On Friday, July 11, 2014 WBK released a White Paper entitled “State Implementation of CO2 Rules: Institutional and Practical Issues with State and Multi-State Implementation and Enforcement” addressing the institutional and practical challenges that states face in implementing EPA proposed CO2 Emission Guidelines issued pursuant to Section 111(d) of the Clean Air Act. The White Paper analyzes the proposed rule’s impact on state regulatory institutions and the effects of the overlay of a CO2-driven regulatory …