Regulating Greenhouse Gas Emissions from Existing Sources: Section 111(d) and State Equivalency

On December 9, 2011, the Nicholas Institute for Environmental Policy Solutions convened a broad range of stakeholders to explore the legal and policy issues presented by the regulation of greenhouse gas (GHG) emissions under 111(d) (existing source performance standards) of the Clean Air Act. The workshop focused primarily on the options for states to demonstrate that existing GHG policies are equivalent to the 111(d) requirements. The Nicholas Institute distributed this document to workshop participants prior to the event to provide a framework for the issues that would be discussed. Nothing in this document should be interpreted as expressing the Institute’s opinion of the path the EPA should take on any given issue.