The Clean Power Plan: Carbon Trading, State Legislation and the Political Economy Issue

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 …

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.

EPA’s CO2 Rules and the Cooperative and Municipal Question

WBK attorneys Ray Gifford, Greg Sopkin and Matt Larson issued a new white paper today, titled “EPA’s CO2 Rules and the Cooperative and Municipal Question.” The opening question for this Paper is: What enforcement issues arise under the proposed rule given the scope of the Building Blocks and existing regulatory authority with regard to cooperatives and municipal utilities?

State Implementation of CO2 Rules

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 …