The Elephant in the Room or the Elephant in the Mousehole? The Legal Risks (and Promise) of Climate Policy under §115 of the Clean Air Act

Is Section 115 of the Clean Air Act a viable alternative or complement to the Clean Power Plan? This paper critically examines Section 115 and its potential breadth and flexibility for regulating greenhouse gases, concluding that it holds great promise but also comes with legal risks.

Working Paper by Nathan Richardson — Oct. 31, 2016