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CAIR Frequent Questions - Compliance Supplement Pool for NOx Annual Program

Q: How do I apply for CSP allowances?

A:Instructions for applying for CSP allowances can be found here. (Word, 1 page)

Q: How was the 200,000 ton Compliance Supplement Pool (CSP) figure arrived at? Was the CSP figured into the CAIR modeling? Is it correct that the CSP allowances can only be used January-April 2009 and October-December 2009? (pg. 25274/3)

A: The CSP is discussed on 70 FR 25209. The CSP was used in the CAIR modeling. The CSP is only part of the NOx annual requirements; other than that, there are no restrictions on when CSP allowances can be used.

Q: How discretionary is compliance supplement pool disbursement? As explained on page 25263, the CSP must be allocated based either on early reductions achieved in 2007 and 2008, or based on a demonstration of need for extending the compliance deadline beyond 2009.

A: Compliance supplement pool allowances may be distributed for early reductions in 2007 and 2008, or to address issues of reliability of electricity supply in 2009. See 51.123(e) (4) for the distribution limitations and also 96.143 (b) and (c) for suggested trading rule language.

Q: If the NOx compliance supplement pool doesn't significantly impact the marginal cost of compliance what does EPA believe its value to be? (pg. 25209)

A: As explained on 70 FR 25222, the compliance supplement pool could be used to help companies that may not be able to complete all control installations by January 2009.

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