Regulating Climate In A Climate Of Regulation

Law360, New York (November 18, 2009, 1:23 PM EST) -- The Obama administration has taken several tentative initial steps toward regulating greenhouse gases while also threatening a single transformative leap.

The tentative steps involve increasing fuel efficiency and decreasing GHG emissions from motor vehicles and requiring large GHG emitters to tally and publicly report their emissions.

The administration’s threatened leap is to regulate GHG emissions under the Clean Air Act (CAA).

If the U.S. Environmental Protection Agency ends up developing transformative GHG limits through regulation, it is likely that two major approaches to evaluating regulatory efforts...
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