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RAP experts keep their finger on the pulse of the energy sector and provide timely analysis of topics impacting stakeholders TODAY.
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September 15, 2016
Is It Time to Retool Regulation for Clean Air, Clean Energy?
- Ken Colburn ,
- Christopher James
Looking at the electric power industry today brings to mind the well-known April 1970 dispatch from Apollo 13: “Houston, we have a problem.” Actually, we have several. Prominent among them is the growing permeation of environmental issues into energy… View Summary +

February 1, 2016
Recognizing Early Action Under the Clean Power Plan
- Ken Colburn
Data suggest that the electric power sector’s long march toward decarbonization was already well underway before the EPA’s Clean Power Plan (CPP) rulemaking, let alone the final rule’s compliance period, which doesn’t begin until… View Summary +
December 2, 2015
Put the Horse Before the Cart: Align Clean Power Plan Compliance with State Energy Goals
- Ken Colburn ,
- Christopher James
Most states are still sorting through the details of EPA’s Clean Power Plan (CPP) final rule. Given its significant, though generally positive, departure from the proposed rule, and EPA’s initial plan submittal deadline of September 6, 2016,… View Summary +
October 1, 2015
Skate Where the Puck Is Going to Be
- John Shenot
Hall of Famer Wayne Gretzky once said, “A good hockey player plays where the puck is. A great hockey player plays where the puck is going to be.” Strangely enough, when I think about what lies ahead for electric… View Summary +

August 3, 2015
Hit the Ground Running on EPA’s Clean Power Plan: 12 Steps for Effective, Least-Cost Compliance
- John Shenot ,
- Ken Colburn
EPA is expected to finalize its Clean Power Plan (also known as its “111(d) rule”) today. Once published in the Federal Register, states may have only one year (or in some cases, two years) to develop initial… View Summary +
June 25, 2015
Reliability Standard: I Do Not Think it Means What you Think it Means
Much like the character Inigo Montoya who, in the movie The Princess Bride questions Vizzini’s relentless repetition of the word “inconceivable,” I find myself wondering whether many of those who insist over and over again that the EPA’s… View Summary +
May 22, 2015
Complying with the Clean Power Plan While Delivering Affordable, Reliable Power
- Ken Colburn ,
- John Shenot
Yesterday, the National Association of Clean Air Agencies (NACAA) released an important new resource: Implementing EPA’s Clean Power Plan: A Menu of Options (disclosure: RAP provided technical assistance and helped write the Menu). We believe the… View Summary +

February 9, 2015
Energy Efficiency as an Air Quality Strategy: Connecting the Dots Using a Mobile Source Analogy
- Ken Colburn
Every year states invest more than $6 billion in energy efficiency programs, which also improve air quality. Yet, states rarely receive any credit for the resulting emissions reductions! The benefits don’t stop with air quality. Energy efficiency not only reduces… View Summary +
July 9, 2014
Tackling 111(d): The Proposed Rule is Out, Now What?
- Ken Colburn
June 18th— the date EPA published its proposed rule to reduce greenhouse gas (GHG) emissions from existing power plants under section 111(d) of the federal Clean Air Act in the Federal Register—marked the beginning of a new… View Summary +
May 15, 2014
Tackling 111(d): Could Regional Approaches Rule?
- Ken Colburn
States have a long history of collaborating to achieve energy and environmental goals at lower cost and with greater efficiency than they could achieve alone. Collaborating to implement EPA’s forthcoming 111(d) rule may once again offer across-the-board… View Summary +