Pennsylvania and the Clean Power Plan: Towards a 111(d) Compliance Strategy

The Environmental Protection Agency released its proposed Clean Power Regulation in June 2014, and in mid-summer 2015, the finalized rule will be the first comprehensive regulation of carbon dioxide emissions from existing power plants in American history. Compliance strategies will be expensive and complex decisions for states to make. Each state faces the choice of whether to comply individually or as a region, but posses the freedom to comply in whatever way they choose. Pennsylvania is unique. The commonwealth has an entrenched coal industry, a nascent natural gas industry, and is a net exporter of electricity. Joining the Regional Greenhouse Gas Initiative (RGGI), a group of northeast states that borders Pennsylvania to the north, may be one compliance option, but joining a different region may be a more desirable lower cost solution. This analysis seeks to show that the cost of compliance would be lower if Pennsylvania joined a select group of states within the PJM Interconnection. One result of the analysis suggests that by joining with complementary states within PJM, relatively minor changes in Pennsylvania coal-fired generation would be required to meet Clean Power Plan compliance 2030 goals.