EMA Chairman Urges for Continuity of Trading at EPA Public Hearing

Sept. 1, 2010 - PRLog -- Today the Chairman of the Environmental Markets Association (EMA), Thad Huetteman, urged for regulatory certainty at U.S. Environmental Protection Agency’s Public Hearing Proposed Rule: Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone.  

As the leading US-based trade association focused on promoting market-based solutions such as emissions trading to meet environmental challenges, EMA has two primary objectives: 1) to assist in the formation of sound public policy in flexible environmental regulation; and 2) to encourage the spread of trading industry best practices through effective education, training, and member networking.

In the aftermath of the D.C. Circuit Court’s decision in North Carolina vs. EPA crippling uncertainty has undermined confidence in the continued viability of emissions trading.  EMA recognizes EPA's efforts in the proposed Transport Rule to preserve a critical role for emissions trading in environmental regulation, while working within the bounds of the Court decision to guarantee that interstate transport of pollutants does not interfere with attainment in downwind states.

Mr. Huetteman stated that he, “failed to understand how “cap-and-trade” policy has been diminished in the debate on Capitol Hill over climate change legislation.”   As EPA analysts noted in a recent article “The Acid Rain and NOx Budget programs have reduced SO2 and NOx emissions faster and at far lower costs than anticipated, yielding wide-ranging health and environmental improvements.”  To fulfill our national compliance targets by undertaking significant financial commitments, EMA feels it is essential for EPA to restore confidence in trading programs where companies can both receive a fair shot at a return on investment and reduce emissions.  

EMA understands the need for additional emission reductions.  Huetteman continued, “Without the environmental certainty of a “cap”, none of us can be assured that the desired improvements in human health and air quality will be achieved.  Without the regulatory certainty needed to support “trade”, risk premiums for emission reduction projects go up, along with the cost of allowances - something that does not benefit the environment or consumers.”

Cap & trade should be about attracting capital to the highest return projects.  The higher the cost of capital, the higher the cost of the projects that get completed, and the greater the resistance to further reductions. Emission allowances represent the return on emission reduction investments which underwrite the improvements in human health and air quality.


EMA supports efforts to promote market-based mechanisms for responding to environmental issues because emissions trading results in reducing emissions earlier and at a lower cost than any other form of regulation.  We encourage EPA to maintain the continuity of existing trading programs by providing for the convertibility of current period allowances into the subsequent Trading Rule programs.

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EMA is the pre-eminent voice for those organizations who underwrite improved human health and air quality by creating SO2 and NOx reductions and-- when they exceed their required reductions-- trading them. EMA represents a diverse membership including electric utilities, emissions brokers and traders, exchanges, law firms, project developers, consultants, academics, public interest groups and government agencies. In short, the people who help make environmental markets work every day.