In this presentation for Vermont Law School, David Farnsworth examined the challenges regulators faced in establishing the Regional Greenhouse Gas Initiative (RGGI) and the key steps they undertook in adapting existing cap-and-trade models to produce a successful electric sector carbon management program. He explores how the Regional Greenhouse Gas Initiative continues to provide a strong model—relying on its central features of allowance auctioning and recycling revenue into clean energy investment by member states—for mass-based compliance under the U.S. Environmental Protection Agency’s Clean Power Plan.