The parameters for the benchmarks must be clearly articulated and be closely tied to an intelligent national energy policy. I am concerned that today some decisions are being made to reflect agendas not articulated in the Act. I also believe we are dictating national energy policy through decisions made under the Clean Air Act. While the two must complement each other, energy policy needs to be thoughtfully debated in its own right. If a market-based system is used, the initial allocation of emissions is again a taxing task.
Most systems use historic emissions as the baseline.
Unfortunately, that system penalizes the cleaner facilities and rewards dirty facilities. Basing allocations on a market-based value, I would suggest gross revenue, would be a system more consistent with market principles. I believe there are vast opportunities for such a system. We would be able to create an environment where emission reductions can become revenue enhancers rather than revenue drains. We can create an environment that makes technology advances which reduce emissions very marketable.