The proposed Clean Power Plan to reduce carbon emissions from existing power plants is a long overdue turning point in America’s response to climate change.

EPA’s approach gives the states tremendous flexibility to design strategies that work best for them. States have always been incubators of innovation, and they will drive technological and policy innovation as they encourage low-cost solutions to implement the plan.

We need to encourage that innovation – by cities, states, and businesses — to show the path forward to a clean energy economy.

C2ES submitted comments today as part of the EPA’s process to seek stakeholder input to the proposed rule before finalizing it in June 2015.

Here are five suggestions that could make EPA’s framework even better.

1. EPA should view the Clean Power Plan as a stepping-stone to a nationwide, comprehensive, market-based carbon policy.

An economy-wide, market-based carbon policy would be the most cost-effective way to bring down domestic greenhouse gas emissions. Since this would require legislation, which is unlikely in the near-term, the Clean Power Plan is a critical step toward a broader program. EPA should take this opportunity to prepare states and power companies for such a program by developing model provisions to promote interstate cooperation, market-based approaches, and consistent policies across state lines.

2. The plan should not discourage new load, such as electric vehicles, that can cut emissions on a system-wide basis.

The proposal does not differentiate between a typical use of electricity that increases emissions and one that offsets emissions elsewhere, such as electric vehicles. While we support the proposal’s general incentives to promote efficiency and reduce demand, we have suggested some changes to ensure carbon-cutting load is not discouraged.

3. The plan should encourage maintaining the existing nuclear fleet.

EPA views nuclear generation as playing a critical role in our clean energy future, which is a position we support. However, the proposal does not provide strong incentives for states to maintain their nuclear fleets, and in some cases could actually encourage states to shift from nuclear to natural gas generation. We have suggested an alternative approach to existing nuclear generation that would avoid this problem.

4. The emissions target “glide path” should be softened, with no net loss of emissions reductions, to allow for long-term planning and investment.

EPA has proposed an interim target for each state to achieve across the 2020-2029 timeframe. These interim targets assume that states can quickly ramp up their use of existing natural gas power plant capacity to replace coal. Since the interim targets are therefore relatively stringent, they could force states to focus on short-term solutions, such as investment in new natural gas capacity, instead of long-term solutions, such as investment in zero-carbon generation. Softening these interim targets could help push states toward zero-carbon generation in the long-term. States opting for the less-steep glide path would need to reach a higher target to ensure the integrity of the overall effect of the rule.

5. EPA should encourage energy efficiency measures regardless of when or where the associated emission reductions take place.

States will need to come to an agreement about how energy efficiency or clean energy investment is counted when electricity crosses state lines. EPA should help states overcome this challenge in ways that ensure all energy efficiency improvements can be properly recognized and rewarded, regardless of when the efficiency policies were put in place or whether they reduce electricity imports in addition to reducing domestic generation.

EPA’s framework provides a great opportunity for state and business innovation. Enhancements to the final Clean Power Plan can create the environment for even greater results. We urge EPA to stick to its timeline for submitting a final rule in June 2015 and we look forward to working with states and stakeholders to forge practical, innovative implementation strategies.