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The document argues that mass-based emission standards are superior to rate-based standards for regulating existing power plants because they avoid production incentives that can lead to emissions 'rebound' and conflicts with existing regional trading systems. Through economic modeling, the author compares a 'fossil budget' approach (covering all fossil units) and a 'coal budget/gas rate' approach. Both core cases are projected to reduce fossil sector carbon emissions by 26% to 27% relative to 2005 levels by 2020, primarily by displacing high-emission coal generation with existing natural gas combined cycle (NGCC) units. While the fossil budget approach provides stronger long-term price signals for zero-carbon investment, the coal budget/gas rate approach results in lower near-term emission credit prices ($20/tonne vs $34/tonne), lower wholesale price increases (6.9% vs 27.9%), and lower retail rate impacts (2.3% vs 4.1%).