Comments from CPC on EPA's Advance Notice of Proposed Rulemaking

Clean Air-Cool Planet Encourages EPA to think
‘Economy-Wide’ in Reducing GHG Emissions

Clean Air-Cool Planet encourages the U.S. EPA to put forward an economy-wide cap-and-trade program if it moves to regulate greenhouse gas emissions (GHGs) under the Clean Air Act.  EPA had asked for comment on regulatory options to deal with climate change following Supreme Court’s 2007 rejection, in Massachusetts v. EPA, of Bush Administration arguments that EPA lacked authority to regulate GHGs under the Clean Air Act.

CA-CP’s comments recognize that the best way to achieve an effective and economically efficient program to reduce GHGs, which have global impacts, is through new legislation.  However, in the absence of Congressional action, EPA can and must act, and CA-CP’s detailed analysis shows how EPA can implement a nation-wide cap-and-trade program as the basic framework for reducing U.S. GHG emissions.

CA-CP also argues that a careful reading of the act would allow EPA to include transportation fuels, as well as stationary sources, under the cap, and to provide both a floor price and a safety valve to control costs and limit the volatility of the GHG permit market. For the details, click below:

Download Climate Policy Center Response (PDF, 158 KB)

  See the EPA Advance Notice of Proposed Rulemaking