Prevailing Academic View on Compliance Flexibility Under § 111 of the Clean Air Act
Resources for the Future Discussion Paper No. 11-29
21 Pages Posted: 2 Jan 2012 Last revised: 9 Apr 2014
Date Written: July 13, 2011
EPA will soon propose performance standards under Section 111 of the Clean Air Act for greenhouse gas pollution from the two largest emitting stationary source sectors — fossil-fueled power plants and petroleum refineries. The form these standards will take remains unclear. A key issue that will shape the effectiveness of the regulations is the degree to which they enable regulated entities to use flexible approaches to achieve the standards. This discussion paper provides the content of a letter to EPA Administrator Jackson that describes areas of general academic agreement on the EPA’s authority to use compliance flexibility options under Section 111 of the Clean Air Act in the development of performance standards for greenhouse gas emissions.
Keywords: source category, existing sources, state implementation plan, new sources, tradable performance standards
JEL Classification: K32, Q54, Q58
Suggested Citation: Suggested Citation