The Western Power Trading Forum proposed an alternative way to set up a carbon trading market for the power industry. It dubbed it the Tradable Emission Attribute Certificate system. The system would differ from the load-based cap system the California Public Utilities Commission is developing to regulate utilities. It also would vary from the first-seller system advocated by the Market Advisory Committee, which would regulate in-state generators and wholesale power importers (see story above). Under the Forum’s plan, generators serving California, whether in- or out-of-state, would have to obtain tradable emission certificates based on their emission rates from the Western Renewable Energy Generation Information System, explained Clare Breidenbach, Forum consultant on climate change policy. Utilities would remain subject to a load based carbon cap. Utilities could demonstrate compliance with their cap to regulators by buying some combination of certificates from the generators and credits in a broader California carbon market to cover each MWh of power they provide to their customers. Generators, however, would only be able to sell their certificates within the power industry. Breidenich said such a system “captures the value of carbon at the generator level for all power sales.” This would encourage cleaner generation because gas and renewable energy plant operators will gain additional revenue, while credits from dirtier coal plants will be worth less. This price differential, or signal, will encourage a shift toward cleaner generation technologies that emit less greenhouse gases, according to Breidenich. The plan might work for each 100 MW of power a utility sells like this: a utility’s gas plant certificate purchases would total 55,000 pounds, but would offset 50 MWh. Its wind plant certificate purchases would total zero pounds, yet cover 20 MWh. This would leave the need to buy credits on the broader California carbon market totaling only 67,500 pounds to cover the other 30 MWh. The net result would be that the utility would have to supply certificates and credits worth 122,500 pounds of CO2 emissions to regulators to cover the whole 100 MWh of power instead of credits representing the full 225,000 lbs.