In 2015, the U.S. EPA faced an aggressive deadline to review 4.3 million public comments on its Clean Power Plan, which aims to curb carbon emissions from existing power plants. Using RTI-CHARM, a tool developed by RTI experts in environmental regulation, we were able to help the EPA process those comments and understand and evaluate issues important to the public.
Facing the Challenge of Unprecedented Public Input
Power plants account for roughly one-third of U.S. carbon emissions. Under the President's Climate Action Plan, in June 2014 the EPA proposed the Clean Power Plan to cut carbon emissions from existing power plants.
An issue as complex as power plant regulation requires extensive participation from the public. When the EPA opened the Clean Power Plan for public input, more than 4.3 million comments streamed in. The EPA faced an aggressive deadline to review these comments, analyze them, and integrate the results into the final rule.
Managing and Summarizing Public Comments with the RTI-CHARM Tool
When the EPA chose us to review comments on the Clean Power Plan, we assembled a team of dozens of experienced rule development professionals. The team used our own Comment Handling and Response Manager, or RTI-CHARM, to store, manage, and prepare summaries from more than 24,000 excerpts from comment letters within four months after the close of the comment period.
We converted the stream of comments on a diverse array of issues, such as state goal computation, state plan development, carbon capture and storage, and other measures to reduce greenhouse gas emissions into actionable information for the Clean Power Plan.
We also helped process public comments in support of two additional EPA rulemaking proposals closely related to the Clean Power Plan—the New Source Performance Standards (NSPS) for new fossil fuel–fired electric utilities, and a set of carbon pollution standards for modified and reconstructed fossil fuel–fired electric utilities.
Our experts in electric utility emissions provided technical support for all three rules aimed at cutting carbon pollution from the electric utility sector.
Understanding and Integrating Public Comments
The summaries we provided helped the EPA quickly understand and begin to evaluate issues important to the public. The EPA was able to address the issues and put the final rule into effect within nine months of the close of the public comment period—remarkably fast considering the volume of comments received and the precedent-setting nature of the rule itself.
Unveiled in August 2015, the Clean Power Plan is expected to cut U.S. carbon pollution from the power sector by 870 million tons by 2030, reducing air pollution and resulting in cost savings for electrical customers.