​On August 3, 2015, the United States Environmental Protection Agency (“EPA”) signed the final Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units under Clean Air Act (“CAA”) section 111(d) (“111(d) Rule,” “Clean Power Plan,” or “CPP”) and proposed Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Constructed On or Before January 8, 2014; Model Trading Rules; Amendments to Framework Regulations implementing the 111(d) Rule (“Proposed Federal Plan (FP) /Model Trading Rules”). 1 The 111(d) Rule and proposed FP/Model Trading Rules were published in the Federal Register on October 3, 2015. See 80 Fed. Reg. 64,662 (111(d) Rule); 80 Fed. Reg. 64,966 (Proposed FP /Model Trading Rules). Comments on the Proposed FP/Model Trading Rules are due on January 21, 2016, although the National Rural Electric Cooperative Association (“NRECA”) has asked EPA to extend the comment period by sixty days to allow NRECA and its smaller utility member cooperatives additional time to analyze the complex proposal. FULL FILING