Ray Gifford, Greg Sopkin and Matt Larson released a new white paper, “The Clean Power Plan: Carbon Trading, State Legislation and the Political Economy Issue,” on October 21, 2015. The  notion  of  headroom  available  for  states  in  the  Western  Interconnection and Texas Interconnection assumes the accuracy and feasibility of the inputs to EPA’s BSER formula. The BSER formula in the Western Interconnection and Texas Interconnection yielded carbon budgets that no state could reasonably achieve.  The …