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The EPA is effectively imposing cap and trade by administrative regulation under the Clean Air Act, without Congressional approval.
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Paul Noe, writing in in 2011 in the Administrative Law Review, points to jobs lost when regulation finally pushes manufacturing offshore, such as lost wages, dampened earning potential, relocation and new-job training costs.
FORBES: Regulation Vs. Jobs: Assessing The Employment Impact Of Rules and Regulations
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Similarly, new regulation that imposes compliance requirements and punishments for failure to comply entails administrative and other costs related to compliance risk, because every additional element of potential coercion i.e.
FORBES: Regulation, The Democrats, and The Parallel Universe