A new study examines the U.S. Environmental Protection Agency’s proposed CO2 rules and the Nicholas Institute for Environmental Policy Solutions at Duke University’s proposed "Common Elements Approach" for state policymakers to address it.
The study, by Raymond L. Gifford, Gregory E. Sopkin, and Matthew S. Larson for the legal, regulatory, and business strategies firm Wilkinson Barker Knauer, LLP, of Denver, Colorado, cautions states against the approach for several reasons:
- The Common Elements Approach "leaves many significant questions remaining to be addressed."
- It "requires state implementing legislation."
- It lacks "a basic level of ‘common elements’ needed" to implement it.
- It furthermore "does not appear to comply with the proposed Clean Power Plan."
- Finally, "timing issues remain difficult if not insurmountable."
The study is accessible online here.
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