Comments on Clean Power Plan Federal Plan Requirements and Model Trading Rules

January 21, 2016

The Georgetown Climate Center submitted comments in response to the proposed Clean Power Plan Federal Plan Requirements and Model Trading Rules. These comments were built on discussions the Center had with states as they consider their options for developing plans, and on prior research conducted by the Center on the linking of subnational emissions trading programs, but they do not necessarily reflect the views of individual states.

GCC fed-model plan comments.pdf