Virginia Stakeholders Group for Clean Power Plan Report of Activities and Recommendations, April 18, 2016

On April 18, 2016, the Virginia DEQ released a report on the activities and findings so far of Virginia’s Clean Power Plan stakeholders group, which met five times from November 2015 to March 2016.  According to that report,  “[N]o further meetings [of the stakeholders group] are planned at this time, [but] DEQ will evaluate whether additional meetings are needed after several utility integrated resource plans (IRPs) and other studies become available in May 2016.”  Access to the stakeholder group’s report in available at the DEQ’s “Greenhouse Gases” Web site, online at, as of 5/10/16).

Following is an excerpt from the summary of recommendations in the April 2016 report: “The group came to consensus that a source performance standards plan was preferred over a state measures plan.  There was general agreement that Virginia should wait until additional studies are released (anticipated in May 2016) before making a decision about mass vs. rate (e.g., release of IRPs from Dominion and American Electric Power, the PJM Regional Transmission Organization study, etc.).  Although the group did not come to consensus as to whether the compliance plan should be mass- or rate-based, there was consensus/general agreement on specific mechanisms for either approach.  A mass-based plan should contain or consider the following: Program should be trading-ready [and] must address leakage (i.e., shifting generation to new plants); Allowance allocation should be based on historical generation or emissions; [the plan should] allow early retired units to keep allowances through their useful life to ensure coverage for rate payers; include trading, banking, and borrowing of allowances; [plan should] provide some set aside of allowances; recognize the importance of renewables in the allowance allocation method.  A rate-based plan should contain or consider the following: Program should be trading-ready; [the plan should have] a reliability safety valve; [there should be] a national registry for generating verifiable allowances and credits; [there should be] price transparency; [the plan should] include EPA model rule safety valve language, include biomass and combined heat and power, and include all types of renewable and low-emission sources.”

For a discussion of the “mass-based” and “rate-based” alternatives for complying with carbon-emission reductions under the Clean Power Plan, see Navigating the Clean Power Plan Maze, Bacon’s Rebellion, 2/16/16.

For more on the Clean Power Plan, please see the Water Central News Grouper post, Final Version of “Clean Power Plan” Announced by President Obama and the U.S. EPA on August 3, 2015.

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