Baker Botts is actively engaged at all levels in advocacy efforts related to EPA’s proposed Clean Power Plan (CPP), which would establish for the first time carbon emission standards for the power sector under Section 111(d) of the Clean Air Act. As proposed, the CPP would be the most expansive, expensive and intrusive program in the history of EPA. Both prior to and following the proposal of the CPP, Baker Botts has worked to educate EPA and key environmental and citizen groups on innovative solutions that would moderate (although not eliminate) the potentially harsh impacts of the CPP. We continue to meet with EPA officials regarding the CPP, provide tools for clients to use with local and state agencies, and help clients develop long term plans that address the CPP. Baker Botts also is participating in the rulemaking process for EPA’s standards for new power plants under Section 111(b) of the Act, and helping clients develop and permit new generating resources.