Comments on “Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations,” Docket ID No. EPA-HQ-OAR-2015-0199

The Environmental and Energy Study Institute (EESI) submitted comments to the U.S. Environmental Protection Agency (EPA) regarding the proposed Federal Implementation Plan (FIP) and model trading rules for greenhouse gas emissions from electric utility generating units. EESI advocates for a more holistic approach that gives equal weight to biomass, combined heat and power (CHP), and demand-side energy efficiency alongside other renewables. The organization also emphasizes the need to protect environmental justice communities from pollution 'hot spots' created by trading schemes and suggests improvements to the Clean Energy Investment Program (CEIP) to better support low-income housing and energy retrofits.

• EESI argues that the proposed FIP and model trading rules fail to adequately recognize a full range of carbon reduction tools, specifically neglecting technologies for energy efficiency in buildings, combined heat and power (CHP) systems, and waste utilization.
• The organization expresses concern that trading schemes may negatively impact environmental justice communities by allowing power plants to purchase allowances instead of reducing local emissions, potentially creating localized pollution 'hot spots'.
• EESI recommends that the EPA implement price floors and ceilings for allowances and Emission Reduction Credits (ERCs) to prevent market distortions and ensure they remain an incentive for emissions reductions.
• The document highlights the critical role of the building sector, noting it consumes over 70 percent of total generated electricity and accounts for one-third of national carbon emissions, necessitating a focus on deep-energy retrofits and net-zero construction.
• EESI advocates for the inclusion of biomass in the FIP and model trading rules, citing its potential to replace 100 Gigawatts of coal generation and its ability to monetize waste streams that would otherwise emit greenhouse gases through landfilling or open burning.
• Regarding the Clean Energy Investment Program (CEIP), EESI suggests allowing projects installed after September 6, 2016, to qualify, arguing that the current proposal may incentivize developers to delay construction until 2018.

APA

Environmental and Energy Study Institute (n.d.). Comments on “Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations,” Docket ID No. EPA-HQ-OAR-2015-0199. https://www.eesi.org/files/CPP_EESI_FIP_comments_1.21.16_final.pdf

Chicago

Environmental and Energy Study Institute. Comments on “Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations,” Docket ID No. EPA-HQ-OAR-2015-0199. n.d. https://www.eesi.org/files/CPP_EESI_FIP_comments_1.21.16_final.pdf.

Wikipedia

{{cite press release |author=Environmental and Energy Study Institute |title=Comments on “Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations,” Docket ID No. EPA-HQ-OAR-2015-0199 |url=https://www.eesi.org/files/CPP_EESI_FIP_comments_1.21.16_final.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{environmentalandenergystudyinstitutendcomments, author = {{Environmental and Energy Study Institute}}, title = {{Comments on “Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations,” Docket ID No. EPA-HQ-OAR-2015-0199}}, publisher = {Environmental and Energy Study Institute}, url = {https://www.eesi.org/files/CPP_EESI_FIP_comments_1.21.16_final.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }