The nature of greenhouse gas (GHG) emissions (particularly carbon dioxide (CO 2 ) emissions) makes their control difficult to integrate with the U.S economy and traditional U.S. energy policy. There is a strong linkage between industrialization and GHG emissions, particularly between energy consumption and GHG emissions. In 2008, energy-related activities contributed 86% of U.S. greenhouse gases. Despite the obvious interrelationship between energy policy and greenhouse gas (GHG) emissions, the United States has struggled to integrate the two. For a country that has traditionally used its cheap supply of energy to substitute for more expensive labor and capital costs to compete internationally, this linkage is particularly strong, as witnessed by the nation's high GHG emissions per capita. The country continues to increase how efficiently it uses energy to create economic goods and services, thus reducing energy-related emissions per unit of output. Two factors contributing to this trend are a two-decade preference for using natural gas (rather than coal) for new electric generating facilities and a steady structural change in the economy away from heavy manufacturing and toward high technology and services. Overall, however, U.S. GHG emissions rose from about 6 billion metric tons in 1990, to about 7 billion metric tons in 2008. In the face of this economic reality, along with continuing scientific uncertainty, debate over a greenhouse gas (GHG) reduction program can be categorized by three inter-related Cs: C ost, C ompetitiveness, and C omprehensiveness. In the debate each of these terms frequently represents a "sound-bite" for a concern; but in program development, each represents an interwoven complex of issues. Cost, as a sound-bite, commonly refers to some monetary estimate of what a GHG reduction program would require, typically expressed as a gross dollar amount or as a percentage reduction in gross domestic product for some period of time. Costs most often are cited by a number or percentage, but costs actually embrace a multifaceted set of changes in economic relationships, involving producers, consumers, and government entities. At a program level, "costs" have many ramifications: federal outlays for research and monitoring; regulatory program operation and oversight; potential public and private sector increases in expenses—for example if energy prices rise; and so on. Furthermore, in a nuanced view, net costs/benefits would be considered, as opposed to looking at costs (or benefits) in isolation. But direct benefits from GHG reductions, as well as secondary benefits such as commercialization of breakthrough technologies and reductions in related more conventional pollutants (e.g., sulfur dioxide, nitrogen oxides, and mercury), can be difficult to quantify (and are frequently ignored). Competitiveness, at the simplest level, most typically reflects concerns about what firms would be disadvantaged by cost increases as a result of GHG reduction requirements. More broadly, however, competitiveness reflects changes in the competitive relationships of producers of goods and services—some facing serious product cost and product substitution issues, others seeking to capitalize on new markets or new cost advantages resulting from legislation. Moreover, competitiveness concerns arise at both the domestic and international levels, depending on the details of the proposed legislation. Comprehensiveness, in the debating arena, relates to the disconnect between individual national responses and a problem that is global in nature—particularly as an individual country's action or inaction affects international competitiveness and growth in GHG emissions. Specifically, if the United States were to require GHG reductions that impose costs on its industry while some other countries do not, domestic firms might be competitively disadvantaged, perhaps substantially, and global GHG emissions would not be significantly affected. Only a "comprehensive" GHG reduction requirement—all nations having to meet comparable GHG reduction requirements—would result in a "level playing field" in which no nation would be at a competitive disadvantage in world markets. However, what would represent "comparable" GHG reduction requirements is problematic, given the diverse resource endowments and disparate economic conditions of the world's nations. The United Nations Framework Convention on Climate Change (UNFCCC) specifically provides for "differentiated" responsibilities between designated developed nations and developing nations with the developing countries taking the lead. The complexity involved in developing a fair and effective comprehensive approach to reducing GHG emissions that encompasses these features has stymied the international community for almost two decades. Because cost, competitiveness, and comprehensiveness are inter-related, C ost frequently becomes the overriding soundbite. Nevertheless, it should be recognized that the term cost alone may embody many ramifications. Costs have been a major concern in GHG policy deliberations, beginning with the United States' negotiations on, and 1992 ratification of, the United Nations Framework Convention on Climate Change, and continuing to the current debate in Congress. During the protracted deliberations on the UNFCCC, the National Academy of Sciences (NAS) released a report, Policy Implications of Greenhouse Warming , in which the expert panel stated that "The United States could reduce or offset its greenhouse gas emissions by between 10 and 40 percent of 1990 levels at low cost, or at some net savings, if proper policies are implemented." The NAS's energy policy recommendations focused on increasing energy conservation and efficiency, incorporating greenhouse warming as a factor in future energy planning, and studying and eventually implementing "full social cost pricing" of energy. Although widely publicized and promoted, this premise was not sufficient for the U.S. to commit to firm targets and time frames for carbon dioxide (CO 2 ) reductions, as witnessed by the U.S. negotiation and ratification of the UNFCCC. Driven by concerns about scientific uncertainty with respect to global climate, the George H. W. Bush Administration—against the wishes of most environmentalists and some vocal Members of Congress—refused to commit to a binding agreement to reduce the nation's CO 2 emissions by a specific date. The UNFCCC reflects this negotiating position of the United States and some other countries in that it calls for voluntary control measures. Senate floor debate on ratification of the treaty brought out concerns by some Senators about the cost of compliance, its impact on the country's competitiveness , and the comprehensiveness with respect to the developing countries—concerns that were overcome because of the non-binding nature of the reduction goals. Those arguing for more binding commitments argued that emissions controls could create jobs and enhance economic health, and that emissions were an indicator of inefficiency. As finally negotiated, the objective of the Convention is to: ... achieve ... stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system. Such a level should be achieved with a time frame sufficient to allow ecosystems to adapt naturally to climate change to ensure that food production is not threatened, and to enable economic development to proceed in a sustainable manner. Arguing that "the developed country Parties should take the lead" in reducing emissions, the Convention set the goal that developed countries aim toward returning their greenhouse gas emissions to their 1990 levels by the year 2000. In line with this goal, developed countries were to adopt national plans and policy options to mitigate climate change by reducing anthropogenic emissions and enhancing sinks. The Energy Policy Act of 1992 (EPACT), P.L. 102-486 , was the principal statutory basis for programs making up the U.S. response to the UNFCCC. Primarily crafted as an energy policy response to the Iraqi takeover of Kuwait and the U.S.-led response, its energy conservation, renewable energy, and other titles were also seen as having a beneficial effect on global climate change concerns being debated at this time in international circles. In its 1992 UNFCCC National Action Plan submission to the UNFCCC, the George H. W. Bush Administration listed 11 different titles of EPACT as "extremely important" to its overall strategy of reducing greenhouse gases. The aforementioned recommendations of the NAS were embodied in several sections of EPACT. These sections included provisions to establish energy-efficiency standards, promote dissemination of energy-saving information, establish several national research and development programs related to deployment of energy-efficiency technologies, and authorize the Department of Energy (DOE) to evaluate cost-effective energy efficiency technologies. In addition to these activities to improve energy efficiency, EPACT included a separate title to incorporate global warming concerns in energy policy planning. Title XVI was designed to assist the government in making informed decisions on global warming by collecting, analyzing, and reporting information on climate change through DOE. Activities included a report on the various economic, energy, social, environmental, and competitive implications of reducing greenhouse gas emissions; developing a least-cost energy strategy designed to achieve "the stabilization and eventual reduction in the generation of greenhouse gases"; creating a Director of Climate Change; and developing an inventory of greenhouse gases and early reductions in such gases. Indeed, the passage of EPACT was anticipated by its authors to stabilize or even reduce emissions of greenhouse gases at little cost, in line with the 1991 NAS report. As stated by the House Report: The committee expects that, if fully implemented, H.R. 776 will result in a substantial reduction in U.S. greenhouse gas emissions relative to forecasted levels. The bulk of these reductions result from the programs that will demonstrate and transfer advanced clean coal and renewable technologies abroad, and from the domestic energy efficiency and renewable energy initiatives. The provisions on electric utilities, alternatives fuels and coalbed methane are also significant. EPACT's portfolio of domestic strategies and program options—technology development/transfer, financial assistance to developing countries, and least-cost solutions—closely track the provisions of the UNFCCC. With the authorization of these programs and activities, EPACT effectively constitutes implementing legislation for the U.S. commitment made in signing and ratifying the UNFCCC.