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EPA’s Proposed Rule: Federal Plan Requirements for Greenhouse Gas Emissions From Electric Utility Generating Units Open Access

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The questions or whether to develop a “mass-based” or “rate-based” emissions trading program under that rule arise in the context of EPA’s EPA’s proposed Clean Power Plan or Federal Implementation Plans, so we are re-filing the comment in the current docket for the Agency’s consideration. The comment concludes that a rate-based trading program, similar to the EPA’s successful program for trading lead in gasoline in the 1980s, has compelling advantages over a mass-based program.

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