Preparing for CO2 Regulations for Existing Power Plants: Key Points to Look for in the Final Clean Power Plan Rule

In June 2014, the U.S. Environmental Protection Agency issued its Clean Power Plan rule, developed pursuant to section 111(d) of the Clean Air Act to reduce carbon dioxide emissions from the nation’s fleet of existing electric generating units. The agency will release the final version of the rule in August 2015. This final rule is expected to reflect some, perhaps significant, changes addressing the more than 4 million public comments on the proposed rule. This policy brief identifies the key elements in the final rule that could affect state implementation choices. These elements include potential changes in final state emissions targets, treatment of natural gas combined cycle units and under-construction nuclear units, rules and flexibility regarding rate-to-mass conversion, submission deadlines for state plans, and guidance regarding multi-state trading.