University of San Diego

San Diego Journal of Climate & Energy Law


In Part I, this paper reviews the allocation plans that have been tried so far on an international scale and why they have not succeeded. In Part II, the paper explains EPA's Clean Power Rule and what we are calling the switching opportunities approach that is at least roughly suggested by the Rule. In Part III, the paper discusses the two different "cost-sensitive" approaches adopted by the EPA under the Clean Air Act so far, and in Part IV, the paper discusses the basis for using the Clean Power Plan as a model and the advantages and disadvantages of "scaling up" the switching opportunities approach to the international arena.