CPP Replacement Plan Launches Debate On State Flexibility, NSR Overhaul

摘要

EPA's advance notice of proposed rulemaking (ANPRM) seeking input on a narrow replacement for the Obama-era Clean Power Plan (CPP) tees up discussion of a rule limiting greenhouse gas (GHG) cuts to those obtainable from plant efficiency improvements, while suggesting the agency might give states maximum flexibility to limit requirements, including whether any federal standards would be "binding."