ABSTRACT

The Clean Air Mercury Rule (CAMR) was issued in March 2005 (EPA 2005a) along with the supporting regulatory impact analysis (RIA; EPA 2005b). The CAMR would have put in place a cap-and-trade system for reducing mercury emissions from power plants, following up on a cap-and-trade system (mandated by the Clean Air Interstate Rule, or CAIR; EPA 2005c) that would have tightened the existing cap on sulfur dioxide (SO2) emissions from utilities. It also would have implemented a new cap-and-trade system for utility nitrogen oxide (NO x ) emissions. The CAIR would have resulted in significant ancillary reductions in mercury emissions at these sources. The incremental mercury reductions from the CAMR, in contrast, would have been relatively small. Unfortunately, efforts of the U.S. Environmental Protection Agency (EPA) resulted in no reductions in any of these types of emissions because the District of Columbia Circuit Court vacated both the CAIR (U.S. Circuit Court of Appeals, 05-1244, St NC v. EPA) and the CAMR (U.S. Circuit Court of Appeals, 05-1097, St NJ et al. v. EPA) rules in 2008. As of this writing, regulatory activities to further control these emissions are in limbo.