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Tabbed activity summarizing the interaction between APD and the Air Quality Division regarding emissions banking and trading, emissions inventory, the SIP, and Rule Development

Tab Title: Banking and Trading

Tab Content:

· Emissions Banking and Trading Programs (EBTPs) provide flexibility for compliance with the Federal Clean Air Act through a market-based framework for emissions banking and trading while achieving net reductions in air emissions and offer incentives for voluntary air emissions reductions.

· The following two credit programs provide the means to satisfy offset requirements for Nonattainment NSR permits—

» Emission Reduction Credits (ERCs)

» Discrete Emission Reduction Credits (DERCs)

· The following two cap and trade programs were established as part of the Houston-Galveston-Brazoria (HGB) area ozone attainment demonstration—

» Mass Emissions Cap and Trade (MECT)

» Highly Reactive Volatile Organic Compounds (HRVOC) Emissions Cap and Trade (HECT)

*** Both the MECT and HECT programs may also be used for NSR offsets but with certain limitations, and APD staff should work with EBT staff to ensure all program requirements are being met.

· The third cap and trade program, Emissions Banking and Trading of Allowances (EBTA), was established under Senate Bill 7 (SB7) of the 76th Texas Legislature and applies to formerly grandfathered electric generating units.

See the summary table on this page for a quick reference regarding the applicability of the various EBTPs.

Tab Title: Emissions Inventory

Tab Content:

· Emissions Inventory staff...

» develop and maintain the inventory of point and area source emissions,

» manage air emissions research projects,

» implement the air emissions and inspection fee rules, and

» perform audits to ensure fees have been correctly reported.

· A company's emissions inventory data may be used to...

» review compliance with air permit allowables,

» verify netting procedures used in the major NSR permitting process,

» provide emissions data to be used for background modeling,

» meet federal reporting requirements,

» conduct photochemical modeling,

» support rule development,

» document emission trends,

» support investigations conducted by Field Operations staff, and

» determine fee amounts.

Tab Title: SIP

Tab Content:

· The SIP is the state's plan for air quality protection and improvement and explains how the state will comply with federal air quality standards according to the Federal Clean Air Act. These standards are the National Ambient Air Quality Standards (NAAQS) for criteria pollutants (particulate matter, sulfur dioxide, nitrogen dioxide, carbon monoxide, ground level ozone/smog, and lead).

· A SIP must be submitted by the state government of any state that has areas that are designated as nonattainment for federal air quality standards.

· The SIP will reduce pollution to meet health-based standards by...

» setting control strategies for reducing emissions,

» being applied to areas not meeting federal air quality standards, and

» setting technical and regulatory processes for demonstrating attainment.

· In limited situations, there may also be SIP requirements for specific attainment areas.

· 30 Texas Administrative Code (TAC) Chapter 116 and air permits are part of the SIP. Additional SIP rules, such as 30 TAC Chapters 115 and 117, may require additional emission controls and/or process changes to permitted facilities to achieve SIP pollution reductions.

· Non-compliance with the SIP may result in...

» a federal implementation plan,

» greater difficulty in facilities obtaining federal air permits, and

» cut-off of federal highway funding.

Tab Title: Rule Development

Tab Content:

In addition to the specific permit related work conducted by the areas mentioned, AQD staff members also play a role in the development of air permitting rules and standard permits by providing comments regarding the proposed language and its uniform compliance with engineering standards and scientific accuracy and feasibility.


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