UCLA law school’s Emmet Center on Climate Change and the Environment examined CARB’s proposed trading regulations and compared them with the European Trading System and trading programs in the United States, including the federal sulfur dioxide, or acid rain program; the Regional Greenhouse Gas Incentive program; and the Regional Clean Air Incentives Market in the Los Angeles area. The resulting 81-page report, Rules of the Game: Examining Market Manipulation, Gaming and Enforcement in California’s Cap-and-Trade Program, concluded that California has designed a cap-and-trade program to regulate GHG emissions in a way that incorporates the best practices from other emissions trading programs that is likely to result in a fair, cost-effective market compared with other trading programs, and that the proposed market regulations will reduce the risk of market manipulation or gaming.