State Implementation of CO2 Rules V2.0

WBK attorneys Ray Gifford, Greg Sopkin and Matt Larson released a new white paper today, titled “State Implementation of CO2 Rules: Institutional and Practical Issues with State and Multi-State Implementation and Enforcement.” This paper incorporates feedback from the original paper, and also updates the analysis to include the Notice of Data Availability (NODA), issued by EPA on October 28, 2014.