NRECA filed comments with the U.S. Environmental Protection Agency (EPA) in support of the agency's proposal to repeal the Clean Power Plan (CPP). The nature, consumers served, size and generation portfolios of electric cooperatives set them apart from others in the electric utility industry, and thus present immense challenges for co-ops if forced to comply with CPP mandates. NRECA encourages EPA to propose and finalize a Section 111 regulation to address carbon dioxide for existing electric generating units consistent with the agency's legal authorities and historic traditional source-focused approach--meaning standards that can be achieved at the unit without requiring curtailed operation or unit shutdown. FULL FILING