In addition to regulating fuel economy, EPA is applying Clean Air Act permitting requirements to large stationary sources of greenhouse gases: power plants, refineries,
steel mills, pulp and paper factories, and cement production facilities.63 EPA will soon establish greenhouse gas New Source Performance Standards (NSPS) for coal - fired power plants and petroleum refineries.64 If these go unchallenged, it is
likely that EPA will develop greenhouse gas performance standards for numerous other industrial source categories.