12.07.2015 Views

PCAP - Presidential Climate Action Project

PCAP - Presidential Climate Action Project

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This proposal is framed in terms of advancing a national energy policy. The President has a keyrole in planning national energy policy. In terms of implementing a new CAFÉ standard, theauthority is delegated to the DOT (after consultation with the EPA and the DOE), and by statutethe DOT must make certain findings and ensure that any new standard meets certain criteriabefore a new standard is set. The President cannot make the findings and determinations for theagency. See Proposals B-7 and B-8 for a similar analysis. However, the President can reestablishfederal policy in this regard (e.g., establish this standard as part of the national energyplan) and direct the DOT to review the standard based on this policy and revise it as permitted bylaw.Conclusion. Based on the aspirational nature of the targets and goals, and the President’ssubstantial authority to plan national energy and climate change policy, these targets and goalsare good candidates for implementation by executive directive. Support for this directive canalso be found in numerous statutory provisions. Some of these have been presented in thisanalysis. In addition to being aspirational, these targets are directed to the general public, thusby convention, the President should consider issuing the directive as a presidential proclamation.Good candidates to implement by executive directive (7 proposals). Alternative formrecommended.CEES 25 | P age

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