance for Comments on the Proposed Federal Plan and Model Rules for the Clean Power Plan to Protect Voluntary Action.

Please contact Todd Jones at with any questions, or if you are interested in adding your name and organization to those endorsing these recommendations.