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. 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.
|• ||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|
Questia, a part of Gale, Cengage Learning. www.questia.com
Book title: Emissions Trading, an Exercise in Reforming Pollution Policy.
Contributors: T. H. Tietenberg - Author.
Publisher: Resources for the Future.
Place of publication: Washington, DC.
Publication year: 1985.
Page number: 120.
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