Comment on Developing a Comprehensive Approach to Climate Change Mitigation Policy in the United States: Integrating Levels of Government and Economic Sectors
Date | 01 August 2009 |
Author |
8-2009 ENVIRONMENTAL LAW AND POLICY ANNUAL REVIEW 39 ELR 10723
Comment on Developing a
Comprehensive Approach to Climate
Change Mitigation Policy in the
United States: Integrating Levels of
Government and Economic Sectors
by Robert D. Brenner and Anna Marie Wood
Robert D. Brenner is the Director of the Oce of Policy Analysis and Review (OPAR) in the Oce of Air and Radiation at
the United States Environmental Protection Agency (EPA). Anna Marie Wood is a Senior Policy Analyst in OPAR at EPA.
In the article Developing a Comprehensive Approach to
,1
Peterson, McKinstry, and Dernbach2 demonstrate the
1. omas D. Peterson et al., Developing a Comprehensive Approach to Climate
and Economic Sectors, 39 ELR (E L. P’ A. R.) 10711 (Aug.
2009) (a longer version of this Article was originally published at 26 V. E-
. L.J. 227 (2008)).
2. Peterson, McKinstry & Dernbach are collectively referred to as “the authors”
in this Comment.
importance of a comprehensive approach to climate change
policy in the United States. e article notes that climate
change legislation proposed thus far fails to integrate state
and local climate change programs with national a nd inter-
national eorts. e authors also assert that the proposals
do not ensure integration across all economic sectors of the
full range of mea sures and programs needed to achieve sig-
nicant greenhouse gas (GHG) reductions. e authors sug-
gest that, either through federal legislation or rulemaking,
a comprehensive approach should be established to address
governance issues and signal an eective commitment by the
United States to address climate change.
e authors propose an approach to address this short-
coming using a combination of elements under t he Clean
Air Act (CAA),3 the most signicant of which include: (1)
the establishment of a national ambient air quality standard
(NAAQS) for greenhouse gasses with short, intermediate
and long term reduction goa ls implemented t hrough state
implementation plans (SIPs); (2) national and regional per-
formance or technology based standards and cap-and-trade
programs for some sectors; and (3) SIPs that include mea-
sures necessary to achieve additional GHG reductions.
Between the time the authors wrote their article a nd the
publication of this comment, much has changed in a rela-
tively short time period. In July, EPA issued an advanced
notice of proposed rulemaking concerning the reg ulation
of greenhouse gas emissions under the CAA (ANPR).4 e
ANPR examined and solicited public comment on the CAA
provisions that could be used to reduce emissions of GHGs,
and the interconnection among these authorities. en, in
3. 42 U.S.C. §§7401-7671q, ELR S. CAA §§101-618.
4. Regulating Greenhouse Gas Emissions Under the Clean Air Act, 73 Fed. Reg.
44354 (July 30, 2008).
Robert D. Brenner played a key role in the development, congressional
on innovative, cost-efect ways to implement its provisions, particularly
and other economic incentives. He has been a leader in EPA’s eforts
International Afairs.
programs under the Clean Air Act. Prior to joining EPA, Ms. Wood
Copyright © 2009 Environmental Law Institute®, Washington, DC. reprinted with permission from ELR®, http://www.eli.org, 1-800-433-5120.
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