This letter provides comments to the U.S. Environmental Protection Agency on Clean Power Plan FIP and Model Trading Rules. In sum, this letter offers broad suggestions that should be addressed by EPA in any final rule. These comments are offered to EPA independent of the question of the legality of the CPP and this proposed rule. Most significantly, these comments do not supersede or alter the comments, litigation position, or opinions of any state and should not be viewed as representing the perspective of any individual state.
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