Emissions Trading, An Exercise in Reforming Pollution Policy

By T. H. Tietenberg | Go to book overview
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trading program and achieving the ambient standards has been necessarily loose. Annual reductions in emissions are neither necessary nor sufficient for improvements in air quality at those monitors recording pollution levels exceeding the standards.With the achievement of the ambient standards in doubt due to the absence of an adequate air quality accounting system, the states have followed an excessively risk-averse strategy. Immediate extra reductions were sought wherever they could be found in the hope they would be sufficient. As part of this frenzied search for reductions, shutdown credits have been confiscated, preventing their use for any other purpose and minimum control thresholds have been imposed to prevent emission reduction credits being used to satisfy BACT, LAER, and NSPS standards. Allowable emissions trades that permit actual emission increases are also an outgrowth of an inadequate air quality accounting system.The ability to develop an accurate and effective air quality accounting system hinges on the ability of state control authorities to define a unique allowable emissions level for each major source, to issue permits consistent with that definition, and to monitor for compliance. These do not seem insurmountable problems, particularly since Oregon already has the basic ingredients of this approach in place.21 At the core of the Oregon rules lies the plant site emission limit, an allowable emissions standard placed on all new and existing sources larger than some minimum emissions threshold. These emission limits are incorporated into the operational permits received by the sources and are based on actual emissions in 1977 or 1978 minus any required controls since that time. The total amount of pollution allowed by these limits is consistent (including some anticipated reversion of shutdown credits to the state) with the baseline in attainment areas. Any emission trades result in adjustments in the operating permits of both the acquiring and relinquishing sources. With this type of air quality accounting system, emission trades can be conducted without jeopardizing air quality. Without an adequate air quality accounting system, states will either continue to engage in cost-ineffective practices to protect air quality or air quality can deteriorate. Neither alternative is attractive.
SUMMARY
By the manner in which it assigned the control responsibility, the command-and-control approach imposed a very large and unequally distributed financial burden on complying sources. Because they bore a
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21
Kostow and Kowalcyzk ( 1983, p. 982).

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