As part of its response to climate change the 1997 Kyoto Protocol envisages the employment of emissions trading schemes ("ETS") to provide a market based incentive to reduce emissions and to engage in carbon sequestration activities. Such schemes would also serve to encourage the creation of an industry focused on energy conservation and alternatives to energy production -so called "green" or "clean" energy. Whilst a number of jurisdictions have introduced ETSs there is no definitive model. In

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... 010 the Tokyo Metropolitan Government ("TMG") established an ETS and currently Australia has had a comprehensive nationwide regime in place since 1 July 2012. Notably the approaches adopted in the two jurisdictions have marked differences. It is proposed to compare the two regimes with a view to identifying lessons for ETS design and implementation.