Interchangeable Emission Reduction Credits

Case Number: SLS No. 97-013
Title: Interchangeable Emission Reduction Credits, Part 1

Case Files: Case (14 pages)   |  Exhibits (46 pages)

Teaching Note:

Author: Mary J. Decker, Case Writer; Barton H. (“Buzz”) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law

Abstract: The Bay Area Air Quality Management District in California has proposed a draft air pollution rule that will allow the generation, banking, and trading and use of interchangeable emission reduction credits. These credits are designed to provide a cost-effective alternate means of complying with certain air district rules and regulations. Communities for a Better Environment, an environmental justice organization, opposes the draft rule in part because it believes the rule allows the creation of toxic air pollution hot spots in low income and minority neighborhoods. What comments on the draft rule should CBE provide to the air district?

Key Words: Air pollution, air toxics, emissions trading, market-based incentives, air pollution trading credits, mobile sources, environmental justice.


Case Number: SLS No. 97-014
Title: Interchangeable Emission Reduction Credits, Part 2

Case Files: Case (2 pages)  |  Exhibits (17 pages)

Teaching Note:

Author: Mary J. Decker, Case Writer; Barton H. (“Buzz”) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law

Abstract: This two page addendum to the Part 1 Interchangeable Emission Reduction Credits case study asks the students to review the written comments on the draft rule received by the Bay Area Air Quality Management District, including the comments CBE submitted. the students will evaluate the comments and recommend an appropriate response by the air district. In particular, how should the air district address the concerns raised by CBE?

Key Words: Air pollution, air toxics, emissions trading, market-based incentives, air pollution trading credits, mobile sources, environmental justice.