The emissions trading program was in one sense a radical reform of existing policies. Whereas in the command-and-control approach, control authorities had responsibility for both defining the goals and deciding how much emission reduction should be achieved from each individual discharge point, in the emissions trading program the plant managers were allowed great flexibility in choosing the mix of emission reductions used to meet the ambient goals.
The previous chapters have provided a considerable amount of detail on how the program was designed to deal with practical implementation issues and with overcoming resistance from various constituencies.1 It is now time to coalesce these individual insights into an evaluation of the program as a whole.
Measured against the first benchmark, there can be little doubt that the program has improved upon the policy that preceded it. As of December 31, 1983, 61 bubbles had been approved, 6 were proposed, 98 were under review (for proposal) at EPA or the states, and 36 were known to____________________