Faced with Congressional inaction, the Administration has proposed to regulate CO2 emissions using existing authority. The §111(d) proposal attempts to incorporate cost-effective measures into this framework through innovative formulas. The EPA conducted an impact analysis illustrating the price, cost, and CO2 impacts under an assumed set of state compliance scenarios (although actual implementation approaches will vary more widely). We summarize the key features and primary implications of the rule from the perspective of a hydro asset with merchant exposure (although individual asset owner’s circumstances vary).

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Hydropower and the EPA Section 111(d) Proposal