2015 Ozone Standards and Affects on Future Expansions in New Nonattainment Areas. Role of Emission Reduction Credits

摘要

1. The 2015 NAAQS Ozone Standard will create new nonattainment areas across the country which may bring challenges to facilities looking to expand or build in these areas as their may be a shortage of Emission Reduction Credits. How many new. nonattainment areas will be created? Will they allow interpoliutant trading? Will they allow interstate trading? Will they allow intrastate trading between nonattainment areas? There are many lessons to learn from existing nonattainment areas and the Emission Reduction Credit (ERC) registry. There is a shortage of ERCs in many parts of the country including the Northeast and the Gulf Coast. VOC ERCs are especially scarce and air modeling has been used in Texas, Pennsylvania, and Louisiana as of late to allow NOx ERCs to offset VOC emissions. In some cases, new regulations were required to be written to allow for interpoliutant trading. New facilities that are looking to site a new major chemical plant, refinery, power plant or similar facility with large emissions will need to factor in the new counties that are now newly nonattainment and the difficulty of receiving an air permit that the nonattainment status now brings upon the region.