Abstract:
The Article describes the architecture of a regional electric grid extending across nine Intermountain West (IMW) and Pacific Northwest (PNW) states, characterized by coal-fired generation on the east and south serving loads across the region including states to the west with few or no coal facilities but with significant loads and energy efficiency opportunities. This multi-state system architecture argues for an Environmental Protection Agency (EPA) Clean Air Act § 111(d) strategy that calculates the required Best System of Emissions Reduction (BSER) standard on both a state-by-state and a regional basis, and for a rule that affords states wide flexibility to enter into a range of multi-state compliance arrangements.