GLRPPR Sector Resource: State Implementation of CO2 Rules: Institutional and Practical Issues with State and Multi-State Implementation and Enforcement
State Implementation of CO2 Rules: Institutional and Practical Issues with State and Multi-State Implementation and Enforcement
EPA's proposed rule to regulate carbon dioxide emissions ("Section 111(d)" or the "CO2 Emission Guidelines") from electric generating units (EGUs), issued June 2, 2014, has triggered immediate analysis and commentary about the prudence and legality of EPA's approach under the Clean Air Act. This White Paper approaches the proposed rule from the perspective of states and focuses in particular on the institutional and practical challenges that states face in implementing the proposed rule.
Wilkenson Barker Knauer, LLP
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