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Playing Without Aces: Offsets And The Limits Of Flexibility Under Clean Air Act Climate Policy, Nathan D. Richardson
Playing Without Aces: Offsets And The Limits Of Flexibility Under Clean Air Act Climate Policy, Nathan D. Richardson
Nathan D Richardson
The U.S. Environmental Protection Agency (EPA) continues to move ahead with regulation of greenhouse gas emissions under the Clean Air Act (CAA). Previous work has indicated that basic forms of compliance flexibility—trading—appear to be legally permissible under the relevant part (Section 111) of the CAA. This paper takes a close look at more expansive and ambitious types of flexibility: trading between different kinds of sources, biomass co-firing, and, above all, offsets. It concludes that most types of such extended flexibility are either legally incompatible with the CAA, or so legally problematic that EPA is unlikely to adopt them. This has …