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Designing Emission Budget Trading Programs Under Existing State Law, a White Paper by Ari Peskoe analyzes existing state authority to freely allocate allowances to EGUs and non-emitters, to auction allowances, and to include newly constructed sources in the program.
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Emission Rate Credits in the Clean Power Plan: An FAQ for States and Stakeholders by Ari Peskoe addresses definitional and legal issues about Emission Rate Credits (ERCs) and is organized around the following three questions: 1) What are ERCs? 2) How do ERCs interact with existing tradable instruments? 3) How will EPA and states ensure the integrity of the ERC market?