Public Utility Commission Regulation and Cost-Effectiveness of Title IV: Lessons for CAIR

There is growing evidence that the cost savings potential of the Title IV SO2 cap-and-trade program is not being reached. PUC regulatory treatment of compliance options appears to provide one explanation for this finding. That suggests that PUCs and utility companies should work together to develop incentive plans that will encourage cost-minimizing behavior for compliance with the EPA's recently issued Clean Air Interstate Rule.