EPA Ozone/PM/Haze FACA Subcommittee

Science and Technical Support Work Group

Position on

New Source Review Issue Paper

Issue:	How are the emissions from new and modified stationary sources addressed in AOVs and AOIs?

BPAP Work Group Recommendation:

Option number 4( Establish the potential for trading and banking emissions between new and existing major sources for offsets and other requirements under the SpIP's new source provisions), with a phase-in to Option 4.a. (inter-pollutant trading). Individual SpIP's could implement a demonstration program allowing inter-pollutant trading.

STSWG Comments:

BPAP's 9/19/96 version of the NSR reform issue paper is a significant improvement over the 8/28/96 version. However, there are still at least two major issues which remain.

1. The list of NSR Options should be reduced to two options. Either the AOV and AOI have the same requirements for NSR or they don't. Options 2.a-4.a are just a few of the possible implementations of Option 2.

A cap & trade option can not currently necessarily address the issue of impact equivalency (i.e., a ton of a certain pollutant at one point in an AOI may not have the same impact as a ton of the same pollutant at another point in the AOI). The implementation of a cap & trade program for the same pollutant may be very costly to implement - and the tools necessary for implementation may not even be available at this time. To compound this by adding inter-pollutant trading at this time is not reasonable.

BPAP's recommendation is the politically correct recommendation. It represents the desired state. It does not make scientific sense at this time. Such a program, even if possible, will be resource intensive, and some areas may not have the necessary resources.

Recommendation: Option 2, allowing different NSR requirements in AOVs and AOIs, and allow each area to define that difference as part of the SIP or "Spatially Integrated Plan."

2. There is no mention of what the requirements will be for a new source which may wish to locate in an AOV that is not in the AOI.