Illinois has been reluctant in the past to implement trading programs for pollution credits. IDOT does not presently intend to implement credit trading. Eventually, it should be possible to trade ECO vehicle credits against both ECO needs and factory emission control requirements. US EPA objects to the knowing requirement. Conclusion The ECO program places substantial new obligations on employers, with short response times.
Compliance costs are high and non-compliance penalties are significant.
It is important that employers conduct the ECO survey diligently and secure the highest APO permissible. High APOs reduce the amount of mandated future activities required to achieve compliance with regional goals. Early action to increase APO is in the employer's best interests. The Chicago Area Transportation Study, Commute Group Division, offers educational and technical assistance regarding the program, but will not prepare plans for employers. All rights reserved.