ion, and possible future direction, of Emission Reduction Purchase Agreements (“ERPAs”), and to suggest three areas for future legal scholarship in relation to such agreements. An ERPA is simply a contract that purports to transfer “the entire legal and beneficial right and/or title”1 in a relatively new form of property right, namely CERs or ERUs issued pursuant to the Kyoto Protocol. These units have been categorized as “regulatory property”2 and are distinguishable from the traditional categories of public, private or commons property.