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”).
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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