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EPA’s Clean Power Plan: Understanding and Evaluating the Proposed Federal Plan and Model Rules

December 2015

Citation: 45 ELR 11155

Issue: 12

Author: Julie DeMeester and Sarah Adair

The U.S. Environmental Protection Agency’s (EPA’s) Clean Power Plan was accompanied by model rules for states that provide both a mass-based and a rate-based approach. The model rules, once finalized, will give states a streamlined but customizable template that is trading ready. EPA also provided proposed mass- and rate-based federal plans that would be implemented absent state-promulgated plans. They are similar to the proposed model rules, but they exclude certain compliance options, such as demand-side energy efficiency under the rate-based approach. This Article explores the details and important aspects of these various compliance approaches.

Julie DeMeester is a Policy Assocaite, and Sarah Adair is a Senior Policy Associate, with the Nicholas Institute for Environmental Policy Solutions at Duke University.

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