Even for all the gloom and doom surrounding the coal industry lately, coal will still account for more U.S energy production in 2017 than any other resource according to the U.S Energy Information Administration. Coals comeback marks a rebound from 2016 where, for the first time, U.S electricity from natural gas exceeded output from coal-fired power plants. But with higher natural gas prices on the horizon, coal should once again take the top energy producing …
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 …
The New EPA Building Block 3 and the Final Rule
Ray Gifford, Greg Sopkin and Matt Larson have issued a white paper, entitled “The New Building Block 3 and the Final Rule.”
EPA’s CO2 Rules and the Common Elements Approach
Ray Gifford, Greg Sopkin and Matt Larson released a new white paper, “EPA’s CO2 Rules and the Common Elements Approach,” on April 28, 2015. The Common Elements Approach leaves many significant questions remaining to be addressed. Until these issues are resolved, states cannot consider the approach or variations on this approach as a viable compliance option…
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?
EPA’s CO2 Rules and the State Institutional Problem
WBK attorneys Ray Gifford, Greg Sopkin and Matt Larson released a new white paper today, titled “EPA’s CO2 Rules and the State Institutional Problem.” The Opening Question for this Paper is: Are new institutional arrangements and state legislation necessary to implement the proposed CO2 Emission Guidelines?
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 …