Various factors are driving the structure of the United States Environmental Protection Agency’s (EPA) proposed Clean Power Plan, including changes in utility business models and energy delivery and compliance technology. At a special briefing of the Gulf Coast Power Association on the Southwest Power Pool (SPP), David Farnsworth considers these factors and explores possible compliance paths, particularly those that lie “outside the building block box” of the EPA’s plan. The presentation outlines the pros and cons of several specific compliance strategies that SPP states might consider, and notes that states have an opportunity to lead the way on producing strategies that focus on least-cost options and future economic opportunities.