AAEA believes climate change legislation and regulation will need to address environmental justice concerns related to the perception that emission trading programs cause disproportionate pollution from older, dirtier plants to negatively impact low-income and minority communities. There is also widespread belief that global warming and climate change will disproportionately affect low-income and minority communities. Some environmental justice groups oppose cap-and-trade programs.
AAEA is recommending an Environmental Justice Allowance Reserve (EJAR) to address the racial 'Hot Spots' issue. These allowances would come from a special reserve, similar to the current Acid Rain Program Renewable Energy and Conservation Reserve, when the initial allowance allocation is made. They would be awarded to utilities, automakers and others that undertake environmental justice practices and programs designed to mitigate or prevent price shocks, increase the installation of pollution control equipment, promote community education and enhance health-related activities. Utilities and automakers could choose to work with organizations and businesses that conduct environmental justice activities related to climate change mitigation and reductions in emissions of sulfur dioxide, nitrogen oxides and mercury.