Reporting Rule and So Much More: Setting the Stage for Cap and Trade for U.S. and International Trading Transactions

Written by  Elizabeth Thomas, Brianne P. Anderson, Maria Cull, Gordon F. Peery.

On September 22, 2009, the U.S. Environmental Protection Agency (EPA) issued a final rule pursuant to authority under the Clean Air Act, codified at 40 C.F.R. pts. 86, 87, 89, 90, 94, 98, 1033, 1039, 1042, 1045, 1048, 1051, 1054, and 1065, that requires industries across the U.S. economy to report greenhouse gas (GHG) emissions. 

One goal of this reporting rule is to better understand from where GHGs are coming, which is expected to guide the development of policies and programs focusing on the reduction of GHG emissions.  This rule sets the stage both for Congressional action and further regulatory action to regulate emissions of GHGs.

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