AEE submitted comments on the Proposed Federal Plan and Model Trading Rules, which are intended to ensure that the Clean Power Plan sends a uniform market signal across the country and facilitates state planning.

AEE supports EPA’s use of market-based trading in both mass- and rate-based compliance plans. However, AEE believes that certain elements of each plan type as proposed will impede the deployment of cost-effective advanced energy measures. Our comments identify revisions that will ensure these measures can compete fairly in the market for emission reductions, allowing states to capture the economic benefits of these technologies while reducing implementation costs.

Please complete the form to download the comment letter.