The current approach is inefficient and ineffective , imposing unnecessarily high costs due ( 1 ) stranded capital investments from the installation of controls that later become obsolete when additional requirements are promulgated ; ( 2 ) reduced lead time for complying with those requirements ; ( 3 ) limited or non-existent flexibility for emissions trading to allow cost-efficient control options ; and ( 4 ) a reliance upon lengthy , expensive , and uncertain litigation to sort out regulatory ambiguity and compliance with the law .
The high costs are because of the installation of controls and reduced lead time for compliance .