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Expert Analysis

CPP Rollback May Impact SO2 Emissions Trading Markets

By David Fotouhi, Gibson Dunn & Crutcher LLP (December 16, 2016, 11:43 AM EST) -- If the U.S. Environmental Protection Agency's Clean Power Plan is jettisoned or substantially scaled back by the D.C. Circuit or the next administration, then the resulting short-term regulatory uncertainty and the potential tapering of recent declines in sulfur dioxide emissions may affect sulfur dioxide emissions allowance prices. Although modifications to the Clean Power Plan will have the most direct effect on greenhouse gas emissions, participants in sulfur dioxide emissions trading markets should carefully monitor market reactions and real-world emissions data as they engage in compliance planning in the coming years....

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