The electric generating industry has been besieged with piecemeal pollutant-by-pollutant regulation.   A piecemeal pollutant-by-pollutant approach to emissions reductions is costly and inefficient.   Power producers must make expensive control decisions for some pollutants without knowing the requirements that will apply to other pollutants – or even to the same pollutants in the near future.

In contrast, an multi-pollutant approach would allow electricity generators to optimize their pollution control decisions.  A multi-pollutant strategy with firm caps on emissions will create a stable environment for capital investment by providing relatively long-term certainty about the industry’s future emission reduction obligations.  With a clear understanding of future compliance obligations, companies can then target investments in new and existing electric generation capacity to reduce emissions and enhance electric system reliability.