The Last Great Clean Air Act Book?

Abstract

Environmental lawyers are already blessed with several excellent summary overviews of the Clean Air Act (CAA). As useful as these general roadmaps are, however, every practicing environmental lawyer knows that "the devil is in the details." For every statutory section, the administrative rules and regulations are at least an order of magnitude more complex than the statute itself; beneath the rules lie numerous interpretations, caveats, exceptions, guidance documents, regulatory preambles, agency manuals, letter rulings, policies, precedents, and manifold other administrative utterances. These administrative constructions and interpretations add at least another hundredfold to a thousandfold of additional detail. Together the multiple levels of administrative law-making form a vast interpretative pyramid of stunning detail and complexity that translates "law at the wholesale level" (the goal proclaimed in the statute) into "law at the retail level" (the specific, enforceable dictates to a regulated entity).