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Cadmus Report Assesses State Options for Clean Power Plan Compliance

Posted By Kathleen Humphrey, Friday, May 15, 2015

Waltham, Mass., May 14, 2015—The Cadmus Group, Inc. (Cadmus) announced today that it had issued a final report for the Western Interstate Energy Board (WIEB) based on research exploring multi-state compliance options for the U.S. Environmental Protection Agency’s (EPA’s) proposed 111(d) rule, also known as the Clean Power Plan. The full report is available at

Under the proposed Clean Power Plan, EPA would establish numeric greenhouse gas emissions reduction goals for every state and require each state to develop and submit a compliance plan outlining how it will achieve and enforce those goals. States will be allowed to submit single-state or multi-state compliance plans.

The report, “Exploring and Evaluating Modular Approaches to Multi-State Compliance with EPA’s Clean Power Plan in the West,” assesses multi-state collaboration on select elements—referred to as “modules”—of state compliance plans that consider renewable energy, energy efficiency, and re-dispatch (supplanting coal and oil with lower-emitting natural gas) approaches to reducing emissions.

“Our principal findings indicate that the modular approach is indeed a valid strategy for compliance with the requirements of 111(d),” said Kate Wilson, primary author of the report and director of Cadmus’ greenhouse gas and sustainability reporting services. “Furthermore, our team found that the Western Renewable Energy Generation Information System (WREGIS), with some enhancements, is a potential platform to support this approach for the states in the Western Interconnection. The modular approach, supported by a system such as WREGIS, could benefit states as they approach 111(d) in that it is conducive to multi-state solutions without requiring one or more states that would like to cooperate to engage in complex negotiations and agreements on all compliance plan elements. It also offers the opportunity to lower overall compliance costs and allows greater compliance flexibility in cases where collaborating states offer comparative advantages. This research offers valuable insight for other states around the country looking to explore their compliance strategy.”

The report also identifies a range of policy considerations states will need to take into account before engaging in a modular approach and recommends ways of resolving them, with the caveat that EPA may address them in final 111(d) rules. The final 111(d) rule is expected this summer.

“Cadmus distilled complex technical material into a highly informative report for policymakers,” said Alaine Ginocchio of WIEB. “It describes what is needed to track and trade renewable energy and energy efficiency and demonstrate compliance with the Clean Power Plan. WIEB will continue to develop these ideas and the policy considerations identified.”

About The Cadmus Group, Inc.

Cadmus is an employee-owned consultancy committed to helping our clients address complex challenges by applying diverse skills and experiences in a highly collaborative environment. By assisting our clients in achieving their goals, we create social and economic value today and for future generations. Founded in 1983, we leverage our staff’s exceptional expertise in the physical and life sciences, engineering, social sciences, strategic communication, architecture and design, law, policy analysis, and the liberal arts to provide an array of research and analytical services in the United States and abroad. See more at

Tags:  111d  cadmus 

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