Using the Clean Air Act to Regulate Greenhouse Gases
“The regulation of greenhouses gases under the Clean Air Act is not preordained by some divine power. It’s a policy choice that became necessary once what I would regard as a more administrable, efficient, and less-costly legislative program to control these gases failed in the Senate. EPA, quite understandably, said, ‘We never really wanted to do this. It’s not the best way to control greenhouse gases, but it’s what we’ve got, and we’re going to do it.’”
-Bob Nordhaus, Partner, Van Ness Feldman LLP; October 15, 2015
Retrospective Analysis of Federal Regulations
“Very few new regulations over the last several years have included any discussion of retrospective analysis. Planning for future retrospective analysis can promote better rule design and focus data collection afterwards. So the Office of Management and Budget in the course of its executive order review of rules ought to be working with the agencies to develop a retrospective analysis plan for high-priority rules as part of the final rule.”
-Arthur G. Fraas, Visiting Fellow, Resources for the Future; October 21, 2015
Complying with 2025 CAFE Standards
“If you don’t do a lot of hybridization, the only cars that comply are base-model compact and intermediate-sized vehicles. Once you get away from those vehicles, compliance becomes much more difficult.”
-K. G. Duleep, President, H-D Systems; December 2, 2015
Trading Rules under EPA’s Clean Power Plan
“We believe in adding energy efficiency, we believe that [evaluation, measurement, and verification for energy efficiency] should be standardized, and we thought that what EPA was suggesting was in the right ballpark.”
-Victor Niemeyer, Senior Technical Executive, Electric Power Research Institute; January 27, 2016
Partnering with the Federal Government on Drought Issues
“Because of all the different roles the federal government plays, it has a unique potential to bring actors to the table and get them to compromise on some tough basin management issues where there just isn’t enough water to go around without some of those compromises.”
-Ellen Hanak, Director, Public Policy Institute of California Water Policy Center; February 3, 2016