Field (11 y 12) PDF
Field (11 y 12) PDF
Field (11 y 12) PDF
11
Command-and-Control
Strategies: The Case
of Standards
A command-and-control (CAC) approach to public policy is one where, in or-
der to bring about behavior thought to be socially desirable, political authorities
simply mandate the behavior in law, then use whatever enforcement machinery—
courts, police, fines, and so on—that is necessary to get people to obey the
law. In the case of environmental policy, the command-and-control approach
consists of relying on standards of various types to bring about improvements
in environmental quality. In general, a standard is simply a mandated level of
performance that is enforced in law. For example, a maximum level of a toxic,
such as ppm (parts per million) of arsenic in drinking water. A speed limit is a
classic type of standard; it sets maximum rates that drivers may legally travel.
An emission standard is a maximum rate of emissions that is legally allowed.
The spirit of a standard is, if you want people not to do something, simply pass
a law that makes it illegal, then send out the authorities to enforce the law.
Figure 11.1 is our familiar graph showing marginal abatement costs and
marginal damages related to the rate at which some production residual is
emitted into the environment. Suppose that initially the actual level of efflu-
ent is at e1, a rate substantially above the efficient rate of e*. To achieve e* the
authorities set an emission standard at that level; e* becomes a mandated up-
per limit for the emissions of this firm. The standard is then enforced by send-
ing out whatever enforcement authorities are necessary to measure and detect
any possible violations. If infractions are found, the source is fined or subject
to some other penalty. If the firm reduces emissions in accordance with the
standard, it will be incurring an amount equivalent to area a per year in total
abatement costs. These total abatement costs are the compliance costs of meet-
ing the standard.
Standards are popular for a number of reasons. They appear to be simple
and direct. They apparently set clearly specified targets. They appeal, therefore,
202
Marginal
abatement
costs
$ Marginal
damages
et eo e* e1
Emissions (tons/year)
to the sense that everybody has of wanting to come directly to grips with envi-
ronmental pollution and get it reduced. Standards also appear to be congenial
to our ethical sense that pollution is bad and ought to be declared illegal. The
legal system is geared to operate by defining and stopping illegal behavior, and
the standards approach conforms to this mind-set.
We will see, however, that the standards approach is a lot more complex
than might first appear. Standards appear to offer a method to take away the
freedom of sources to pollute, replacing it with mandated changes in behav-
ior. In fact, a very practical reason for the popularity of standards is that they
may permit far more flexibility in enforcement than might be apparent. What
appears to be the directness and unambiguousness of standards becomes a lot
more problematic when we look below the surface.
Types of Standards
There are three main types of environmental standards: ambient, emission, and
technology.
Ambient Standards
Ambient environmental quality refers to the qualitative dimensions of the sur-
rounding environment; it could be the ambient quality of the air over a particu-
lar city or the ambient quality of the water in a particular river. So an ambient
standard is a never-exceed level for some pollutant in the ambient environ-
ment. For example, an ambient standard for dissolved oxygen in a particular
river may be set at 3 parts per million (ppm), meaning that this is the lowest
level of dissolved oxygen that is to be allowed in the river. Ambient standards
cannot be enforced directly, of course. What can be enforced are the various
emissions that lead to ambient quality levels. To ensure that dissolved oxygen
never falls below 3 ppm in the river, we must know how the emissions of the
various sources on the river contribute to changes in this measure, then intro-
duce some means of controlling these sources.
Ambient standards are normally expressed in terms of average concentra-
tion levels over some period of time. For example, the current national primary
ambient air quality standard for carbon monoxide (CO) is 9 ppm based on an
8-hour averaging time and 35 ppm based on a 1-hour averaging time. Neither
can be exceeded more than once per year. The reason for taking averages is to
recognize that there are seasonal and daily variations in meteorological condi-
tions, as well as in the emissions that produce variations in ambient quality.
Averaging means that short-term ambient quality levels may be worse than
the standard, so long as this does not persist for too long and it is balanced by
periods when the air quality is better than the standard.
Emission Standards
Emission standards are never-exceed levels applied directly to the quantities of
emissions coming from pollution sources. Emission (or effluent) standards are
normally expressed in terms of quantity of material per some unit of time—for
example, grams per minute or tons per week. Continuous emissions streams
may be subject to standards on “instantaneous” rates of flow: for example, up-
per limits on the quantity of residuals flow per minute or on the average re-
siduals flow over some time period. These are sometimes called “performance
standards.”
It is important to keep in mind the distinction between ambient standards
and emission standards. Setting emission standards at a certain level does not
necessarily entail meeting a set of ambient standards. Between emissions and
ambient quality stands nature, in particular the meteorological and hydrologi-
cal phenomena that link the two.
Research to study the linkage between emission levels and ambient quality
levels is an important part of environmental science. The environment usually
transports the emissions from point of discharge to other locations, often dilut-
ing and dispersing them along the way. Chemical processes occur in all envi-
ronmental media that often change the physical character of the pollutant. In
some cases this may render the emitted substance more benign. Organic wastes
put in rivers and streams will normally be subject to natural degradation pro-
cesses, which will break them down into constituent elements. Thus, the ambi-
ent quality of the water at various points downstream depends on the quantity
of emissions as well as the hydrology of the river: its rate of flow, temperature,
natural reaeration conditions, and so on.
The link between emissions and ambient quality also can be vitally affected
by human decisions. A classic case is automobiles. As part of the mobile-source
air pollution program, emission standards have been set for new cars in terms
of emissions per mile of operation. But because there is no effective way of con-
trolling either the number of cars on the roads or the total number of miles each
is driven, the aggregate quantity of pollutants in the air, and thus, ambient air
quality, is not directly controlled.
Emission standards can be set on a wide variety of different bases. For example:
1. Emission rate (e.g., pounds per hour).
2. Emission concentration (e.g., parts per million of biochemical oxygen
demand, or BOD, in wastewater).
3. Total quantity of residuals (rate of discharge times concentration times
duration).
4. Residuals produced per unit of output (e.g., SO2 emissions per kilowatt-hour
of electricity produced).
5. Residuals content per unit of input (e.g., SO2 emissions per ton of coal burned
in power generation).
6. Percentage removal of pollutant (e.g., 60 percent removal of waste material
before discharge).
In the language of regulation, emission standards are a type of performance
standard because they refer to end results that are meant to be achieved by the
polluters that are regulated. There are many other types of performance stan-
dards: for example, workplace standards set in terms of maximum numbers of
accidents or levels of risk to which workers are exposed. A requirement that
farmers reduce their use of a particular pesticide below some level is also a per-
formance standard, as is a highway speed limit.
Technology Standards
There are numerous standards that don’t actually specify some end result, but
rather the technologies, techniques, or practices that potential polluters must
adopt. We lump these together under the heading of technology standards.
The requirement that cars be equipped with catalytic converters or seat belts
is a technology standard. If all electric utilities were required to install stack-
gas scrubbers to reduce SO2 emissions,1 these would be, in effect, technology
standards because a particular type of technology is being specified by central
authorities. This type of standard also includes what are often called design
standards or engineering standards. There are also a variety of product stan-
dards specifying characteristics that goods must have and input standards that
require potential polluters to use inputs meeting specific conditions.
At the edges, the difference between a performance standard and a technol-
ogy standard may become blurred. The basic point of differentiation is that a
performance standard, such as an emission standard, sets a constraint on some
performance criterion and then allows people to choose the best means of achiev-
ing it. A technology standard actually dictates certain decisions and techniques
to be used, such as particular equipment or operating practices to be used by
polluters. For illustrative purposes, Exhibit 11.1 shows some typical standards,
1
A scrubber is a device that treats the exhaust gas stream so as to remove a substantial proportion
of the target substance from that stream. The recovered material then must be disposed of
elsewhere.
Standards Applicable
to Snowmobiles 1 EXHIBIT 11.1
This may be appropriate for some substances, certain highly toxic chemicals, for
example, but it would be essentially impossible to achieve for all pollutants.
The standard might instead be set at a level that accepts a “reasonably small”
amount of damages, for example, e0, the point where the marginal damage
function begins to increase very rapidly. Here again, however, we would be
setting the standard without regard to abatement costs. A different logic might
suggest that in setting the standard, damages ought to be balanced with abate-
ment costs. This would put us squarely within the logic used in discussing the
notion of economic efficiency and, in this way, lead us to set the standard at e*,
the efficient emission level.
Note that there is, in effect, a certain amount of “balancing” going on when
standards are set on the basis of an average over some time period. In this
case short-run periods, when ambient quality is relatively low, are considered
acceptable as long as they do not last “too” long. A judgment is being made, in
effect, that it is not necessary to install enough abatement technology to hold
ambient quality within the standard under all conceivable natural conditions.
In other words, an implicit trade-off is being made between the damages that
will result from the temporary deterioration of ambient quality below the stan-
dard and the high costs that would be necessary to keep ambient quality within
the standard under all conditions.
Uniformity of Standards
A very practical problem in standard setting is whether it should be applied
uniformly to all situations or varied according to circumstances. This can be
illustrated by using the problem of the spatial uniformity of standards. The
ambient air quality standards in the United States, for example, are essentially
national. The problem with this is that regions may differ greatly in terms of
the factors affecting damage and abatement cost relationships, so that one set
of standards, uniformly applied across these local variations, may have serious
efficiency implications.
Consider Figure 11.2. It shows two marginal damage functions, one of which
(labeled MDu) is assumed to characterize an urban area, whereas the other
(labeled MDr) applies to a rural area. MDu lies above MDr because there are
many more people living in the urban area, so the same quantity of emissions
will affect the health of more people there than in the rural region. Assume
that marginal abatement costs (labeled MAC) are the same in the two regions.
Because the marginal damages are much higher in the urban than in the rural
area, the efficient ambient level of benzene is much lower in the former than in
the latter region; the efficient level is er in the rural region and eu in the urban
area. Thus, a single, uniform standard cannot be efficient simultaneously in the
two regions. If it is set at eu, it will be overly stringent for the rural area, and if
it is set at er, it will not be tight enough for the urban region. The only way to
avoid this would be to set different standards in the two areas. Of course, this
confronts us with one of the great policy trade-offs: the more a policy is tailored
so that it applies to different and heterogeneous situations, the more efficient
it will be in terms of its impacts, but also the more costly it will be in terms of
MAC MDu
MDr
0 eu er
Ambient levels of benzene
getting the information needed to set the diverse standards and enforcing them
once they have been established.
The curves in Figure 11.2 could be used to represent other heterogeneous
situations as well as differences in geographical regions. For example, MDu
might represent marginal damages in a particular region under some meteoro-
logical conditions such as high humidity, or in one season of the year, whereas
MDr could represent the marginal damage function for the same area but under
different meteorological conditions, like windy conditions, or at a different time
of year. Now a single standard, enforced throughout the year, cannot be effi-
cient at all points in time; if it is efficient at one time, it will not be at the other.2
Marginal
Abatement
Costs ($)
Emission
Level (tons/
month) A B
20 0.00 0.00
19 1.00 2.10
18 2.10 4.60 MAC B
17 3.30 9.40
16 4.60 19.30 204.9
15 6.00 32.50
14 7.60 54.90 MACA
13 9.40 82.90 $
12 11.50 116.90
11 13.90 156.90 32.5
10 16.50 204.90
16.5
9 19.30 264.90
8 22.30 332.90
5 10 15 20
7 25.50 406.90
Emissions (tons/month)
6 28.90 487.00
5 32.50 577.00
4 36.30 677.20
3 40.50 787.20
2 44.90 907.20
1 49.70 1,037.20
0 54.90 1,187.20
the same standards to all sources. It makes their regulatory lives much simpler,
and it gives the impression of being fair to everyone because all are apparently
being treated alike. But identical standards will be cost-effective only in the un-
likely event that all polluters have the same marginal abatement costs.
Consider Figure 11.3, showing the marginal abatement cost relationships
for two different sources, each emitting the same waste material. Note that
the marginal abatement cost functions differ; for Firm A they increase much
less rapidly as emissions are reduced than they do for Firm B. Why the dif-
ference? They may be producing different outputs with different technolo-
gies. One firm might be older than the other, and older technology may be
less flexible, making it more costly to reduce emissions than at the plant with
the newer equipment. One plant may be designed to use a different type of
raw material input than the other. This, in fact, mirrors the situation in the
real world. Normally one can expect considerable heterogeneity in abate-
ment costs among groups of firms even though they are emitting the same
type of residual.
4
An equiproportionate cutback is one that reduces each source by the same percentage of its
original emissions. In the example in the text, the 10-ton cutback for each source was equal in
absolute terms and also equiproportionate, as each source was assumed to be initially at an
emission level of 20 tons per month.
5
Note total abatement costs in Table 11.1 are the sum of MAC from Figure 11.3.
Firm A: 1.00 + 2.10 + 3.30 + 4.60 + 6 + 7.60 + 9.40 + 11.50 + 13.90 + 16.50 = $75.90
Firm B: 2.10 + 4.60 + 9.40 + 19.30 + 32.50+ 54.90 + 82.90 + 116.90 + 156.90 + 204.90 = $684.40
equiproportional cutback, there may be nothing to stop the authorities from set-
ting different standards for the individual sources. To get an overall reduction to
20 tons/month in the previous example, they could require Source A to reduce
to 5 tons/month and Source B to cut back to 15 tons/month. The difficult part
of this, however, is that to accomplish this, the authorities must know what
the marginal abatement costs are for the different sources. This point needs to
be stressed. For almost any real-world pollution problem, there will normally
be multiple sources. For a public agency to set individual standards in accor-
dance with the equimarginal principle, it would have to know the marginal abate-
ment cost relationship for each of these sources. We talked in Chapter 9 about the
problem of asymmetric information. Polluters normally have a substantial
amount of private information about pollution-control costs. These costs will
usually vary among sources, so for the regulators to establish cost-effective
pollution-control regulations, they will have to find some way to obtain this
information. The primary source of data would have to be the polluters themselves,
and there is no reason to believe they would willingly share this information. In
fact, if they realize, as they certainly would, that the information would be used to
establish individual source standards, they would have every incentive to provide
the administering agency with data showing that their marginal abatement costs
rise very steeply with emission reductions. Thus, there are real problems with au-
thorities attempting to establish source-specific emission standards. Nevertheless, a
considerable amount of this is done informally, through the interactions of local
pollution control authorities, charged with enforcing common standards, and local
sources, each of which is in somewhat different circumstances. We will come back
to this later when we discuss issues of enforcement.
MAC1
MD
MAC2
e
d
a
c
b
0 e3 e 2 e1
Emissions
firm could expect to have after investing some large amount of resources in
an research and development (R&D) effort to develop better treatment or re-
cycling technology. Without any pollution-control program at all, there is ab-
solutely no incentive to spend the money on the R&D. But suppose the firm is
now faced with having to meet emission standards of e2 tons/year. With the
original marginal abatement costs the total annual cost of compliance for this
firm is (a + b) per year. If the R&D program is successful and MAC1 reduces
to MAC2, compliance costs would be only b/year. The difference, a/year, is
the amount by which compliance costs would be reduced and represents, in
fact, the incentive for engaging in the R&D effort. We will see in the next chap-
ter that this is a weaker effect than is provided by economic-incentive types of
programs. Nevertheless, it is an incentive, which is more than we could say for
technology standards.
To understand fully the incentive effects of standards, one has to look closely
at the details. Figure 11.4 depicts a standard applied to total emissions. His-
torically, most standards have been applied to emissions per unit of input or
output of industrial firms. For electric utilities, an emission standard per unit
of fuel burned is a standard per unit of input. There are important incentive
implications of setting standards this way. Consider the following expression,
showing how total emissions from an industrial operation are related to under-
lying performance factors:
Total = Total × Inputs used for × Emissions per
emissions output unit of output unit of input
Suppose authorities apply an input standard to, for example, coal-
burning power plants. The standard could be expressed in terms of
maximum amounts of SO2 emissions allowed per ton of coal burned. This
is a standard applied to the last term of the equation, and so the power
plant will presumably reduce its emissions per unit of input to the level
of the standard. But there are two other ways of reducing total emis-
sions, as depicted in the first two terms to the right of the equals sign.
One is to reduce total output through, for example, encouraging consumers
to conserve electricity. The other is to reduce the amount of coal needed per
unit of electricity generated, in other words, for the plant(s) to increase fuel
efficiency. But the plants will have no incentive to reduce emissions in these
last two ways because the standard has been written in terms only of the last
factor in the expression.
In recent years, regulators have been moving more toward output-based
standards, that is, standards expressed in terms of allowable emissions per unit
of output.6 If you multiply together the last two terms of the expression, you
get emissions per unit of output. If you now place a standard on this factor,
note that polluters can reduce it in two ways: by reducing inputs per unit of
output and by reducing emissions per unit of input. The incentives of the pol-
luters have been broadened. So in the case of a power plant, an output-based
standard would involve both incentives: to reduce emissions per unit of coal
burned (perhaps by switching to low-sulfur coal) and to become more fuel ef-
ficient (perhaps by upgrading the boilers of the plant).
6
Automobile emission standards have always been in terms of output, for example, grams of
pollutant per mile driven. We will talk about this in Chapter 15.
7
There is another perverse incentive lurking in equiproportionate reductions. If polluters realize
that they will be subject to an equiproportionate cutback in the future, it is better for them to
increase their base now by increasing their emissions. When the cutback is imposed, they will be
able to emit higher amounts than they would have had they not inflated their base.
MAC
$
MPC′
MPC
e* e1 e0
Emissions
8
In the last chapter we discussed liability rules as a way of controlling emissions. In penalty
function terms, liability rules turn the marginal damage function into an MPC curve, because they
would make firms responsible for paying for the damages their emissions produce.
than this would require higher abatement costs than it would save in terms of
reduced penalties. Unless something changes, therefore, the firm’s emissions
will end up at e1, and the amount of noncompliance will be e* − e1.
The only way to reduce noncompliance is to raise the penalty function.
Basically, there are two ways of doing this: raise monitoring activities so as to
be better able to detect noncompliance, or raise fines for those who have been
detected as noncompliant. Of course, authorities could do both and, if they did
so enough, the penalty function could be raised to something like the dotted
line labeled MPC’, which would then ensure a noncompliance rate of zero.
This analysis shows several things. It shows the basic result that there is a
trade-off in enforcement; to get higher levels of compliance authorities will
normally have to devote more resources to enforcement. There may be some
trade-off also between monitoring and fines. The MPC curve of Figure 11.5
can be raised or lowered by changes in either one of these enforcement
elements.
We should also note that monitoring in this case requires measuring, or
estimating, the quantities of emissions, because the MPC function is essen-
tially expressed in terms of deviations of actual emissions from the emission
levels set in the standard. This deviation could apply to hourly, daily, or an-
nual quantities. Over the years, there have been major advances in monitor-
ing technology. In the early days of rigorous pollution control, much of the
enforcement effort depended on self-monitoring, where sources themselves
kept the books on emissions flows over time. This permitted the agencies to
visit firms periodically to audit the records at each source. Agencies could
also make random checks to measure emissions. The rate of auditing and ran-
dom visits could be varied according to agency budgets. More recently, tech-
nologies have been developed for undertaking continuous measurement and
electronic reporting (via the Internet, for example) of emissions in some cases.
The future will undoubtedly also see new developments in remote monitoring
technology.
The other main factor behind the MPC function of Figure 11.5 is the size
of the fines or other sanctions (e.g., jail terms). Most pollution-control statutes
contain provisions on the size of the fine (or jail term) that may be levied against
violators if and when they are caught and found guilty. In many cases, fines
have been set too low, lower than the abatement costs required to meet the
standards. In these situations firms can actually save money by dragging their
feet on compliance. With low sanctions like this, enforcement is therefore likely
to be much more difficult and costly than if sanctions are higher. Sources faced
with the possibility of having to pay substantially higher fines would presum-
ably have a stronger incentive to come into compliance.
It needs to be kept in mind also that sanctioning ordinarily involves using
the court system to pursue legal action. The functioning of courts may put some
limits on what enforcing agencies may do. For example, if monetary fines or
other penalties expressed in the law are very high, courts may be reluctant to
hold sources in rigorous noncompliance because of the economic dislocation
this may produce.
deal of informal give-and-take between the authorities and local plant man-
agers, with participation by local environmental groups as well. A cynic,
or a political realist, might conclude that standards approaches are favored
because of the very fact that in the real world of tight public agency budgets,
they permit partial or incomplete compliance. One of the advantages (some
might say disadvantages) of policies using standards is that they permit
flexibility in enforcement.
Summary
The most popular approach to environmental pollution control historically has
been the setting of standards. This has been called the command-and-control
approach because it consists of public authorities announcing certain limits
on polluters, then enforcing these limits with appropriate enforcement institu-
tions. We specified three primary types of standards: ambient, emission, and
technology. Initial discussion centered on the level at which standards should
be set and the regional uniformity of standards.
A leading problem with standard setting is the question of cost-effectiveness
and the equimarginal principle. In most standards programs, the administra-
tive bias is to apply the same standards to all sources of a particular pollutant.
But pollution control can be cost-effective only when marginal abatement costs
are equalized across sources. When marginal abatement costs differ among
sources, as they almost always do, uniform standards cannot be cost-effective.
In practice, differences among sources in their marginal abatement costs of-
ten are recognized informally by local administrators in applying a uniform
national standard.
We dealt at length also with the question of the long-run impact of standards
through their effects on the incentives to look for better ways of reducing emis-
sions. Technology standards completely undermine these incentives. Emission
standards do create positive incentives for R&D in pollution control, although
we will see that these are weaker than those of economic-incentive types
of pollution-control policies, the subject of the next two chapters. Finally, we
discussed the all-important question of enforcement.
For additional readings and Web sites pertaining to the material in this
chapter, see www.mhhe.com/field7e.
221
French aircraft TNSA (Tax sur les nuisances sonore aériennes) charged at 11
noise charges busiest airports, based on maximum take-off weight, certified
noise performance, and time of day
Czech Republic air Charges on power plants, covering SO2, NOx, particulate
pollution charges matter, and VOCs (excluding methane)
Plastic bag tax in Charges on all plastic bags (biodegradable or not) except bags
Ireland used for fresh meat and fruits
Pesticide tax in Tax on pesticides based on their components, a registration
Norway fee, a fee to fund efficiency and residue trials, and risk to
environment and human health
Landfill tax in U.K. Tax has two rates: a local rate on less polluting wastes (e.g.,
rocks and soils) and a higher rate for everything else
Water taxes in Consisting of a water supply tax and a waste tax based on
Denmark discharge of nitrogen, phosphorus, and organic matter
Swedish carbon tax The first country to introduce a tax on CO2 emissions, offset by
a reduction in personal income taxes
Energy tax in the A “downstream” tax applying to energy products used for
Netherlands heating and electricity generation in households and small and
intermediate-sized businesses
Natural resource Covers extraction of natural resources, waste disposal,
tax in Latvia hazardous goods, and air and water emissions
Source: Institute for European Environmental Policy, Environmental Tax Reform in Europe:
Opportunities for the Future, Annexes to Final Report, Brussels, May 2014.
1
Terminology varies in this subject. Some people prefer to talk of emission charges, others
prefer emissions taxes. For our purposes, charges and taxes are synonymous and are used
interchangeably.
2
The idea of taxing “bads” was first put forth by A.C. Pigou in his Economic of Welfare (London,
Macmillan, 1920). Thus, Pigouvian taxes are taxes meant to achieve changes in the behavior of,
in this case, polluters, in contrast to standard taxes, whose purpose is primarily to raise public
revenues.
300
250
MAC
200
$ 150
100
a
50
b
0 2 4 6 8 10
Emissions (tons/month)
shows total abatement costs. The last two columns show the total monthly tax
bill the firm would pay at different emission levels, and the total cost, consisting
of the sum of abatement costs and the tax bill. We see that the minimum total cost
of $855 occurs at an emission rate of 4 tons/month. Let’s pursue the logic of this
by considering marginal abatement costs. Suppose the firm is initially emitting
10 tons/month. If it does not reduce emissions, the firm’s tax, or payment for
using the environment, is $1,200. The firm has an incentive to reduce emissions.
If it were to cut emissions to 9 tons, it would cost $15 in abatement costs, but it
would save $120 in total tax bill, clearly a good move because total costs drop
to $1,095. Following this logic, it could improve its bottom line by continuing
to reduce emissions as long as the tax rate is above marginal abatement costs.
The rule for the firm to follow is thus: Reduce emissions until marginal abate-
ment costs are equal to the charge on emissions. This is shown diagrammatically
in the bottom part of Figure 12.1. With a continuous marginal abatement cost
function, it’s possible to talk about fractions of tons of emissions, something we
could not do in the upper panel. So the graph is drawn to agree with the integer
values above; that is, the charge of $120 leads the firm to reduce emissions to
exactly 4 tons/month.
After the firm has reduced its emissions to 4 tons/month, its total (monthly)
tax bill will be $480. Its monthly abatement costs will be $375. Graphically, to-
tal abatement costs correspond to the area under the marginal abatement cost
function, labeled b in the figure. The total tax bill is equal to emissions times
the tax rate, or the rectangle labeled a. Under a charge system of this type, a
firm’s total cost equals its abatement costs plus the tax payments to the taxing
authority.
Why wouldn’t the firm simply disregard the charge, continue to pollute
as it has been doing, and just pass the charge on to consumers in the form of
higher prices? If the firm stayed at 10 tons of emissions, its total outlay would
be $1,200/month, consisting entirely of tax payment. This is much higher than
the $855 it can achieve by cutting back to 4 tons/month. The assumption in an
emissions charge program is that competitive pressures will lead firms to do
whatever they can to minimize their costs. Thus, when there is competition in
the industry subject to the emission tax, it will lead firms to reduce emissions
in response to the tax. By the same token, however, we must recognize that if
competition is weak, firms may not respond in this way. Electric power plants,
for example, are usually operated by regulated monopolies subject to oversight
by public utility commissions. They may not respond to charges on sulfur diox-
ide (SO2) emissions in the same way as firms that operate in more competitive
economic climates.
For competitive firms, the amount of the response will depend on several
factors. The higher the charge, the greater the reduction, and vice versa. In the
example of Figure 12.1, a tax of $50/ton/month would have led the source to
reduce emissions only to 7 tons/month, whereas one of $180 would have pro-
duced a cutback to 2 tons/month; that is, the firm would select an emissions
quantity closest to where MAC equals the charge. Also, the steeper the mar-
ginal abatement cost function, the less emissions will be reduced in response to
a tax. We will come back to this later.
Compare the charge approach with an emission standard. With the tax the
firm’s total outlay is $855. Suppose that, instead, the authorities had relied on
an emission standard to get the firm to reduce emissions to 4 tons/month. In
that case, the firm’s total outlay would be only the $375 of abatement costs.
Thus, the charge system ends up costing the firm more than the standards ap-
proach. With a standard, the firm has the same total abatement costs as in the
charge system, but it is still essentially getting the services of the environment
free, whereas with a charge system it has to pay for those services. But although
polluting firms would thus prefer standards to emission charges, there are good
reasons, as we will see, why society would often prefer taxes over standards.
Marginal Marginal
abatement damage
costs
t*
c
a
d e
b
0 e1 e* e0
Emissions (tons/year)
3
We have seen a graph like this several times before, for example, in Figures 11.3 and 5.5.
A B
MACA MACB
50 50
40 40
$ 30 $ 30
20 20
c
a
10 10
b d
5 10 15 20 5 10 15 20
Emissions (tons/month) Emissions (tons/month)
these emissions, after they leave the respective sources, are uniformly mixed
together, so that the emissions of the two plants are equally damaging in the
downstream, or downwind, impact area. The marginal abatement costs for the
two sources are the same as those we used in the last chapter. They are shown
in graphical form at the bottom of Figure 12.3. The marginal abatement costs
of Source A increase much less rapidly with reductions in emissions than do
those of Source B. In the real world, differences like this are normally related to
the fact that the firms are using different production technologies. They may be
producing different outputs (e.g., a pulp mill and a food-canning firm), or they
may be plants in the same industry but using different production techniques
(e.g., coal-fired and oil-fired electric power plants). According to the graphs, the
production technology used by Source B makes emission reduction more costly
than it is at Source A. If we impose an effluent charge of $33/ton on each source,
the operators of Source A will reduce their emissions to 5 tons/month; those
at Source B will cut back to 15 tons/month (dealing only with integer values).
After these reductions, the two sources will have the same marginal abatement
costs. The total reduction has been 20 tons per month, which the effluent charge
has automatically distributed between the two firms in accordance with the
equimarginal principle.
Note very carefully that the emission tax has led Source A to reduce its
emissions by 75 percent, whereas Source B has reduced its emissions by only
25 percent. The emissions tax leads to larger proportionate emission reductions
from firms with lower marginal abatement costs. Conversely, firms having
steeper marginal abatement costs will reduce emissions less, in proportionate
terms. Suppose that instead of the charge the authorities had instituted a pro-
portionate cutback on the grounds that “everybody should be treated alike”;
therefore, they require each source to reduce emissions by 50 percent. Our two
sources in Figure 12.3 both reduce emissions to 10 tons/month. At this point
their marginal abatement costs would be different. Furthermore, we can calcu-
late total abatement costs by remembering that total cost is the sum of marginal
costs. Thus, for example, for Source A the total costs of 10 tons of emissions
would be $(1.0 + 2.1 + . . . + 16.5) = $75.90.
The following tabulation compares the compliance costs of the equipropor-
tionate reduction and the effluent charge with equimarginal rules.
Note how much the totals differ. The total compliance cost of an equipropor-
tionate cutback is about 2.8 times the total cost of an emission tax. The simple
reason is that the equiproportionate cutback violates the equimarginal principle;
it requires the same proportionate cutback regardless of the height and shape of
a firm’s marginal abatement costs. The difference in total costs between these
two approaches is quite large with these illustrative numbers. We will see in
later chapters that in the real world of pollution control these differences are
often much larger. The extra amount spent to treat all firms with the same pro-
portionate percentage could have been used to further reduce pollution.
The higher the tax rate, the more emissions will be reduced. In fact, if the
tax rate were increased to something over $55/ton, Firm A would stop emit-
ting this residual entirely. The marginal abatement cost function for Firm B in-
creases so rapidly, however, that an extremely high charge (more than $1,187/
ton) would be required to get this source to reduce emissions to zero. A single
effluent charge, when applied to several firms, will induce a greater reduction
by firms whose marginal abatement costs increase less rapidly with emission
reductions than from firms whose marginal abatement costs increase more rap-
idly. Because the firms are paying the same tax rate, they will have different
total abatement costs and different tax bills. In Figure 12.3, the total abatement
costs are equal to area b for Source A and area d for Source B. On the other hand,
the monthly tax bill sent to Source A would be only a, compared to a bill of c
sent to Source B. Thus, the less steeply the marginal abatement cost of a firm
increases, the larger that firm’s emission reduction will be and the smaller its
tax bill.
It needs to be emphasized that the efficiency results of the emission charge
approach (i.e., that it satisfies the equimarginal principle) are achievable even
though the administering agency knows nothing about the marginal abatement costs of
any of the sources. This is in clear contrast with the standards approach, where
the public agency has to know exactly what these marginal abatement costs are
for each firm in order to have a fully efficient program. In a charge approach the
only requirement is that firms pay the same tax rate and that they are cost mini-
mizers. After each one has adjusted its emissions in accordance with its mar-
ginal abatement costs (which we can expect them to know themselves), they
will all be emitting at the appropriate rates to satisfy the equimarginal principle.
distance (B)
out and diluted than there is for the emissions from Source B. There could be
other reasons than location differences for the different impacts; for example,
they may emit residuals at different times of the year when wind patterns are
different. Studying the location problem will allow us to examine the general
problem of nonuniform emissions.
In this case a single emission charge applied to both sources would not be
fully efficient. A single charge addresses only the problem of differences in
marginal abatement costs, not differences in damages caused by the emis-
sions from different sources. In Figure 12.4, a one-unit reduction in emissions
from Plant B would improve environmental quality (reduce damages) in the
urban area more than a one-unit reduction in emissions from Plant A, and
this fact must be taken into account in setting emission charge rates. Suppose
emission reductions at Source B are twice as effective at reducing damages
as reductions in emissions at Source A. This means, in effect, that the efflu-
ent tax paid by Source B must be twice as high as the effluent charge paid by
Source A.4 Thus, after adjustment to these tax levels the marginal abatement
cost of Source B would be twice the marginal abatement cost of Source A. But
the damage reduction per dollar spent in reducing emissions would be equalized
across the two sources.
The logic of the preceding discussion would seem to imply the conclusion
that in these cases we would have to charge different emission charges to each
source. To do this, we would have to know the relative importance of the emis-
sions from each source in affecting ambient quality. Exhibit 12.2 discusses
some results showing that for several important air pollutants, damages were
4
The technical concept here is called a “transfer coefficient.” A transfer coefficient is a number
that tells how the emissions from any particular source affect ambient quality at some other point.
In the previous example, suppose 1 ton of SO2 emitted by B would increase SO2 concentration
over the urban area by 0.1 ppm. Then a ton emitted from Source A would increase the ambient
concentration by 0.05 (assuming an effect that is strictly proportional to distance). If the transfer
coefficient for Source B is 1, that for Source A is 0.5, so the tax at A has to be half the tax at B. More
generally, if the transfer coefficient at A is t1, and that of B is t2, then the tax at A should be t1/t2
times the tax at B.
Different sources with the same type and particulate matter (PM2.5) and sulfur diox-
quantity of emissions may be very differ- ide (SO2). The top four power plants are
ent in terms of the damages they cause. near urban areas and the bottom four are
Two economists estimated source-specific in rural locations.
damages from emissions of major pol- For the urban power plants, note the
lutants from power plants in the United differences for the Con Edison plant in
States. They used a large-scale model New York: it would take 11 tons of PM2.5
that tracks the consequences of emission emitted from the stack to produce the
through air quality changes, exposure same damage as 1 ton emitted at ground
levels, dose-response information, and level. For SO2 it would take 8 tons com-
the valuation of resulting health impacts ing out of the stack to generate the same
on affected populations. Some results are damages as 1 ground-level ton. For the
shown in the following table. Results are rural plants, the results are very different;
in the form of “trading ratios,” which is here the stack and ground-level emissions
the number of tons of pollutant emitted produce the same levels of damage.
from the power-plant stack that causes What these results show is that there
the same amount of damage as would can be very substantial differences be-
1 ton emitted at ground level at the tween sources in terms of damages pro-
same site. The results shown are for fine duced by the same pollutant.
substantially different among sources. The best response here might be to in-
stitute what is called a zoned emission charge. Here the administering agency
would divide a territory into separate zones; the actual number of zones would
depend on the circumstances of the case. Within each zone the agency would
charge the same emission charge to all sources, whereas it would charge differ-
ent charges in different zones.
2 4 6 9 12
MAC1
$ $
MAC2
th
a d
tl
b c e f
e1 e 2 e3 e4
Emissions (lbs/month) Emissions (lbs/month)
to many people that society could benefit by replacing certain existing taxes
with emission taxes. Many countries tax employment, for example. When firms
hire workers, they must pay employment taxes to cover such things as the pub-
lic costs of unemployment insurance and social security payments. But employ-
ment taxes lead to reduced levels of employment because, in effect, they make
hiring workers more expensive. A government, therefore, might reduce its em-
ployment taxes and increase emission taxes in such a way as to keep its total tax
revenue the same. This action has come to be known as the double-dividend
hypothesis. This refers to the fact that society would gain both from the emis-
sions taxes (through reduced emission damage) and from reduced employment
tax (through increased employment).
But predicting the revenue impacts of emission taxes may be difficult. Sup-
pose, in Figure 12.6, an emission tax was increased from tl to th. If the aggregate
marginal abatement costs of the affected firm is MAC1, total tax revenue will
increase from (b + c) to (a + b). But if the marginal abatement cost is actually
MAC2, raising the emission tax will cause tax revenues to decrease from (e + f)
to (d + e). This is because in the case of MAC2 the tax increase leads to a large
decrease in emissions, while in the case of MAC1 it does not. Thus, if the tax
authorities don’t know much about the shape and location of the relevant mar-
ginal abatement, they may be in for some major surprises in terms of changes
in tax revenues.
Research on the double-dividend idea has also brought out another im-
portant factor. This is the potential impact of increased prices of the goods
and services produced by the sectors subject to emission taxes. This can
have a direct negative effect on the welfare of consumers of these goods and
services. It can also have an indirect effect working through changes in the
labor market.5
5
See Don Fullerton and Gilbert E. Metcalf, “Environmental Taxes and the Double-Dividend
Hypothesis: Did You Really Expect Something for Nothing?” Chicago-Kent Law Review, 73(1), 1998,
pp. 221–256.
MAC1
MAC 2
$
t
c
a d
b
e
0
e2 e1
Emissions (tons/year)
may be feasible instead is to put charges on these materials as they are bought
by farmers—that is, say, a charge per ton of fertilizer or per 100 pounds of pesti-
cide purchased. The charge is to reflect the fact that a certain proportion of these
materials ends up in nearby streams and lakes. Because they are paying higher
prices for these items, farmers would have the incentive to use them in smaller
quantities. Higher prices also create an incentive to use the fertilizer in ways
that involve less wastage, for example, by reducing the amounts that run off.
Placing a charge on something other than emissions is usually a “second-
best” course of action made necessary because direct emissions can’t be closely
monitored. In cases such as this we have to watch out for distortions that can
come about as people respond to the charge, distortions that can substantially
alleviate the effects of the tax or can sometimes make related problems worse.
We mentioned in Chapter 1 the move by many U.S. communities to tax house-
hold trash. One technique is to sell stickers to the residents and require that
each bag of trash has a sticker on it. The rate of tax is determined by the price of
the stickers, and it is relatively easy to monitor and enforce the system through
the curbside pickup operations. But the per-bag tax will produce an incentive to
pack more into each bag, so the reduction in total quantity of trash may be less
than the reduction in the number of bags collected.
On Carbon Taxes
We have now realized that reducing global emissions of GHGs is a critically
important activity to pursue. An obvious idea would be to tax emissions of
GHGs, especially carbon dioxide. CO2 emissions result whenever fossil fuels,
that is, fuels containing carbon, are burned to produce energy. A CO2 emission
tax could be placed directly on emissions, assuming they could be accurately
measured.
Another approach is to place a tax on fuel used, since this is strictly propor-
tional to carbon dioxide released.
r The carbon footprint of an item (a physical good, or a service) is the to-
tal emissions of GHGs occurring in the production and consumption of the
item, usually expressed in equivalent tons of CO2 (one ton of CO2 is equiva-
lent to 0.27 tons of carbon).
This tax could fall on commercial establishments. Perhaps a better approach
would be to levy a tax “upstream,” where fossil fuels are first extracted. The tax
would then filter through the system, affecting more heavily the prices of those
goods and services that have large carbon footprints and less heavily on prices
of those with low or negligible footprints, as is depicted in Figure 12.8.
Input markets
Output markets
6
This was discussed in greater detail in Chapter 8.
7
Sterner, Thomas, Fuel Taxes and the Poor: The Distributional Effects of Gasoline Taxation and Their
Implications for Climate Policy, London, Routledge, 2011.
The burden on workers is tied closely to what happens to the rate of output
of the affected firms. Here again, the extent of the output effect depends on
competitive conditions and the nature of the demand for the good. If the emis-
sion tax program is applied to a single firm in a competitive industry or if the
demand for the output of an industry is very responsive to price, output adjust-
ments will be relatively large and workers could be displaced. The long-run
burden is then a matter of whether good alternative sources of employment are
available.
Although burdens because of price and output changes may be real, we have
to remember that, on the other side, the charge program is creating substantial
benefits in the form of reduced environmental damages. To know how a pro-
gram affects any particular group, we would have to account also for how these
benefits are distributed.
Effluent charges also could involve substantial sums going from consumers
of the goods produced by the taxed industry to the beneficiaries, whomever
they may be, of the funds collected by the taxing authorities. These funds could
be used for any number of purposes; how they are used would determine their
impacts. They might, for example, be distributed to lower-income people to
offset the effects of price increases. They even might be returned in part to the
firms paying the effluent taxes. This is done in some European countries to
help finance the purchase of pollution-control technology. As long as the return
payments do not make the marginal emissions tax rate effectively lower, the in-
centive effects of the charge are not affected. Alternatively, they might be used
to pay for other environmental initiatives in places where direct public action
is called for. They even might be used to reduce overall budget deficits, with
benefits flowing to general taxpayers.
Abatement Subsidies
An emission charge works by placing a price on the environmental asset into
which emissions are occurring. Essentially, the same incentive effects would re-
sult if, instead of a charge, we instituted a subsidy on emission reductions. Here
a public authority would pay a polluter a certain amount per ton of emissions
for every ton it reduced, starting from some benchmark level. The subsidy acts
as a reward for reducing emissions. More formally, it acts as an opportunity
cost; when a polluter chooses to emit a unit of effluent, it is in effect forgoing
the subsidy payment it could have had if it had chosen to withhold that unit of
effluent instead. Table 12.1, using the same numbers as in the preceding discus-
sion on emission charges, shows how this works in principle. The firm’s base
level is set at its current emissions rate: 10 tons/month. It receives $120 per ton
for every ton it cuts back from this base. The fourth column shows its total sub-
sidy revenues, and the last column shows total subsidies minus total abatement
costs. This net revenue peaks at 4 tons/month, the same emissions level the
firm would choose with the $120 tax. In other words, the incentive for the firm
is the same as for the tax.
Although an abatement subsidy like this would have the same incentive for
each individual source, total emissions may actually increase. To understand
why, note the difference in the financial position of this firm when it emits 4
tons of pollutant under the two programs: With the tax it has total costs of $855
(see Figure 12.1), whereas with the subsidy it has a total revenue of $345. Thus,
the financial position of the firm is much different. In effect, it will be earning
higher profits after the imposition of the subsidy, and this can have the effect
of making this industry more attractive for potential new firms. There is the
possibility, in other words, of having the emissions per firm go down while
the number of firms in the industry increases, and therefore total emissions
increase. This feature is a major drawback of simple subsidies like this.
Although subsidies linked directly to emission reductions have never be-
come particularly popular, governments around the world have frequently
resorted to many other types of subsidies to further the goals of pollution re-
duction. A few of these are listed in Exhibit 12.3.
Deposit-Refund Systems
One place where subsidies may be more practical is in deposit-refund systems.
A deposit-refund system is essentially the combination of a tax and a subsidy.
For example, a subsidy (the refund) is paid to consumers when they return an
item to a designated collection point. The purpose of the subsidy is to provide
the incentive for people to refrain from disposing of these items in environmen-
tally damaging ways. The funds for paying the subsidy are raised by levying
taxes (the deposit) on these items when they are purchased. In this case, the
purpose of the tax is not necessarily so much to get people to reduce the con-
sumption of the item, but to raise money to pay the subsidy. The tax is called a
deposit and the subsidy a refund, but the principle is clear.
Deposit-refund systems are particularly well suited to situations where a
product is widely dispersed when purchased and used, and where disposal is
Types of Environmentally
Related Subsidies EXHIBIT 12.3
Subsidies in the Form of Example(s)
Tax benefits Tax exemptions for pollution-control
equipment or recycling equipment
Exemptions of ethanol-blended gas
from federal taxes
Reduced environmental fines Reductions in normal fines if firms
undertake extensive pollution-control
plans
Public grants to encourage environmental EPA grants to communities to fund
programs “brownfields” programs1
Grants to farmers to adopt
conservation practices
Grants to businesses or communities
to establish recycling programs
Development rights purchase programs Public purchases of agricultural
development rights to maintain land
in agriculture or open space
Public support of environmental market Public rules on procurement of
development products made from recycled
materials
Cash payments for people who turn
in old, high-emitting automobiles
Cost-sharing grants Grants made to localities to cover a
portion of the cost of building
wastewater treatment facilities
1
Brownfields are contaminated industrial sites that pose relatively low risks, but may be avoided
by private developers because of potential liability problems.
8
As of 2015 these were California, Connecticut, Hawaii, Iowa, Maine, Massachusetts, Michigan,
New York, Oregon, and Vermont, plus Guam.
is subject to a tax (a deposit), the proceeds of which go into a special fund. This
fund is then used to subsidize (the refund side) a waste oil recovery and repro-
cessing system. The terms of the subsidy are set so as to encourage competition
in the recovery/reprocessing system and to provide an incentive for users to
reduce the extent to which oil is contaminated during use.
In Sweden and Norway, deposit-refund systems have been instituted for
cars. New-car buyers pay a deposit at the time of purchase, which will be re-
funded when and if the car is turned over to an authorized junk dealer. Experi-
ence with these systems shows that success depends on more than just the size
of the deposit-refund. For example, it is essential that the collection system be
designed to be reasonably convenient for consumers.
Other items for which deposit-refund systems might be appropriate are con-
sumer products containing hazardous substances, such as batteries containing
cadmium, and car batteries.9 Automobile tires also might be handled this way.
The deposit-refund system also might be adaptable to conventional industrial
pollutants. For example, users of fossil fuels might pay deposits on the quanti-
ties of sulfur contained in the fuels they purchase; they would then get refunds
on the sulfur recovered from the exhaust gas. Thus, they would lose their de-
posit only on the sulfur that went up the stacks.
Summary
Emission charges attack the pollution problem at its source, by putting a price
on something that has been free and, therefore, overused. The main advan-
tage of emission charges is their efficiency aspects: if all sources are subject to
the same charge, they will adjust their emission rates so that the equimarginal
rule is satisfied. Administrators do not have to know the individual source
marginal abatement cost functions for this to happen; it is enough that firms
are faced with the charge and then left free to make their own adjustments. A
second major advantage of emission charges is that they produce a strong in-
centive to innovate, to discover cheaper ways of reducing emissions.
The apparent indirect character of emission charges may tend to work against
their acceptance by policymakers. Standards have the appearance of placing di-
rect control on the thing that is at issue, namely, emissions. Emission charges,
on the other hand, place no direct restrictions on emissions but rely on the self-
interested behavior of firms to adjust their own emission rates in response to
the tax. This may make some policymakers uneasy because firms apparently
are still allowed to control their own emission rates. It may seem paradoxical
that this “indirect” character of effluent taxes can sometimes provide a stronger
inducement to emission reductions than seemingly more direct approaches.
But emission charges require effective monitoring. They cannot be enforced
simply by checking to see if sources have installed certain types of pollution-
control equipment. If emission charges are to have the appropriate incentive
effects, they must be based closely on cumulative emissions.
9
As of 2015, 13 U.S. states had deposit-refund systems for car batteries.