Going it Alone: Potential Interstate Problems of Intrastate Clean Power Plan Compliance

As evidenced by the 27 states that are suing the EPA, the agency’s recently-finalized Clean Power Plan(CPP) is controversial to say the least. In addition to the legal challenges facing the rule, there are also concerns over grid reliability posed by the large number of coal-fired generator retirements anticipated in the near term. Although much ink has been spilled on analyzing the Clean Power Plan, aside from discussions over grid reliability, little attention has been paid to other potential interstate effects posed by intra-state CPP compliance efforts, and vice versa. Despite the pitfalls posed by discordant state implementation plans within a region, the CPP nonetheless does not require regional collaboration. As argued in this essay, however, by failing to collaborate, states may not only put their own and neighboring states’ CPP compliance plans at risk, but also jeopardize existing and future regional electric system planning efforts.
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