Comment on Developing a Comprehensive Approach to Climate Change Mitigation Policy in the United States: Integrating Levels of Government and Economic Sectors

In this piece, Michael B. Gerrard comments on an article by Thomas D. Peterson, Robert B. McKinstry Jr., and John C. Dernbach which held two central insights: (1) Any serious national effort to control emissions of greenhouse gases must continue to leave important roles to the states; and (2) It would be a mistake to put too many eggs in the cap-and-trade basket. Although Gerrard agrees with these insights, he has reservations about the authors' proposal to use the mechanism of national ambient air quality standards and state implementation plans as a way to give states the vital roles they deserve. In discussing alternative methods to this, Gerrard delves into the topics of state action, the national ambient air quality standards, state implementation plans, and lastly, alternative approaches to state roles.