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; Vol. 80, Federal Register, No. 205, Friday, October 23, 2015

The Union of Concerned Scientists (UCS) submitted a public statement to the EPA supporting the Clean Power Plan (CPP) while advocating for a mass-based emissions trading approach for states subject to a federal implementation plan. UCS argues that a mass-based system provides greater certainty for achieving emissions budgets and better integration with future carbon markets. The document provides detailed recommendations for both rate-based and mass-based models, including the expansion of eligible zero-emission resources to include distributed generation and energy efficiency. It also proposes modifications to the Clean Energy Incentive Program (CEIP) to broaden project eligibility timelines and ensure benefits reach low-income communities. Additionally, UCS emphasizes the need to protect voluntary renewable energy markets and suggests implementing interim compliance provisions to prevent emissions deficits.

• UCS strongly recommends that the EPA adopt a mass-based emissions trading program for the federal plan, arguing it offers the "greatest certainty around true achievement of an emissions budget" and a lower administrative burden than rate-based approaches.
• For rate-based implementation, UCS supports the subcategorized rate approach to ensure consistency and enable interstate trading, but argues the EPA's list of eligible zero-emission resources is too narrow.
• UCS proposes expanding eligible resources under the rate-based federal plan to include demand-side energy efficiency (DS-EE), distributed generation, combined heat and power (CHP), and waste heat to power (WHP).
• To mitigate leakage in a mass-based approach, UCS advocates for the "new source mass complement" as the most effective option, though it suggests improvements to the EPA's alternative set-aside strategy, including increasing the renewable energy set-aside from 5 percent to at least 10 percent.
• UCS recommends that in federal-plan states where the state has not taken authority over allowance allocation, the EPA should distribute allowances to electric distribution utilities on a pro-rata basis rather than to affected electric generating units (EGUs) to avoid "windfall profits for generators".
• To ensure the integrity of the CPP, UCS suggests adding interim year compliance provisions requiring affected EGUs to surrender at least 50 percent of their emissions in intervening years of a compliance period.
• UCS argues that the CPP could harm the voluntary renewable energy market—which represents 26 percent of all non-hydro renewable generation nationally—unless mechanisms are created to ensure voluntary actions remain a "regulatory surplus".
• Regarding the Clean Energy Incentive Program (CEIP), UCS recommends shifting project eligibility to begin upon the submission of a state's "expression of intent to participate" (due September 6, 2016) rather than after the final plan submission to avoid stalling projects.
• UCS suggests that the EPA provide a rigorous framework for states to define "low-income community" for CEIP purposes, incorporating environmental justice indicators and utilizing tools like EJSCREEN.

APA

Cleetus, R., Clemmer, S., Deyette, J., McNamara, J., Richardson, J., Rogers, J., & Tsuchiya, A. (2016). 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; Vol. 80, Federal Register, No. 205, Friday, October 23, 2015. Union of Concerned Scientists. https://www.ucs.org/sites/default/files/attach/2016/01/UCS_CPP-FIP-MTR-Public-Submission_1-21-16.pdf

Chicago

Cleetus, Rachel, Steve Clemmer, Jeff Deyette, Julie McNamara, Jeremy Richardson, John Rogers, and Alyssa Tsuchiya. 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; Vol. 80, Federal Register, No. 205, Friday, October 23, 2015. Union of Concerned Scientists, 2016. https://www.ucs.org/sites/default/files/attach/2016/01/UCS_CPP-FIP-MTR-Public-Submission_1-21-16.pdf.

Wikipedia

{{cite press release |last1=Cleetus |first1=Rachel |last2=Clemmer |first2=Steve |last3=Deyette |first3=Jeff |last4=McNamara |first4=Julie |last5=Richardson |first5=Jeremy |last6=Rogers |first6=John |last7=Tsuchiya |first7=Alyssa |title=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; Vol. 80, Federal Register, No. 205, Friday, October 23, 2015 |publisher=Union of Concerned Scientists |date=21 January 2016 |url=https://www.ucs.org/sites/default/files/attach/2016/01/UCS_CPP-FIP-MTR-Public-Submission_1-21-16.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleetus2016federal, author = {Cleetus, Rachel and Clemmer, Steve and Deyette, Jeff and McNamara, Julie and Richardson, Jeremy and Rogers, John and Tsuchiya, Alyssa}, title = {{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; Vol. 80, Federal Register, No. 205, Friday, October 23, 2015}}, publisher = {Union of Concerned Scientists}, year = {2016}, month = jan, url = {https://www.ucs.org/sites/default/files/attach/2016/01/UCS_CPP-FIP-MTR-Public-Submission_1-21-16.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }