EPA’s CO2 Rules and the Common Elements Approach – April 28, 2015

Ray Gifford, Greg Sopkin and Matt Larson released a new white paper, "EPA’s CORules and the Common Elements Approach," on April 28, 2015. 

The Common Elements Approach leaves many significant questions remaining to be addressed. Until these issues are resolved, states cannot consider the approach or variations on this approach as a viable compliance option…