Adele Morris of the Brookings Institution reports that state of Virginia has submitted comments on the EPA's Clean Power Plan that call for additional flexibility in compliance options. Significantly, the Virginia comments were very similar to those that Morris has been advocating, in her push to get states to consider a state carbon tax, and to have a state carbon tax be an option for complying with section 111(d). Morris and others met with Virginia state officials three months ago to discuss a state carbon tax and suggested comments, so apparently that meeting went pretty well.
This is a potentially huge development, because Virginia is a very carbon-intensive state. Under the EPA proposed rule, Virginia is expected to reduce its emissions from a rate of 1438 lbs. of CO2/net MWhr to 884 by 2020, and to 810 by 2030. That a state that is politically purple and with a very important coal industry is considering a state carbon tax is much more significant then if this was under consideration in a state like Massachusetts or Washington.