NASEO Comments on EPA Clean Energy Incentive Program Design Details

NASEO submitted comments to EPA on design details for the proposed Clean Energy Incentive Program (CEIP) under the Clean Power Plan (CPP).

While not taking a position on the CPP, NASEO feels that it is important for states that choose to develop compliance plans and opt to participate in the CEIP to have wide flexibility and opportunity to craft least-cost approaches that also support other state energy and economic objectives.

The CEIP would make available to states matching early action incentive Emission Rate Credits or emission allowances to encourage certain renewable energy and low-income community energy efficiency and solar projects prior to the CPP’s main compliance period.

NASEO’s comments focus on flexible definitions of “low-income” to reduce administrative burdens; broadened criteria for energy efficiency, solar, and combined heat and power eligibility; clarification of several definitions and provisions in the proposed rule; reasonable measurement and verification provisions; and recognition of State Energy Office and Public Utility Commission expertise.

Date Posted: 8/31/2016