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Carbon Offsets Under the Clean Air Act: Can They Be Creditable?

April 11, 2013

On the assumption that a carbon trading system can constitute a performance standard for GHGs under the CAA, the question arises whether offsets should be creditable for compliance. In the March issue of ELR News & Analysis, Richard B. Herzog calls for a super-category based solely on emission of GHGs within which trading would be allowed.