Trad able Standards for Clean Air Act Carbon Policy

摘要

EPA faces a series of choices as it decides on its approach for regulating stationary-source GHG emissions. It must decide whether to incorporate flexibility, what role to leave to states, and how stringently to regulate—in addition to myriad technical and procedural issues.rnAdopting a tradable standard, in a phased fashion and through a model rule, could balance competing interests and create a comprehensive, cost-effective regulatory program (given that the Agency has eschewed cap and trade). Tradable standards are fundamentally flexible, and evidence suggests that they would lead to very large cost savings over inflexible, traditional standards. Politically, tradable standards cannot be characterized as a cap-and-trade approach, because they do not establish a cap. The important role for states may also shield EPA from some political criticism.