Command Without Control: Why Cap-and-Trade Should Replace Rate Standards for Regional Pollutants
I. Introduction
While current environmental laws provide us with an adequate environmental protection system, they must be reformed if we hope to achieve an excellent one. This Dialogue examines regulation of nitrogen oxides (NOx) and sulfur dioxide (SO2) in the power sector over the past years, and provides a direct comparison of the rate-based methods used in both the Title IV and new source review (NSR) programs of the Clean Air Act (CAA)1 with cap-and-trade programs that have been established for both pollutants. This examination reveals the need to move away from the use of end-of-pipe rate standards and the old source/new source distinction in order to create an efficient and effective regulatory system that embraces the principles of pollution prevention and sustainable development.