Lessons from Implementing the 1990 CAA Amendments

6 Pages Posted: 17 Nov 2010 Last revised: 20 Dec 2010

Date Written: June 1, 2010

Abstract

Lessons learned from implementing the Clean Air Act Amendments of 1990 by the General Counsel of EPA during passage and first year of implementation. Elliott argues that first main lessons to be learned from EPA's successful implementation of the 1990 Amendments were: 1. Establish and communicate clear priorities; 2. Develop a specific plan, with clear responsibilities and deadlines; 3. Early collaboration and cost-effective implementation; 4. Let others take the credit and win over the opposition; 5. Learn the lessons of history and keep it simple, stupid.

The main mistake that the author describes is being so focused on meeting statutory deadlines that matters that were important from a policy perspective (such as opt-in rules for trading) fell through the cracks if they had no mandatory deadline.

Keywords: Clean Air Act, implementation

Suggested Citation

Elliott, E. Donald, Lessons from Implementing the 1990 CAA Amendments (June 1, 2010). Environmental Law Reporter, Vol. 40, No. 10592, 2010; Yale Law & Economics Research Paper No. 419. Available at SSRN: https://ssrn.com/abstract=1709920

E. Donald Elliott (Contact Author)

Yale Law School ( email )

P.O. Box 208215
New Haven, CT 06520-8215
United States
202 256-4149 (Phone)

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