Single Regulation Trading Rule

This recipe is from the State of Connecticut Improve rule effectiveness from 80% to over 100% by eliminating delays and waivers.

Ingredients:

Add the following to source category rules: If a facility cannot meet Reasonably Available Control Technology (RACT) standards, it may buy excess reductions from another source, or pay for the reductions needed.

Seasonings:

• Desire to eliminate exemptions, delays and waivers.
• Willingness to review transactions.

Utensils:

• Availability of early reduction tons.
• Require retirement of tons as an enforcement tool (in addition to, or in lieu of, fines).
• 10 percent of each trade is retired to benefit the environment.

Servings: The state of Connecticut lowered costs for companies and saved 1,738 tons in one year.

Instructions:

1. Encourage early reductions.
2. Write the rule offering a choice between using a specific technology (or performance level) and purchasing similar reductions.
3. Implement the rule and stop giving out exemptions (or AELs); this creates an instant market to reward those who made early reductions.
4. Track environmental and cost benefits. You'll be pleased and surprised!