On August 21, 2018, the Administration proposed a new rule to replace the Clean Power Plan. The “Affordable Clean Energy” or “ACE” rule covers a number of different areas; however, EPN’s comments are focused on the proposed revisions to EPA’s implementing regulations for emissions guidelines. As former EPA employees, EPN members are particularly experienced in addressing changes to rules that provide general procedures for state planning obligations. EPN’s comments provide suggestions to strengthen or clarify sections of the rule and identify changes that should not be adopted, either because they are inconsistent with the Clean Air Act, or because they would weaken or confuse the program.
Read a summary of the comments: EPN Summary of Comments on CPP-ACE 111(d) Implementation Regulation
Read the full comments: EPN Comments on CPP-ACE 111(d) Implementation Regulation