These myriad actions constitute a staggering amount of information and regulation, much of it very technical, that must be absorbed, considered, and on which the regulated community—particularly the energy sector—must respond if the federal rule making process is to succeed.
It is clear that these have been busy months for federal environmental regulators, especially those working at EPA, the federal departments and the Council on Environmental Quality. Even the Department of Agriculture has found itself coping with greenhouse gases (GHG) issues in its administration of the laws applicable to agriculture and the national forests. The ambitious scope of the current “all of government” approach may be discerned after learning how many disparate federal agencies are employed in implementing this policy. So many actions have been proposed or completed that some state officials are experiencing “comment fatigue” because they are being overwhelmed by the scope, size, and complexity of these federal initiatives. The Environmental Protection Agency is, of course, at the forefront of these actions and activities, as described below.
Mr. Cavender may be contacted at anthony.cavender@pillsburylaw.com
