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Full-Text Articles in Law
International Greenhouse Gas Offsets Under The Clean Air Act, Nathan D. Richardson
International Greenhouse Gas Offsets Under The Clean Air Act, Nathan D. Richardson
Faculty Publications
Offsets, and in particular international offsets, have been advanced as an important tool in climate policy, capable of significantly reducing the costs of emissions reductions. As attention turns to the existing CAA as a potential vehicle for general reduction of GHG emissions, an important question is whether regulation under the statute is compatible with international offsets. Certain regulatory programs under the CAA are likely candidates for GHG regulation, but many of them are legally incompatible with international offsets. Those programs that might permit use of international offsets have other problems that make them unpopular choices for GHG regulation. To the …
Greenhouse Gas Regulation Under The Clean Air Act: Structure, Effects, And Implications Of A Knowable Pathway, Nathan D. Richardson, Arthur G. Fraas, Dallas Butraw
Greenhouse Gas Regulation Under The Clean Air Act: Structure, Effects, And Implications Of A Knowable Pathway, Nathan D. Richardson, Arthur G. Fraas, Dallas Butraw
Faculty Publications
It appears inevitable, absent legislative intervention, that regulation under the Clean Air Act (CAA) will move beyond mobile sources to the industrial and power facilities that emit most U.S. greenhouse gas (GHG) emissions. We analyze the mechanisms available to the EPA for regulating such sources, and identify one, New Source Performance Standards (NSPS) as the most predictable, likely, and practical, i.e. knowable, pathway. Based on the legal structure of the NSPS and the EPA’s traditional approach, we analyze a hypothetical GHG NSPS for one sector, coal electricity generation. This analysis indicates that efficiency improvements and perhaps biomass cofiring could be …