A key element of the Clean PowerProgram proposal announced by
EPA is its encouragement of states to develop and use trading
programs as a method of reaching each state's performance goal.
Having set a goal for each state to meet, and outlined its four
"building blocks" to meet those goals, EPA also made
clear it would be receptive to multistate programs to allow for the
trading of allowances.
Of course, the use of environmental commodities is well known
under the Clean Air Act and in state implementation plans (SIPs).
The utility sector is familiar with this tool which has also been
used for reducing nitrogen oxide (NOx) and sulfur oxide (SOx)
emissions from Electric Generating Units (EGUs). Like the
allotments under Title IV of the 1990 Clean Air Act Amendments (the
"acid rain" program) these environmental commodities
delivered emission reductions at a lower cost than a
facility-by-facility, command and control approach. Indeed,
EPA's use of a performance standard
