REUTERS/Fred Prouser: The skyline of downtown Los Angeles through a layer of smog is seen in the distance from a rooftop in Hollywood, California.


How the EPA Should Modify Its Proposed 111(d) Regulations to Allow States to Comply By Taxing Pollution

October 28, 2014, Michael Wara, Adele Morris and Marta R. Darby

In this paper, Michael Wara, Adele C. Morris, and Marta R. Darby review the legal context of section III(d) of the CleanAir Act under the U.S. Environmental Protection Agency proposal, and the relative roles of EPA and the states under section 111(d). The authors also recommend amendments to existing rules and the EPA proposal that would remove those constraints and give states full flexibility in how they can design their pollution tax policies.

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