GHG emissions compliance costs should be minimal for 10 of the 13 subsectors eligible for free emissions allowances in 2016, in WRI’s view. Eligibility for free GHG emissions permits is determined by a combination of trade, energy, and emissions intensity criteria. WRI believes that the American Power Act provides enough free allowances to energy intensive, trade exposed manufacturing industries that any eligible subsector—as a whole—will receive enough free permits to cover all emissions in that subsector for 2016 and several years beyond.