Why are rules restricting the use of early action credits in the early years of the proposed industrial greenhouse gas emissions regulations required?
The objective of providing credits for early action is to address the possible disadvantage that a regulated facility could face as a result of having undertaken greenhouse gas reduction measures early. At the same time, the industrial greenhouse gas emissions regulations are intended to achieve additional emission reductions as soon as possible. Limiting the number of early action credits that can be used in each of the first three years of the regulations (2010, 2011 or 2012) strikes an appropriate balance between these two objectives.
