In the absence of any possible legislative action by Congress in the upcoming term, EPA is now exercising its authority under the Clean Air Act to regulate greenhouse gases as air pollutants.
In California, the Air Resources Board is going ahead with its Cap and Trade program for GHG. It is a program that does not have immediate impact on industry in the sense that affected industry is provided with GHG allowances in the first year to meet their caps. The trading of GHG allowances does not start until 2012 and will accelerate in 2015. State law mandates that GHG be reduced to 1990 level by 2020.