Clean Air Act Section 111(d) CO2 Reduction Compliance Pathways for the Pacific Northwest and Intermountain West States
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Date
2015-06-12
Authors
Duncan, Angus
Journal Title
Journal ISSN
Volume Title
Publisher
University of Oregon School of Law
Abstract
The Article describes the architecture of a regional electric grid extending across nine Intermountain West (IMW) and Pacific Northwest (PNW) states, characterized by coal-fired generation on the east and south serving loads across the region including states to the west with few or no coal facilities but with significant loads and energy efficiency opportunities. This multi-state system architecture argues for an Environmental Protection Agency (EPA) Clean Air Act ยง 111(d) strategy that calculates the required Best System of Emissions Reduction (BSER) standard on both a state-by-state and a regional basis, and for a rule that affords states wide flexibility to enter into a range of multi-state compliance arrangements.
Description
38 pages
Keywords
Pollution
Citation
30 J. ENVTL. L. & LITIG. 303