The "level playing field" idea isn't. It doesn't account for climatic distinctions between sites or the relative risks to surrounding populations. It is however advantageous to larger concerns simply because of economies of scale in the cost of compliance.
Another crooked scam is playing games with the attainment specs to give an advantage to a single player. An example is when Carol Browner set the particulate reduction specs for new diesel at 94% when the industry stated that it could only comply with 90%. You can bet that someone had a proprietary process that met the marginally higher number and made a killing on the resulting shortages of diesel and perhaps royalties on the process.
A flexible system is actually more just and motivates more consideration of individual plant location attributes. That's where pricing emissions has big advantages in flexibility.
The problem with that idea is that it's effectively a tax scam run by the big guys who can buy more influence with the administration. My system works in the opposite fashion, paying those landowners who develop proven processes to adsorb, dilute, or control downstream emissions. It's a long way off but in principle more accurately maps onto the way nature actually mitigates industrial activity.
You're right. I'd forgotten about that. Like I said, it's been a few years.
The "level playing field" idea isn't.
You're right, but I'm referring to stationary source controls enacted by the individual air districts. Clearly, what's required for a stationary source in LA isn't going to be the same (necessarily) in Contra Costa County, or Bakersfield. I meant that the rules adopted for a region (the BAAQMD, for example) should be applied equally and fairly to similar sources permitted within the district.
A flexible system is actually more just and motivates more consideration of individual plant location attributes. That's where pricing emissions has big advantages in flexibility.
Emission credits is actually a great "market solution" to difficult air quality standards. I think they were originated in the South Coast District. Again, conservatives pooh-pooh emission credits (e.g., I hear Melanie Morgan on KSFO ranking in her ignorance on emissions credits, and I want to ring her neck) but it really gives a break to those businesses which simply can't reach their permitted levels, and is an economic advantage to those who do better than their permitted allowance. (Although I see your point about potential abuse in favoring the entity that can afford aggressive controls, and can then recoup much of their expenditure from the little guy who can't; but the concept is still a good one, IMO.)
The problem with that idea is that it's effectively a tax scam run by the big guys who can buy more influence with the administration. My system works in the opposite fashion, paying those landowners who develop proven processes to adsorb, dilute, or control downstream emissions.
Worth considering. Is this applicable to sources of air emissions?