We trade and advise across the two air-quality compliance markets that touch nearly every US industrial operator: federal CSAPR allowances for power-sector emissions, and state-issued Emission Reduction Credits for permit obligations in nonattainment areas.
Air-quality compliance in the United States is split across two parallel regimes. The federal Cross-State Air Pollution Rule caps SO₂ and NOx emissions from power generators through an annual cap-and-trade program. Separately, the Clean Air Act's New Source Review requires industrial facilities in nonattainment areas to offset new emissions with verified reductions — Emission Reduction Credits — that trade in fragmented, state-specific markets.
We cover both. Most clients only need one — but for multi-region operators, coordinated strategy across the two regimes is where the value is.
Each program has its own registries, vintage rules, and pricing dynamics. We hold proprietary positions, broker transactions, and advise on compliance strategy across both.
Verified reductions in criteria pollutants — NOx, VOC, SO₂, PM, CO — used to satisfy New Source Review, Title V, and nonattainment-area permit obligations. Fragmented state markets where information advantage compounds.
EPA's cap-and-trade response to the Clean Air Act's Good Neighbor Provision. Group 1, 2, and 3 NOx allowances plus annual SO₂. We trade the curves across vintages, groups, and seasons for power-sector generators.
The two instruments are often confused but operate on entirely separate axes. The table below captures the distinctions that actually matter for trading and compliance planning.
We hold positions in California ERCs and trade the CSAPR curves directly. When timing matters, we can offer credits from inventory rather than running a sourcing process.
For permit-driven offset needs and annual CSAPR reconciliation, we source credits, negotiate terms, and close — typically faster and cheaper than running it in-house.
If you own a facility that's curtailed, retired, or installed controls, you may have generated marketable reductions. We help you certify, register, and sell them.
For operators with exposure to both regimes, we coordinate ERC procurement with CSAPR positioning and broader Clean Air Act compliance — one desk, one view.
Whether you're sourcing offsets for a permit, reconciling CSAPR exposure, or sitting on reductions you'd like to monetize — send us a note and we'll be in touch within one business day.