Early Reduction Credits Under Lieberman-Warner

Law360 (May 9, 2008, 12:00 AM EDT) -- The "Early Action" provisions of S. 2191, the Lieberman-Warner Climate Security Act, are of critical import to companies that have taken, or are in the process of taking, steps to reduce their greenhouse gas (GHG) emissions.

While S. 2191 purports to provide some pre-enactment credit for early actions that reduce GHG emissions through the distribution of additional allowances to Early Action companies, the relevant provisions are open to considerable interpretation.

Moreover, as drafted, the legislation gives the Environmental Protection Agency (EPA) wide discretion in establishing the...
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