The interesting comparison in that regard is envisioned in the current shape of the design of the cap-and-trade scheme in California. The current wording of the draft regulations (July 2011 Discussion Draft of the Article 5: California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms (Subchapter 10 Climate Change, Article 5, Sections 95800 to 96022, Title 17, California Code of Regulations), published by the Californian Air Resources Board (source: http://www.arb.ca.gov/cc/capandtrade/meetings/meetings.htm)) in § 95811(b)(2) in Subarticle 3 (stipulating entities covered by the California scheme) mentions, among so called ‘First Deliverers of Electricity’, not only electricity generating facilities (i.e. the operators of an electricity generating facility located in California) but also electricity importers.
The said draft regulations make also a distinction as regards the inclusion thresholds for covered entities. In the case of the electricity importers of specified sources of electricity the applicability threshold for an electricity importer is based on the annual emissions of the electricity generating facility from which the imported electricity originated. The applicability threshold for an electricity importer from a specified source which emits 25,000 metric tons or more of CO2 per year is zero metric tons.
In the case of electricity importers of unspecified sources of electricity under Californian cap-and-trade draft regulations the applicability threshold for electricity delivered from unspecified sources is zero MWhs.