The Clean Power Plan (“CPP”), and its companion new source review rule, is the Obama Administration’s signature regulation on reducing greenhouse gas emissions from power plants. Among other things, it requires states to put in place programs designed to reduce overall nationwide carbon emissions from existing power plants by 32% by 2030 compared to 2005 levels. Issued as a regulation by EPA in 2014, it has faced tough times from the get-go – and things are only getting worse.
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