The Virginia Law Review has just posted two essays evaluating the Supreme Court’s landmark environmental decision in Massachusetts v. EPA for its InBrief online magazine, with a third to follow shortly. In the first essay, Virginia’s Jonathan Cannon, who served as General Counsel of the Environmental Protection Agency during the Clinton Administration, argues the decision was an “enormous, if narrow, victory for environmentalists.” Cannon writes:
he holding defines a major new area of responsibility for EPA and requires the Agency to review this and other requests for regulation of greenhouse gas emissions under limits set by the Court. The Court