Greenhouse Gas Regulation Under the Clean Air Act: Structure, Effects, and Implications of a Knowable Pathway

Resources for the Future RFF DP 10-23

61 Pages Posted: 15 Apr 2010 Last revised: 17 Apr 2015

See all articles by Nathan D. Richardson

Nathan D. Richardson

University of South Carolina - Law Library; Resources for the Future

Arthur G. Fraas

Resources for the Future

Dallas Burtraw

Resources for the Future

Date Written: April 13, 2010

Abstract

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 implemented through the NSPS, yielding modest but meaningful emissions reductions. Trading could also rein in costs. Though analysis is limited to one sector and does not include modeling of costs, it suggests that CAA regulation, though inferior to comprehensive climate legislation, could be a useful tool for regulating stationary-source GHGs.

Keywords: climate policy, efficiency, EPA, Clean Air Act, NAAQS, coal

JEL Classification: K32, Q54, Q58

Suggested Citation

Richardson, Nathan D. and Fraas, Arthur G. and Burtraw, Dallas, Greenhouse Gas Regulation Under the Clean Air Act: Structure, Effects, and Implications of a Knowable Pathway (April 13, 2010). Resources for the Future RFF DP 10-23. Available at SSRN: https://ssrn.com/abstract=1589545 or http://dx.doi.org/10.2139/ssrn.1589545

Nathan D. Richardson

University of South Carolina - Law Library ( email )

1525 Senate Street
Columbia, SC 29208
United States

Resources for the Future ( email )

1616 P Street, NW
Washington, DC 20036
United States

Arthur G. Fraas

Resources for the Future ( email )

1616 P ST, NW
Washington, DC 20036
United States

Dallas Burtraw (Contact Author)

Resources for the Future ( email )

1616 P Street, NW
Washington, DC 20036
United States
202-328-5087 (Phone)

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