The Midcontinent Power Sector Collaborative (formerly Midwestern Power Sector
Collaborative) is a diverse stakeholder group formed in 2012 to engage EPA and states on the
regulation of carbon dioxide emissions from power plants in the Midcontinent region.
Participants include state officials, investor-owned utilities, generation and transmission
cooperatives, merchant generators, public power producers and environmental organizations
from the Midcontinent region or with a significant presence in the region.
The Collaborative is facilitated and staffed by the Great Plains Institute.
On August 3, 2015, EPA finalized its Clean Power Plan (CPP) emission guidelines to states under
Section 111(d) of the federal Clean Air Act. The CPP requires states to develop and submit for
approval state plans that implement the CPP emission guidelines. In states that for whatever
reason do not submit an approvable state plan to EPA by the regulatory deadline, EPA will
impose a federal plan to implement the emission guidelines.
Simultaneously with the issuance of the final Clean Power Plan emission guidelines, EPA
proposed a draft federal plan that consists of two model trading rules—one mass-based and
one rate-based. The model trading rules can also be used by states in their state plans. EPA
noticed the proposed federal plan and model trading rules in the Federal Register on October
23, 2015 and is providing a 90-day comment period, which ends January 21, 2016.
What follows are the Collaborative’s comments on the proposed federal plan and model
trading rules.
