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ARTICLE · 09 AUGUST 2013

The President's Climate Action Plan: What Might It Mean For Existing Coal-Fired Plants?

The President recently issued a Climate Action Plan directing the U.S. Environmental Protection Agency to issue final "standards, regulations, or guidelines, as appropriate," pursuant to Sections 111(b) and 111(d) of the Clean Air Act to "address carbon pollution from modified, reconstructed, and existing power plants," no later than June 1, 2015.

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Earlier this summer, the President issued a Climate Action Plan (CAP) directing the U.S. Environmental Protection Agency (EPA) to issue final "standards, regulations, or guidelines, as appropriate," pursuant to Sections 111(b) and 111(d) of the Clean Air Act (CAA) to "address carbon pollution from modified, reconstructed, and existing power plants," no later than June 1, 2015 (one year after issuing its proposal next year). EPA is in the process of devising a regulation to implement this broad directive. This Environmental Client Alert explores the potential details and options that EPA may propose and, to the extent possible at this early stage, suggests some impacts.

The CAP Requirements

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