On October 23, 2015, the U.S. Environmental Protection Agency published in the Federal Register its final rules implementing the Clean Power Plan’s goal of significantly limiting carbon dioxide emissions from existing, new, modified and reconstructed fossil fuel-fired electric generating units. EPA also published its proposed model state trading rules and federal plans for implementation of the required emission reductions from existing EGUs. Updated information on the effective date of the final rules and the deadline for filing comments on the proposed rules is included in this alert. Submission of comments to EPA regarding the proposed rate- and mass-based federal plans for adoption on a state-by-state basis may still significantly impact regulation of EGUs in each state.
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