It’s an amazing scam and power grab — but it keeps a lot of lawyers busy and well fed and a lot of Americans out of work and struggling (as well as the entire U.S. economy).
That 3 year period began in 2007 with the SCOTUS decision on New Source Review.
The first 22 months was when Bush didn't move on it. Then, when Obama came in, Congress immediately began working on Cap and Trade so Obama's EPA was working the CO2 so it was well into 2010 before EPA moved on it.
Plus, EPA and everyone else thought is was only a campaign issue in Texas. Perry/GOP wanted to use it as campaign issue against the dem candidate, Houston Mayor White, and after the election, Texas would get in conformance.
But, in Dec, after the Nov 2010 election, Perry jumped on it even harder, which was a signal that Perry would run for prez, which he finnaly annouced in Aug/Sept 2011.