Taking a Fresh Look at Clean Air Act Standards: The Role of Retrospective Review in Achieving Health and Climate Benefits

Abstract

Many sections of the Clean Air Act (CAA) require the U.S. Environmental Protection Agency (EPA) to retrospectively, and often periodically, review and potentially revise its standards. The paper examines the implementation of the retrospective “residual risk” review provision of CAA 112 to suggest improvements to EPA’s implementation of retrospective review for air toxics standards. By streamlining the review process for low-risk source categories and increasing stakeholder involvement, EPA can meet its statutory requirements while achieving greater risk reductions with fewer resources. The analysis of CAA 112 retrospective review can also inform EPA’s efforts to utilize CAA 111 to reduce greenhouse gas (GHG) emissions. Efficient periodic review of CAA 111 standards would allow traditional command-and-control regulations to effectively address climate change in a rapidly changing regulatory environment.