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Comment on Developing a Comprehensive Approach to Climate Change Mitigation Policy in the United States: Integrating Levels of Government and Economic Sectors

August 2009

Citation: 39 ELR 10723

Issue: 8

Author: Robert D. Brenner & Anna Marie Wood

In the article Developing a Comprehensive Approach to Climate Change Mitigation Policy in the United States: Integrating Levels of Government and Economic Sectors, Peterson, McKinstry, and Dernbach demonstrate the importance of a comprehensive approach to climate change policy in the United States. The article notes that climate change legislation proposed thus far fails to integrate state and local climate change programs with national and international efforts. The authors also assert that the proposals do not ensure integration across all economic sectors of the full range of measures and programs needed to achieve significant greenhouse gas (GHG) reductions. The authors suggest that, either through federal legislation or rulemaking, a comprehensive approach should be established to address governance issues and signal an effective commitment by the United States to address climate change.

The authors propose an approach to address this shortcoming using a combination of elements under the Clean Air Act (CAA), the most significant of which include: (1) the establishment of a national ambient air quality standard (NAAQS) for greenhouse gasses with short, intermediate and long term reduction goals implemented through state implementation plans (SIPs); (2) national and regional performance or technology based standards and cap-and-trade programs for some sectors; and (3) SIPs that include measures necessary to achieve additional GHG reductions.

Between the time the authors wrote their article and the publication of this comment, much has changed in a relatively short time period. In July, EPA issued an advanced notice of proposed rulemaking concerning the regulation of greenhouse gas emissions under the CAA (ANPR). The 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. Then, in November, the presidential election led to a change in political leadership in the United States.

Robert D. Brenner is the Director of the Office of Policy Analysis and Review (OPAR) in the Office of Air and Radiation at the United States Environmental Protection Agency (EPA). Anna Marie Wood is a Senior Policy Analyst in OPAR at EPA.

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