Tackling 111(d) Compliance Planning: It’s Not a SIP!
States asked the U.S. Environmental Protection Agency (EPA) for flexibility in crafting plans to meet the requirements of the proposed Clean Power Plan (also known as 111(d), after the pertinent section of the Clean Air Act), and EPA listened. EPA’s proposal uses four broad “building blocks” (heat rate improvements, re-dispatch to natural gas, non-emitting generation…