Hundreds of ideas, one proposal: How EPA developed the Clean Power Plan

With all the coverage of EPA’s Clean Power Plan, I wanted to take a few minutes or a few hundred words to tell you about the process we followed to write our 645-page proposal. The bottom line is that it is the product of many months of hard thinking and data analysis by EPA staff and substantial input from literally thousands of thoughtful stakeholders.

President Obama Announces His Climate Action Plan

On June 25, 2013, President Obama announced his Climate Action Plan and issued a Presidential Memorandum directing EPA to use section 111(d) of the Clean Air Act to cut carbon pollution from existing power plants. This wasn’t the first time the agency had considered using section 111(d). Since the 2007 Supreme Court decision in Mass vs. EPA, the agency has been considering its authorities to address carbon pollution under the Clean Air Act. In fact, a 2008 advanced notice of proposed rulemaking examined a number of regulatory approaches including section 111. And using Section 111d made a lot of sense, since the Clean Air Act established it for addressing existing sources of pollution not covered by other parts of the Act.

What We Heard

Immediately following the President’s announcement and at his direction, the agency embarked on an extensive public outreach process—one that reached thousands of people through hundreds of meetings, listening sessions, video conferences, phone calls, conference calls, and almost two thousand emails from individuals across the country. We talked to states, power companies, local communities, environmental groups, associations, labor groups, Tribes, and many more. This process was a critical component in developing this rule because it helped focus our attention on what was going on—on the ground—in states and communities across the country, and it generated public discussion and ideas from numerous groups and individuals that helped inform our thinking.

So, What Did We Hear?

  • We heard that flexibility is key, so we maximized flexibility in our proposal letting states chart their own course that builds on the progress they’ve already made.
  • We heard that states could cut pollution more cost-effectively if we, and they, looked at the energy system as a whole, so we allowed states to look across the system to find reductions.
  • We heard that the power sector is interconnected and it crosses state lines, so in addition to proposing that each state develops its own plan, we also proposed to allow states to work together to develop plans, depending on what suits their situation.

We didn’t just hear these ideas from one group or even one sector; we heard them from just about everyone. And what emerged was a collection of ideas—or threads—that guided us as we crafted our proposal.

Weaving it All Together

Over the past year, dozens of EPA scientists, lawyers, economists, health experts, policy analysts, and many others wove the threads we heard along with our own extensive analysis, data, and information into the proposal we announced on June 2.  If you look closely you may see some of the threads you contributed or heard throughout the outreach process.

One of the great values of the transparent process we used, and will continue to use, to collect input from the public is that no one person or group has the only, or best, idea.  It takes all of us contributing our information and suggestions to fashion a good, workable rule that meets the requirements of the law and achieves meaningful public health and environmental benefits.  And EPA’s proposal does just that. It is a proposal that is based on what’s going on in the real world, cuts carbon pollution, protects public health and moves us toward a cleaner, healthier environment for future generations, while supplying the reliable affordable power needed for economic growth.

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