Comments on the U.S. EPA’s Clean Power Plan, Section 111(d)

  • Author(s): Todd Jones
  • Date: December 1st, 2014 | Comment | 30 Pages

  • CRS comments on the June 2014 Proposed Rule Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (the Clean Power Plan “Proposed Rule”). The comments focus on integrating renewable energy (RE) and existing RE markets, instruments, and tracking systems into 111(d) compliance and state plans; accounting and potential double counting of emissions and reductions; interstate tracking of electricity and challenges for state compliance; tracking RE and avoided emissions; and verification, monitoring, enforcement and recordkeeping for RE.

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