On December 1, 2014, WLF filed formal comments with the Environmental Protection Agency (EPA), urging it to abandon a proposed rule that would establish unrealistic carbon emissions standards for existing power plants. WLF expressed concern that the EPA, by effectively requiring States to completely reengineer their electric utility grids to satisfy EPA’s “goals,” was exceeding the scope of its statutory authority under the Clean Air Act (CAA). At the same time, WLF noted, the proposed rule would undermine the States’ primary authority under Section 111(d) of the CAA to devise flexible implementation plans that will not unduly burden the States’ citizens and businesses. WLF also cited studies showing that higher energy costs triggered by the proposed rule would have a devastating economic impact on the American economy.