A new paper, “Use of ‘Third-Party Entities’ for State and Federal Implementation of the Clean Power Plan: Issues and Options,” explores possible roles for private or public sector entities to help states implement components of the Clean Power Plan (should it be upheld by the courts).
Third-party entities (TPEs) could help relieve states and the EPA of administrative burdens while facilitating the incorporation of energy efficiency as well as renewable, nuclear, and other resources for Clean Power Plan (CPP) compliance. TPEs could provide registry and related services to support state issuance and management of emission rate credits (ERCs) and allowances. Such functions can include document management, verifying project eligibility, accrediting Independent Verifiers, reviewing electricity generation and savings claims, and providing tracking infrastructure for ERCs or allowances.
The paper was prepared by Clean Air Act expert attorneys from Van Ness Feldman, L.L.P. NASEO, while not taking a position on the CPP, provided review comments in order to support wide state flexibility and reduced state burden should the CPP proceed.