Several states have mandated faster and/or deeper reductions in plant mercury emissions than those called for by the Clean Air Mercury Rule. Unfortunately, differences between plants make accurate evaluation of control options difficult. In most cases, even statistically based Hg emission models don't pass muster because they don't account for the dynamic chemical behavior of Hg species in gas cleaning systems. This article describes one system evaluation tool that has been validated using Ha field test data from 50 full-scale flue gas cleaning systems. It is already being used by TVA and other utilities.