Allowance trading: Market operations and regulatory response

The use of the SO{sub 2} allowance system as defined by Title IV of the 1990 Clean Air Act Amendments offers utilities greater compliance flexibility than EPA technology standards, State Implementation Plan (SEP) performance standards, or EPA bubble/offset strategies. Traditional methods at best offered the utility the ability to trade emissions between different units at a particular plant. The SO{sub 2} emissions trading system advocated under Title IV will allow a utility to trade emissions across its utility system, and/or trade emissions between utilities to take advantage of interfirm control cost differences. The use of transferable emission allowances offers utilities greater flexibility in the choice of how to control emissions: the choices include fuel switching, flue gas scrubbing, environmental dispatch, repowering, and even the choice not to control emissions [as long as the New Source Performance Standards (NSPS) and Prevention of Significant Deterioration (PSD) requirements are met]. The added flexibility allows utilities to choose the least cost manner of compliance with Title IV requirements. It is hoped (intended) that pollution control cost-minimization by individual utilities will in turn reduce the cost of controlling SO{sub 2} for the electric utility industry in aggregate. In addition, through the use of NO{sub x} emission averaging, the utility would average NO{sub x} emissions from different point sources in order to comply with the prescribed emission standard.