This paper studies plant level data on actual and permitted levels of water
pollution emissions for the pulp and paper industry. There is widespread a
nd substantial overcompliance,with the relevant regulations: aggregate BOD
emissions in 1992 were only 50% of the amount allowed. Overcompliance appea
rs to imply a zero marginal abatement cost and its prevalence therefore has
the potential to substantially change the debate over the costs of regulat
ion. We show instead that plants incurred substantial costs to overcomply.
Marginal abatement costs were roughly $13,000/ton in 1992. We discuss possi
ble explanations for costly overcompliance and their implications for estim
ation. (JEL Q25).