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The use of such “ risk-based exemptions ” appears to violate the Clean Air Act , which calls on facilities to make upgrades and cut air pollution using the best available technology . It 's hard to say — no one has done a risk analysis with respect to shark attacks and because you just ca n't design a safe , effective way to do so and derive meaningful information on which to make predictions or assign a cause . If an allowance program is implemented along with a compliance supplement pool and / or early ABT we are interested in comments on how to make credits fully exchangeable among the programs . If you look at the pace of discovery , it has not slackened at all , even though there has been a lot of pressure on companies to make ends meet .