RGGI was designed to be reviewed periodically rather than operate indefinitely under its original rules. Since the program began in 2009, the participating states have completed three major Program Reviews. Each has changed the future supply of allowances and the mechanisms used to manage allowance prices.
The Original Program: 2009–2013
RGGI began in 2009 with a regional cap of approximately 188 million tons per year for the original ten participating states. When New Jersey withdrew after 2011, its allowance budget was removed, reducing the regional cap to approximately 165 million tons in 2012 and 2013. That reduction reflected the change in membership rather than a tightening of the emissions limit.
Actual emissions were substantially below the original cap. Because unused allowances could be banked, a large surplus accumulated. At the end of 2013, 319 million allowances were in circulation compared with 179 million tons of cumulative compliance obligations, leaving approximately 140 million surplus allowances.
The program’s first major redesign was aimed largely at correcting that oversupply.
First Program Review — Correcting the Original Surplus
Completed in 2013, the First Program Review reduced the 2014 regional cap from approximately 165 million tons to 91 million tons, a reduction of about 45 percent, and scheduled further 2.5 percent annual reductions through 2020.
But lowering the future cap did not eliminate the allowances already held by market participants. RGGI therefore made additional downward adjustments to the number of new allowances distributed between 2014 and 2020 so the existing bank could gradually be absorbed. Those adjustments totaled approximately 139.5 million allowances over the period.
The First Review also created the Cost Containment Reserve (CCR). The CCR made additional allowances available if auction prices reached specified trigger levels, providing additional supply if allowance prices rose more rapidly than anticipated.
The result was a two-part strategy: reduce the supply of new allowances to work down the accumulated surplus while maintaining a reserve that could release additional allowances if prices became sufficiently high.
Second Program Review — Further Tightening and Managing the Bank
The Second Program Review was completed in December 2017. It continued the decline in the emissions cap, adopting a trajectory designed to reduce the regional cap by another 30 percent between 2020 and 2030.
The allowance bank remained an important issue. The updated rules therefore created a Third Adjustment for Banked Allowances, reducing allowance budgets during 2021–2025 to account for surplus pre-2021 allowances still held by market participants. The resulting adjustment totaled approximately 86.8 million allowances over those five years. Market participants remained free to retain and use their banked allowances.
The Second Review also added the Emissions Containment Reserve (ECR). Unlike the CCR, which increased supply when prices were high, the ECR withheld allowances when prices fell below a specified level. RGGI therefore had mechanisms operating in both directions: additional supply could enter the market when prices became high, while supply could be withheld when prices became unusually low.
Third Program Review — A Much Steeper Post-2027 Framework
The third review was completed in July 2025. For the ten states examined in this report, the changes substantially accelerate the reduction in the base cap beginning in 2027. Virginia is not included in the cap and reserve figures discussed here.
The RGGI-10 base cap falls to approximately 69.8 million tons in 2027 and then declines rapidly through 2033. From 2034 through 2037 it continues falling, reaching approximately 9.0 million tons in 2037. Existing banked allowances are not canceled and remain available for compliance.
The 2025 changes also:
- raise the minimum auction price to $9.00 in 2027, increasing 7 percent annually;
- eliminate the ECR and replace it with the higher minimum auction price;
- expand the cost-containment system to two reserve tiers;
- provide approximately 11.75 million allowances in each reserve tier annually beginning in 2027;
- remove standard allowances from circulation if they are offered at auction but remain unsold; and
- eliminate the issuance of new offset allowances beginning in 2027.
The states also committed to begin another Program Review no later than 2028, including consideration of the cap trajectory, reliability, affordability, electricity-load growth, and clean-energy deployment.
The Overall Direction
The three reviews show a clear evolution in the program.
The First Review responded to a cap that had become far too loose and to a large accumulated allowance surplus.
The Second Review continued reducing allowance supply and introduced additional mechanisms to manage both the allowance bank and low market prices.
The Third Review goes considerably further. Beginning in 2027, the base cap falls rapidly, the auction floor rises substantially, unsold allowances are removed rather than returned to future auctions, and additional allowances are made available only through defined cost-containment mechanisms.
The result is a program that is structurally different from its early years. RGGI began with emissions well below the cap and a growing surplus of inexpensive allowances. The post-2027 framework is designed around a much smaller and declining supply of new allowances, while previously banked allowances provide only a temporary source of additional compliance flexibility.