Clean Energy Incentive Program: Basics and Next Steps

The Clean Energy Incentive Program (CEIP) is EPA’s program to incentivize early investment in solar and wind renewable energy generation and energy efficiency programs in low-income communities.

What is the CEIP? 

The CEIP, which was first introduced by the EPA in the final CPP, is an optional program through which states may generate, prior to the commencement of the CPP compliance period, “two for one” emission rate credits (ERCs) and emission allowances.  A participating state may award ERCs or set aside a portion of its allowance budget for new renewable generation projects that commence construction or new energy efficiency programs in low-income neighborhoods that commence operations after the submission of a state’s final plan and that generate (in the case of renewable energy) or save (in the case of energy efficiency) MWh during 2020-2021.   EPA will then grant up to a specified cap matching credits and allowances.

Specifically, the CPP provides that it will award early credits and allowances up to an amount equal to 300 million short tons of carbon emissions in the following manner:

  • For every 2 MWh of qualifying renewable energy generation, the state may award 1 early action ERC to the project, and EPA will award 1 matching early action ERC to the state to award to the project.
  • For every 2 MWh of energy savings from qualified energy efficiency programs, the state may award 2 early action ERCs to the project, and EPA will award the state with 2 matching early action ERCs.

The earned credits and allowances may be applied (or transferred) during the compliance period to meet the state’s CPP emission goals.

How can a state participate?

In order to participate in the program, the state must include in its September 6, 2016 submittal (whether that is the state’s initial submittal or the final plan) a non-binding statement of intent to participate in the plan.   The EPA is also proposing to implement the CEIP in states in which it implements a federal implementation plan.

How will the details be developed? 

What does it mean to “commence construction” or “commence operations,” how will EPA implement the CEIP in states that choose mass-based compliance, how will CEIP-eligible programs be certified, how will energy savings be verified, and what communities qualify as “low-income”?

All good questions, with no current answers.  While the CPP outlines the CEIP framework, the details have not yet been worked out.  EPA is in the process of seeking input from stakeholders about how it should design the details of the program.  In late October, EPA released CEIP Next Steps [link eliminated], detailing more information about the program and seeking input from stakeholders.  More information is also available in the slides [link eliminated] from a November 12 EPA webinar for communities.

Additionally, EPA is holding a series of stakeholder calls, and has established a non-regulatory docket, Docket No. EPA-HQ-OAR-2015-0734, for stakeholders to provide written comments through December 15, 2015 on the CEIP.  Stakeholders may also submit written comments, before January 21, 2016, on the inclusion of the CEIP in the proposed Federal Plan and Model Rules (Docket No. EPA-HQ-OAR-2015-0199).

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Affordable Housing and Energy Efficiency

Although EPA removed energy efficiency from the building blocks in the final CPP, energy efficiency remains available to states as a compliance option.  Energy Efficiency for All’s Clean Power Plan Opportunities for Energy Efficiency in Affordable Housing focuses on approaches to promote energy efficiency in affordable housing.   The report notes that energy efficiency in affordable housing provides benefits beyond CPP compliance, including reducing living costs and improving indoor air quality.  The report mentions the Clean Energy Incentive Program, EPA’s incentive program to encourage energy efficiency investments in low-income communities, as a way to help overcome the lack of alignment between who pays for and who benefits from these investments.

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In Case You Missed It: MISO’s Clean Power Plan Workshop

On November 6, 2015, the Midcontinent Independent System Operator (MISO) hosted a Clean Power Plan Workshop to provide stakeholders and interested parties with a primer on the CPP final rule (slides available here).

Highlights included a closer look at how the EPA calculated the rate and mass targets included in the final rule, slides 15-31, and an overview of emission rate credits and allowances, slides 59-76. Presenters provided a high-level run through of states’ avenues for compliance, trading approaches and the contents of the proposed Federal Plan.

The workshop also offered a quick summary of MISO’s study efforts related to the CPP. A timeline for MISO’s final rule analysis is located on slide 85 of the presentation. In particular, MISO plans to conduct its near-term analysis and present results incrementally in December 2015-February 2016, conduct mid-term analysis and follow-up modeling, and then complete a draft report to share with stakeholders and publish a final report in May-June 2016.  MISO encouraged interested stakeholders to participate in the Planning Advisory Committee.

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Opportunities for Nuclear Power in the Clean Power Plan

EPA recently released a fact sheet on Opportunities for Nuclear Power in the Clean Power Plan.  Specifically, new nuclear generation—including new reactors that come on-line and uprates (capacity increases at existing facilities)—can be counted toward meeting state goals.  EPA details how states can use allowances in a mass-based plan to incentivize additional nuclear capacity.  And in a rate-based plan, new and uprated nuclear may be eligible to receive emission rate credits, a tradable compliance instrument.

Last week also saw an announcement by President Obama of various initiatives intended to sustain and advance nuclear energy.

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Tribes and the Clean Power Plan

On November 18, 2015, the Department of Energy Office of Indian Energy Policy and Programs and the Western Area Power Administration will be hosting a webinar from 1:00-2:30 PM EST entitled EPA Clean Power Plan: What Tribes Need to Know.  Presenters from the EPA will discuss what tribes should know about the CPP and the proposed Federal Plan and Model Rules. Registration is available here.  An agenda has not yet been released.

There are several aspects of the CPP that have the potential to affect tribes directly.  Included among these are the fact that tribes with qualifying clean energy projects located or implemented in their area may be able to participate in emission rate credit and emission allowance trading markets.

Further, EPA finalized CO2 emission guidelines for four electric generating units (EGUs) located on tribal lands: the South Point Energy Center on the Fort Mojave Reservation, the Navajo Generating Station and the Four Corners Power Plant on the Navajo Indian Reservation, and the Bonanza Power Plant on the Uintah and Ouray Indian Reservation.

The tribes with affected EGUs located on their tribal lands may, but are not obligated to, seek “Treatment as States” (TAS) and apply for eligibility to develop and implement tribal implementation plans (TIP).  Alternatively, EPA may itself directly implement the emission guidelines if it makes a finding that is “necessary or appropriate” to do so.  In the Proposed Federal Plan and Model Trading Rules, EPA has proposed to make such a finding.  Its grounds for so doing are that the affected EGUs

are in an area of Indian country located within the continental United States, are interconnected with the western electricity grid, and are owned and operated by entities that generate and provide electricity to customers in several states.

While EPA is proposing to implement a federal plan for the affected EGUs, it has stated that this proposal does not preclude tribes from seeking TAS to either develop a tribal plan or to receive delegated authority to administer all or portions of the federal plan.  Comments on the Proposed Federal Plan are currently due on January 21, 2016, but this date may change as EPA has not yet acted on the Navajo Nation’s request for a 60-day extension of time on the comment period.

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