A hedging strategy for sec. 111(d).
Kyle Danish and Doug Smith are partners, and Avi Zevin is an associate, at Van Ness Feldman, LLP, a law firm with offices in Washington, DC and Seattle that represents clients in matters relating to energy, the environment, natural resources, land use and real estate, and government relations. Mr. Danish focuses on regulation, permitting, enforcement, and policy under the Clean Air Act. Mr. Smith concentrates on utility and energy regulation, and previously served as General Counsel at the Federal Energy Regulatory Commission. Mr. Zevin assists clients with matters related to climate and clean air regulation and policy, energy efficiency, renewable energy, and natural gas transportation.
By December 2, 2014, almost 4 million comments were filed on the Environmental Protection Agency's (EPA) proposed Clean Power Plan, a proposal to reduce carbon dioxide (CO2) emissions from existing power plants.1 In January, EPA announced that it plans to finalize its Clean Power Plan rule in the summer of 2015. State compliance plans will be due a year later, in the summer of 20162 While the schedule is set, there remains substantial uncertainty — about the shape of the final rule, about whether Congress will step in, and about the outcome of expected legal challenges.