changes to employ an "innovative approach to regulation" in which "flexible techniques were used to formulate the amendments--negotiations, round-table discussions, advisory committees" which allowed most interested parties to be involved in the process and the EPA to craft wording that would be both procedurally and operationally acceptable while ensuring that no interest felt it had not been heard. The addition of emissions allowance trading, for example, was approved by the administration because it gave greater leeway to businesses in adjusting their required responses while "the Environmental Defense Fund saw it as a means to get even steeper emissions reductions."
The regulatory burden, however, was immense. It was estimated, for example, that the new regulations would "fill 6000 pages of the U. S. code books [although] all other environmental codes together fill only 9000 pages." The specificity necessitated by many of the areas of regulation increased this burden. All stationary sources of pollution of any size in or near urban areas, for example, were to be required to obtain permits and the reduction of urban pollutants from all sources was to be administered on a locale by locale basis. In an ordinary year prior to 1990 the EPA's Air and Radiation Office ordinarily issued from five to eight rules, but "during the two years after the signing of the amendments, the agency proposed or finalized 76 implementation rules." Conservative estimates in 1995 held that the EPA would be required "to issue some 175 new regulations, write more than 30 guidance documents, conduct some 50 research efforts, prepare 25 reports to Congress, and create 7 panels." In addition states that contained areas that had not attained the National Ambient Air Quality Standards (NAAQS) were required to submit State Implementation Plans (SIPs)--all of which had to be reviewed and approved by the EPA--and could face sanctions for failing to s...