Good list. Very much appreciate that you including some form of sunsetting of permits, so that "banked permits" don't stay around forever.

Would also add, even if simply symbolic, some form of payment for granted allocations. (How about the year -10 in dollars? Thus a 'granted' allocation in 2012 would cost $2; 2013, $3; etc ... Very low cost, but at least something and perhaps even enough to spark a few extra energy efficiency efforts and a path for some funding for good programs.)

We are building a new system, via Cap & Trade. Why is it wrong to maintain the existing framework of CAA, for CO2, while building up the new framework? Let Cap & Trade, as it becomes effective, make EPA enforcement increasingly unnecessary. But, let CAA help provide protection in the interim.

This is a critically important point. The people who are actively making the problem worse should be paying for the damage that they are causing, even if those payments start off low. Polluting the air that your children and mine breathe is not a right. Even if symbolic, every polluter should be paying for pollution permits so that they know their polluting behavior has a cost. See: http://getenergysmartnow.com/2009/05/28/climate-legislation-what-is-the-right-approach/

Electrification of the rail system, for both cargo and passengers, has one of the highest payoffs in terms of economic activity improvements, reductions in oil usage, improved highway safety, and reduced global warming emissions.

This should be a top national priority -- all other countries with major rail systems are electrifying their rail. Our business structure inhibits this happening in the US. Time to change the game because this is too important.