EPA may pursue a dual approach in its pending cap-and-trade proposal to cut sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions that would impose state-specific caps with few restrictions on intrastate trading, alongside regional caps that would impose stricter restrictions on interstate trading, a wide range of sources say.rnHowever, the so-called dual emissions cap approach could create new legal headaches for EPA, after several federal court rulings raised fresh uncertainty over the agency's flexibility in establishing novel trading programs.
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