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The Clean Power Plan and Statutory Interpretation: Is the "Building Block" Approach Permissible Under §111(d)?

July 2015

Citation: ELR 10650

Author: David R. Baake

In June 2014, EPA proposed an emission guideline for emissions of carbon dioxide (CO2) from existing fossil fuel-fired electric generating units (EGUs). This rulemaking--commonly known as the Clean Power Plan (CPP)--identifies as the “best system of emission reduction” a set of four “building blocks” that electric utilities can undertake or purchase credits for to reduce emissions from regulated EGUs. This Comment considers whether the building block approach is permissible under CAA §111(d).

David R. Baake is a Ford Foundation Post-Graduate Fellow and Associate Advocate at the Natural Resources Defense Council.

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