United States
Environmental Protection
Agency
Air and Radiation
(ANR-445)
xvEPA State Acid Rain Program
Final Report
Appendices
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State Acid Rain Program
Final Report
Appendices
By David Bassett
Office of Air and Radiation
Office of Atmospheric and Indoor Air Programs
Emerging Programs Staff
U.S. Environmental Protection Agency
401M Street, SW
Washington, DC 20460
March 1989
- I"-,, «:e,,.,y
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State Acid Rain Projects
Brief Summaries
Appendix A
Office of Air and Radiation
Office of Atmospheric and Indoor Air Programs
Emerging Programs Staff
U.S. Environmental Protection Agency
401M Street, SW
Washington, DC 20460
March 1989
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State; Alabama
Study: Sulfur Dioxide and Nitrogen Oxides Emissions from
Industrial and Utility Sources in Alabama from 1980 to
1985
Key Word; Emissions Inventory
Purpose;
The purpose of the Alabama study was to develop an emissions
inventory of stationary sources of sulfur dioxide and nitrogen
oxides for the years 1980 through 1985. The inventory excludes
boilers of less than 50 MMBtu/hour heat input capacity and
industrial processes that emit less than 100 tons per year of
sulfur dioxide or nitrogen oxides.
Results;
TOTAL SULFUR DIOXIDE AND NITROGEN OXIDES EMISSIONS
(TONS PER YEAR)
Year Sulfur Dioxide Nitrogen Oxides
1980 665,678 235,475
1981 676,489 230,020
1982 507,983 188,999
1983 569,115 201,485
1984 564,544 215,212
1985 653,158 247,459
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SULFUR DIOXIDE EMISSIONS BY INDUSTRY
(1985)
Industry
Utilities
Pulp/Paper
Petro/Gas
Chemical
Bas Metals
Fin Metal
Textiles
Minerals
Tire Manufacturers
Other
Tons/Year
531,324
48,614
47,529
11,208
8,534
374
1,177
4,164
199
35
% of Total
7,
1,
81.35%
7.44%
28%
.72%
1.31%
.06%
.18%
.64%
.03%
.01%
NITROGEN OXIDES EMISSIONS BY INDUSTRY
(1985)
Industry
Utilities
Pulp/Paper
Petro/Gas
Chemical
Bas Metals
Fin Metals
Textiles
Mineral Products
Tire Manufacturers
Other
Tons/Year
201,408
25,941
2,051
5,205
2,753
135
2,122
7,302
254
324
% of Total
81.39%
10.48%
.81%
2.10%
1.11%
.05%
.86%
2.95%
.10%
.13%
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State; Connecticut — Economics
Study; Assessment of Economic Implications of Connecticut and
Federal Sulfur Dioxide Control Policy Options
Key Words; Fuel Switching; Cost
Purpose;
This project examined the economic impact of a change in
Connecticut's 1.0% sulfur by weight limitation to 0.5% on state
utility customers. The project also evaluated the economic impacts
of several federal proposals. These include: (1) a 0.9 pound
sulfur dioxide per million BTU limitation without cost sharing
sponsored by Senator Mitchell (S-321); and (2) a surcharge on non-
nuclear electricity generation and imported power with states
sharing the costs of achieving a 10 million ton reduction in the
48 contiguous states (H.R. 3400).
Results:
o If a 0.5% sulfur by weight limitation is imposed on fuel
oil, a 500 kilowatt hour customer in Connecticut would pay
between $ .20 to $ .55 a month extra in 1987. By 1995, the
costs will have increased to $ .45 to $ .69 per customer per
month.
o If a 0.9 Ib sulfur dioxide per million BTU limitation is
imposed by the federal government, a 500 kilowatt customer
in Connecticut would pay an additional $ .33 per month.
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A 1.0 mill surcharge would cost the average 500 kilowatt per
month customer $.18 to $.45, while a 4.9 mill surcharge
would cost the same customer $.88 to $2.18.
All proposals generally fall within the $1.50 per month
increase in costs that the Connecticut public perception
survey determined to be acceptable to 70% of the utility
customers (see Connecticut — Opinion Survey).
Connecticut would accomplish greater in-state reductions of
elemental sulfur loadings by participating in a national
program than by adopting a state-wide 0.5% sulfur (by
weight) limitation on fuel oil. The estimated cost of
reducing each ton of elemental sulfur by adopting a 0.5%
sulfur-in-fuel limitation is approximately twice the cost of
participating in the Federal control program assumed by this
study.
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State: Connecticut — Emissions Inventory
Study: Projected Sulfur Oxide Emissions in Connecticut Status
Quo and Revision to 0.5% Sulfur Content in Fuel
Key Words;
Emissions Inventory; Fuel Switching
Purpose;
This study has a two-fold purpose. First, projections were made
of Connecticut's sulfur oxide emissions for the period 1980 through
1995 assuming moderate economic and population growth. Second, the
impact of limiting fuel oil sulphur content to 0.5% from the
current 1.0% limitation on sulfur oxide emissions was estimated for
the years 1987 through 1995.
Results;
CONNECTICUT PROJECTED SULFUR OXIDE EMISSIONS
(TONS)
Electric
Industrial
Commercial
Residential
Total
1980
33,734
13,711
4,713
12,428
1984
59,436
12,084
8,807|
8,685
1987
45,252
12,627
9,623
9,134
1990
33,384
12,803
10,229
9,423
1993
28,106
13,453
10,626
9,757
1995
32,011
13,573
10,841
9,966
73,601
98,027
85,651
74,854
70,957 73,606
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The reduction in sulfur oxides from 1984 to 1995 are a
result of decreases in fuel oil consumption. These
reductions are attributable to increases in nuclear power
generation, natural gas burning at two generating units,
hydroelectric power purchased from Canada, and purchases
from refuse-derived fuel and cogeneration projects.
Projected reduction in sulfur oxide emissions with
imposition of 0.5% sulfur by weight fuel limitation for fuel
oils for 1987 is 22,912; for 1990, 17,981; for 1993, 16,026;
for 1995, 17,022.
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State: Connecticut — Opinion Survey
Study; A Survey of Connecticut Residential Electricity
Customers' Perceptions of Acid Rain Issues
Key Words; Regional Approaches; Public Perceptions
Purpose;
This Connecticut project consisted of a public perception survey
designed to ascertain the views of residential electricity
customers in the state on acid rain. Telephone interviews of 764
residential electricity customers were conducted at random with
the sample apportioned to reflect the distribution of customers
with three residential rate classes within each service territory.
The sample design provides an overall confidence level of 95% plus
or minus 4% for the responses.
Results;
o 74% (564) of the respondents were aware of acid rain? 28%
were very concerned and 48% were somewhat concerned with its
impact.
o Connecticut state action to control acid rain in conjunction
with other New England states was favored by 57%.
Connecticut's acting on its own was favored by only 10%.
Government action was not favored by 2.5% of respondents.
o While 91% of the respondents believed that more research
should be done on acid rain, over 75% believed that more
controls should be put in place to reduce acid rain despite
the research not being completed.
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o Respondents were queried concerning their willingness to pay
successively higher monthly charges for state and/or federal
acid rain control programs.
Willingness to Pay State Program Federal Program
$ 1.50 per month 70.5% 67.5%
$ 5.00 per month 28.9% 26.5%
$10.00 per month 7.8% 6.7%
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State: Florida
Study; Acid Rain Control; A Cost Estimation Model for Florida
Key Words; Cost; Planning Criteria; Fuel Switching; Emissions
Trading; Scrubbers; Coal Cleaning
Purpose:
The purpose of the Florida study was to determine the most cost-
effective methods of meeting potential federally mandated sulfur
dioxide emissions requirements that would apply to electric power
plants in Florida. The study focused on specific plants and on
the most cost-effective method of reaching or maintaining a
regulated level of emissions. The desired result was the lowest-
cost sulfur dioxide reduction option for each site in Florida.
Results;
o There are 90 utility units in Florida which emitted a total
of 469,247 tons of sulfur dioxide in 1985. The 68 oil-fired
units emitted 67,387 tons of sulfur dioxide or 14.4% of the
total. The 22 coal-fired units emitted 401,860 tons of
sulfur dioxide or 85.6% of the total.
o The 22 coal-fired units at 6 plants face the greatest cost
of compliance. Coal plants may meet emissions limits at a
certain level by either coal switching or by installing
scrubbers. However, once the regulations become
sufficiently strict, only scrubbers may be used.
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Many of the Florida coal units are old and are scheduled for
retirement either during the study period or shortly
thereafter. Therefore, it would be uneconomical to install
scrubbers at these plants.
For coal plants, a limit of 2.0 pounds of SC>2/MMBtu may be met by
using coal with an approximate sulfur content of 1.2%. The use
of .7% sulfur coal would allow compliance with a 1.2 pound
S02/MMBtu limit. If 0.4% sulfur coal were available, it could be
used to meet a .75 pound SO^MMBtu limit. To obtain 0.4% sulfur
coal, however, chemical coal cleaning to remove the organic
sulfur would be necessary.
For most coal-fired units, the total cost of compliance by use of
scrubbers increases as the regulations become more rigorous,
while per ton costs of reduction actually decline with the
increased stringency of these limits. The reason is that the
significant capital expense portion of the total cost of
scrubbers is essentially fixed once the scrubber system is
installed. This fixed cost is then distributed over more tons of
reduction as the standard becomes more strict.
Oil switching involves the use of low-sulfur oil. Relatively few
capital adjustments are needed to accommodate the new fuel. Most
of the costs would thus be reflected in the fuel adjustments.
The relatively low actual emissions rates at oil units indicate
that most emissions reduction would have to come from coal units.
But if legislation were to allow inclusion of oil plants in a
state-wide average pounds S02/MMBtu standard, rather than a
specific limit at each unit, fewer emissions reductions from coal
units would be required. Emissions rates set for each unit would
result in a greater overall reduction of S(>2 at each proposed
standard.
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An emissions trading system could result in maintaining the
proposed standards with a savings in reduction costs if the
assumptions included in the study hold true.
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State; Illinois — IAUSM
Study; Illinois State Advanced Utility Simulation Model
fIAUSM) STAR Project
Key Words; Control/Cost Modeling; Fuel Switching
Purpose;
The purpose of the project was the investigation of the usefulness
of the Illinois State Level Advanced Utility Simulation Model
(IAUSM) for evaluating policy scenarios. These scenarios included
the allocation of emissions reductions on 1) a cost-effectiveness
basis, 2) a uniform rollback, and 3) a minimization of economic
impact on Illinois coal mining.
Results;
The major result was that IAUSM was difficult to use and, in fact,
did not appear to operate correctly. Illinois does not recommend
its use.
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State: Indiana
Study; Emissions Inventory Verification
Key Word: Emissions Inventory
Purpose;
The purpose of the project was to verify Indiana's 1985 emissions
inventory for large sulfur dioxide and nitrogen oxides emissions
sources. Indiana verified all sources with emissions of sulfur
dioxide and/or nitrogen oxides greater than 100 tons in 1985.
Results;
o Approximately 0.6 work-years of effort was required to
perform the review conducted by Indiana. This level of
effort is expected to be typical of the level of resources
required by other states to accomplish this task with a
similar number of sources.
o If daily or monthly emissions or stack parameters (necessary
for long-range transport modeling) or other such information
is deemed necessary, considerable extra effort would be
required.
o Nitrogen oxides emissions estimates are generally
speculative and any national effort to develop an inventory
should focus on means of improving these estimates.
o Sulfur dioxide emissions estimates for the nine highest
emitting sources differed by less than 0.1% through the
verification process. These nine sources represent 68% of
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the sulfur dioxide emissions for 1985. The total
discrepancy for sulfur dioxide from all sources was 0,6% and
for nitrogen oxides was 3.2%.
Such a verification effort may be useful for determining
emissions reduction requirements for individual sources but
may not be critical for determining a state's emissions
reduction target.
A total of 124 sources emitted over 100 tons of sulfur
dioxide, and 110 sources emitted over 100 tons of nitrogen
oxides. There were 81 sources that exceeded over 100 tons
of both pollutants.
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State; Kentucky
Study! KentuckyState AcidRain (STAR) Project
Key Words: Planning Criteria; Cost; Fuel Switching; NOX
Reductions,* Scrubbers; Coal Cleaning; New
Technologies
Purpose:
The purpose of the Kentucky study was to identify criteria for
evaluating and selecting techniques to control emissions of sulfur
dioxide and oxides of nitrogen from large combustion sources. The
project was designed to identify (and resolve where possible)
issues which might be encountered with a major national control
program.
The Kentucky study evaluated 12 different scenarios for three
levels of emission control stringency for specific sources in
Kentucky. Fuel-switching and credit for NOX reductions were
allowed in some scenarios and prohibited in others. The control
scenarios were compared by their effectiveness and efficiency in
reducing SC>2 and NOX emissions (including the cost-effectiveness
of each scenario).
Results;
o The following six criteria were found useful in predicting
the merit of each control technology for each source:
technological considerations; economic impact; potential for
emissions reduction; contractual obligations; cost to the
source; and effect on nitrogen oxides emissions. Two of the
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criteria (technological considerations and contractual
obligations) were used in determining cost to the source.
Six other criteria were found useful as compliance criteria:
sulfur content of existing fuel supply; boiler size; boiler
capacity factor; retrofit capacity; target reduction level;
and control technique limitations.
The study determined that the usefulness of a particular
criterion in the selection of control techniques may depend
on the value selected for other criteria. For example, as
higher target reduction levels are specified, the relevance
of "cost to the source" declines and the importance of
"potential for emissions reduction" increases.
The study determined that while switching to lower-sulfur
coal was the least expensive S(>2 reduction strategy, coal
switching alone would not yield sufficient SC>2 reductions to
meet the probable targets of federal legislation.
The comparative difficulties of applying technologies to
specific facilities were examined and the relative costs of
strategies are compared in the following chart;
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EFFECT OF ALLOWING CREDIT FOR BOTH SULFUR DIOXIDE AND OXIDES OF
NITROGEN REMOVAL ON COST PER TON
Control Technique
Mean
Cost/Ton
for
Removing
S02
Mean
Cost/Ton
for
Removing
Both SO2
and NOV
Duct Sorbent Injection
Coal Cleaning
Gas Conversion 1.2I
Gas Conversion 50%
Natural Gas Reburn (NGR)
Natural Gas Reburn (NGR)
Fluidized Bed (AFBC)
15%
25%
$2,528
$1,477
$1,236
$1,527
$2,429
$2,393
$9,470
$2,413
$1,427
$1,150
$1,406
$ 976
$1,264
$3,802
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State; Maryland — State-wide Caps
Study; (Draft) state-wide Caps on Sulfur Emissions in Maryland
Key Words; Emissions Trading; Environmental Dispatch;
Regional Approaches; Planning Criteria
Purpose;
The report discusses a state-wide percent reduction in allowable
emissions requirement and an allowable fuel sulfur content for
various source categories. Scenarios examined include: no
emissions trading; interstate trading; emissions reduction credit
market; importing electricity; emissions fees; and centralized
interstate emissions allocation. Public Service Commission and
Federal Energy Regulatory Commission general responses to various
control scenarios are presented. The report describes the
structure and determination of utility rates in Maryland and the
types of utility expenses that can be recovered.
Results;
The Maryland study raised the issue of whether a state-wide cap
should be set only to meet federal standards, or should be set
below the federal standard to allow for future growth? If a state
chooses to allow for future growth, how should it apportion
emissions reductions and enforce the reductions?
o Utilities in the state are part of multi-state grids that
share electricity. They are continuously making implicit
emissions trades by having power generated elsewhere for
their clients or by generating power for transmission out of
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state. Maryland should allow interstate emissions trading
of sulfur emissions. This could be combined with a program
controlling sulfur emissions from utilities by a least-cost
dispatch approach with a long (annual) or short term
emissions cap.
o Maryland should require a percentage reduction in allowable
emissions for several or all source categories. The
affected facilities would decide how to meet the required
percent reduction. Alternatively, the allowable sulfur
content of the fuel could be reduced.
o Monies collected by the state under an emissions market or
fee option program could go to either the general fund, the
air quality management and monitoring program, or be used to
subsidize the installation and operation of additional
emissions control to provide offsets for new or expanding
sources.
o In Maryland, electric rates consist of two components: rate
base and fuel adjustment. Fuel adjustment rate changes are
easier and can be accomplished more quickly than rate base
changes.
o Some loss of efficiency in producing low-cost electricity
would be expected (at least in Maryland) from both a
no-emissions-trading scenario and an emissions-trading-
reduction scenario. It is anticipated that the increased
costs from additional emissions reduction requirements could
be recovered by utilities through increased rates.
o Currently, transmission capacity rather than incentives and
disincentives in the rate-making process is limiting
environmental dispatch in the eastern United States. This
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high usage of transmission capacity reduces the flexibility
of the system to engage in more extensive trading or in a
grid-wide emissions limitation.
An interstate commission may be a successful way of
enforcing a grid-wide emissions limit. It would be
desirable to clearly delineate the enforcement
responsibilities of each participating member in such a
commission.
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State; Maryland — Facility Cap
Study; Description of the Emissions Cap at Westvaco
Corporation's Luke Mill (Luke. Maryland) and Discussion
of Possibly Extension of this Emissions Control
Approach to Other Major Industrial Sources
Key Word; Industrial Controls
Purpose;
This study reviewed what the State of Maryland has learned from
placing a sulfur dioxide emissions cap on a pulp and paper mill
owned and operated by Westvaco Corporation in Luke, Maryland. The
purpose of the emissions cap is to attain and maintain the sulfur
dioxide national ambient air quality standard (NAAQS) in the
vicinity of the mill. The cap is a variable tons per 3-hour block
average emissions limit based on percent plume buoyancy and a tons
per day block average limit. The cap is applied to the combined
sulfur dioxide emissions from two coal-fired boilers and one oil-
fired boiler vented through a common 600-foot stack.
Results;
o An emissions cap can allow a source to achieve the sulfur
dioxide NAAQS and can provide more flexibility by allowing
greater fluctuations, or higher, short-term emissions than
could occur with an instantaneous emissions limit (e.g., a
Ib/second limit).
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The Luke Mill can meet its emissions cap by varying its load
and/or fuel sulfur content. Single or multiple sources may
also be able to meet the cap by varying their number of
operating hours per season or per year.
Compliance monitoring, periodic reporting, and rigorous
quality assurance become especially important with emissions
caps that can vary with operating hours, load, and/or have
seasonal or annual averaging times.
A short-term emissions cap may be used as a guideline for
attaining a seasonal or annual emissions cap.
To properly derive and implement an emissions cap, source
modeling may be needed to ensure attainment and maintenance
of the NAAQS and PSD increments.
A contingency plan, such as an available supply of low-
sulfur fuel, may also be needed to ensure compliance with an
emissions cap under all circumstances.
Non-utilities may be more suitable candidates for emissions
caps because they retain the flexibility to downscale
production guickly if necessary to maintain a cap. If,
however, a cap with a season or annual averaging time is
used, rapid changes in production would less likely be
needed to maintain the cap.
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State; Massachusetts — Planning
Study: Development and Testing of Planning Approach to Acid
Deposition Control
Key Words: Fuel Switching; Energy Conservation; Planning
Criteria; Constraints
Purpose;
This study focused on a number of major issues of concern to states
that will carry out an acid rain program. These issues included
how to plan for and organize a program, data requirements,
identification and testing of criteria to evaluate control
techniques and acid deposition control strategies, and alternative
acid deposition control strategies. Five alternative strategies
were identified and evaluated: (1) cost-effective (absolute), (2)
cost-effective (administration), (3) gas substitution, (4) low
conservation/alternative energy, and (5) high
conservation/alternative energy. The strategies were examined to
determine their effectiveness for four different levels of control:
(1) 26% reduction, (2) 26% reduction maintained (during
implementation period), (3) 35% reduction, and (4) 35% reduction
maintained (during implementation period).
Results;
o The conservation and•alternative energy strategies are
superior to the other strategies, while the gas substitution
strategy comparatively performs very poorly.
o No suitable alternatives to the state-federal State
Implementation Planning (SIP) planning process were found.
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Existing SIP requirements could be adapted if control
legislation passed with language that made emissions
reductions the functional equivalent of meeting the NAAQS.
The SIP process is cumbersome and lengthy but might be
improved by "parallel processing." This would allow EPA
interaction in phases as the SIP is being developed rather
than the current method of serial processing.
The planning burden increases if two pollutants are
controlled rather than one. The planning effort increases
as state flexibility increases. The longer the overall
implementation time, the greater the prospects of
incorporating complex or innovative controls.
Individual state action can only partially protect state
resources because acid deposition is an interstate problem.
Emissions trading is essentially theoretical either because
of the practical problems of implementation or because
implementation is at an early stage.
Unlike existing air programs, which are driven by attaining
NAAQS, cost and socio-economic impacts may be legitimate
evaluation criteria.
Differences between most congressional bills affect state
reduction targets more than the direction and/or magnitude
of state planning efforts. Other differences influence the
level of detail and/or comprehensiveness of planning efforts
but do not require fundamentally different planning
approaches.
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State: Massachusetts — Trading
Study: Emissions Trading within Acid Deposition Control
Key Words; Emissions Trading; Regional Approach; Cost
Purpose;
The study evaluated the use of emissions trading as a possible
means of controlling acid deposition precursor emissions. The
study examined differing approaches to emissions trading program
structure and design, and estimates of resources needed to develop
and operate a program. The study also contains interviews with New
England air agency directors and their experiences with and
attitudes toward emissions trading.
The study identifies and examines advantages and disadvantages of
emissions trading for stationary sources. Discussion of program
structure and design focused on:
o who can participate in an emissions reduction credit
program
o what types of activities (plant shutdown, fuel
switching) can be credited
o what type of baseline is necessary to develop an
effective program
o what types of transfers should be allowed.
The study also examined criteria for evaluating emissions trading
program rules. The criteria identified were: pollution control,
administrative simplicity, clear and simple rules, inclusiveness,
and flexibility.
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The study also identified resources needed to implement an
emissions trading program and presented findings and
recommendations.
Results;
o Although emissions trading offers potential cost savings to
the regulated community by providing regulatory flexibility,
the administrative burden placed upon air agencies and the
resource intensive nature of such a program has led to
divided opinion on the practicality of implementing
emissions trading on the broad basis required.
o The larger and less restricted the emissions trading market,
the greater the potential cost savings.
o Regulations are necessary (i.e., emissions trading must not
cause NAAQS violations), and institutional barriers are
inevitable (i.e., PUC rate regulatory treatment of emissions
reduction credits).
o Setting a proper trade baseline must require that reduction
be both real and surplus, not merely fabricated on paper.
o Prohibiting emissions reduction credits for acid deposition
control in non-attainment areas may accelerate attainment.
While this may preclude some potentially cost-effective
trades, the sacrifice may be worth making.
o Emissions trading between non-proximate sources may change
the spatial distribution of emissions. Therefore,
restrictions may need to be placed on trading between non-
proximate sources.
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There are no direct legal barriers to interstate trading.
However, states' SIP rules vary, as do emissions inventories
and banking and trading rules. To facilitate trading,
divergent state rules and regulations must be reconciled.
Experience with emissions trading programs to date indicates
that developing an emissions trading program requires more
resources than operating one. Start-up costs have been
recovered, at least partially, through fees on program
participants.
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State: Massachusetts — DEM
Study; Dynamic Emissions Management for Acid Deposition
Control
Key Words; Rate versus Target; Maintaining Compliance
Purpose;
The study focused on the information needed to determine the
compliance status of all regulated sources and Massachusetts as a
whole with possible Federal acid rain legislation. It specifically
emphasized the information needed to determine the compliance
status of large point sources of SO2-
The purpose of dynamic emissions management is to track and
maintain compliance with emissions control programs—particularly
programs that are based upon relatively long averaging times or
emissions caps. Dynamic emissions management involves the
following process: emissions information is collected and reviewed
before the compliance periods projections are formally submitted;
the probability of achieving compliance without taking remedial
action is determined; and, if remedial action appears necessary to
avoid non-compliance, steps are taken to implement remedial
actions.
Results;
o Short compliance periods (monthly and possibly quarterly)
may not allow adequate time to effectively implement the
entire dynamic emissions management process within a given
compliance period.
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Compliance periods of longer times (six months to a year)
provide greater opportunity for effectively implementing the
entire dynamic emissions management process and achieving
compliance within a given period.
If compliance periods are short, dynamic emissions
management would be facilitated if sources and regulators
agree in advance on what remedial actions will be taken if
determined necessary.
If an emissions level standard is adopted, no additional
crediting mechanism is needed to account for reductions due
to conservation or non-emitting energy.
If an emissions rate standard is adopted, some mechanism
will be needed to adjust the rate to credit conservation and
non-emitting energy.
Facilities complying with acid rain control regulations
through reduced-sulfur fuel only, require sampling and
analyses combined with fuel use information or continuous
emissions monitoring (CEM).
For sources using pollution control equipment such as
scrubbers (wet or dry) or fluidized bed combustion, CEM is
the only proven method for providing the type and quantity
of S(>2 emissions information needed for acid deposition
control programs.
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State: Massachusetts — Case Study
Study; h Methodology for Evaluating Acid Rain Control
Strategies —A Massachusetts Case Study
Key Words: Fuel Switching,* Energy Conservation; Planning
Criteria
Purpose;
The purpose of the study was to develop and test a methodology for
evaluating various state emissions reduction strategies. The
methodology uses five evaluation criteria to test each strategy.
The five criteria include: average cost of control (dollars/ton
of S(>2 removed) ; secondary environmental impacts (other air
pollutants, liquid and solids disposal, etc.); legal and
institutional impacts; average cost to utility customers
(dollars/billing period); and fairness. The criteria was then
weighted in accordance with the relative importance of each
criterion as determined by the State of Massachusetts program.
The methodology was then applied to five different strategies
(cost-effective at minimum cost; cost-effective at level of minimum
control; gas substitution; low conservation and alternative energy;
and high conservation and alternative energy) at four levels of
control (26% reduction; 26% reduction maintained through 1995; 35%
reduction; and 35% reduction maintained through 1995). These are
the same strategies and levels of control which were used in the
Massachusetts — Planning study, Development and Testing of
Planning Approach to Acid Deposition Control.
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Results;
The conservation and alternative energy strategies are
superior to the other strategies, while the gas substitution
strategy comparatively performs very poorly.
Ivaluation criteria were chosen both for their interest to
Massachusetts and their ability to be measured in some
manner. The criteria may not be the most appropriate for
every state.
Numerical weighting factors may be applied to selected
criteria to establish rankings between different criteria.
These weighting factors can be changed to suit the interests
of any particular state.
It is difficult to measure certain criteria with a single
parameter. Some criteria like "fairness" are essentially
subjective.
The methodology serves as a useful framework for: (1)
considering the relative merits of various control
strategies through promoting their identification and
discussion of the importance of different evaluation
criteria, and the best means of measuring them; and (2)
demonstrating both the relative merits of different
strategies compared to one another as well as the
performance of each strategy under the varying control
stringencies of the -different scenarios.
A "short-cut" approach to the methodology was tested in
which only two of the five criteria were used. Results
indicated that the approach was not a viable alternative.
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State: Massachusetts — Options
Study; Evaluation of Options for Acid Deposition Control
Program Regulation
Key Words: Rate versus Target; Planning Criteria
Purpose;
The project was developed to assist air program managers in
deciding how to structure acid deposition control regulatory
programs. The project evaluates regulatory options established to
limit sulfur dioxide (SO2) emissions. The following options are
evaluated: emission limitation type (options: emissions cap,
emissions rate, hybrid)j cap maintenance provisions (options:
offsets growth margins, hybrid) ; compliance time (options for type:
never to exceed limitations, block average, rolling average;
options for length: short, long); application of emissions
limitations to sources (options: uniform across-the-board, uniform
by source category, non-uniform by individual source)? and starting
date(s) after which regulations apply (options: status quo until
1995, single interim reduction, annual interim reductions).
The study describes regulatory components, identifies options for
each, and lists advantages and disadvantages. This information is
based on a literature search and discussions with state air program
managers, Massachusetts' acid rain work group, and STAR program
participants. The study then identified four criteria for
evaluating criteria (economic, environmental, administration, and
equity) selected during discussions with Massachusetts' air program
managers. Finally, the study evaluated each option based upon a
literature review and the opinions of a panel of five pollution
control specialists.
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Results;
With respect to emissions limitation, source emissions caps
are favored environmentally. Hybrids — switching regulated
sources from a rate to a cap if they choose alternative
compliance strategies — are also favored environmentally.
There does not seem to be consistent agreement on the
economic, environmental, or administrative attributes of cap
maintenance provisions (i.e., growth margins or offsets).
With respect to compliance time, short averaging times or
never to exceed limitations are favored environmentally.
Never to exceed limitations are also favored
administratively if this would require that few sources be
regulated without emissions trading. Uniform limitation
across-the-board would not be favored economically,
A single interim reduction or annually declining emissions
requirements are favored environmentally. Annual reductions
are least favored economically.
A regulation scenario using hybrid emissions limitations is
favored over scenarios using source emissions rate or cap
limitations exclusively when evaluated using an average of
participants" ratings.
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State; Metropolitan Washington Council of Governments
Study; Estimation of 1985 Area and Mobile Source Emissions of
Sulfur Dioxide and Oxides of Nitrogen in the
Washington. D.C. Metropolitan Area
Key Words: Emissions Inventory? El Methodology Assessment
Purpose;
The purpose of this study was two-fold: (1) to make estimates of
1985 mobile and area source sulfur dioxide and oxides of nitrogen
emissions for the Washington metropolitan region utilizing
traditional and non-traditional methods; and (2) to document the
methods used to assess their utility and practicability for
application to other large metropolitan areas.
The study considered four different approaches and eventually used
three approaches. These include the Workbook/MOBILE 3 approach,
an "Energy Balance/Combustion" Approach, a PEI/DOE "Top Down"
Energy Use/Combustion Approach, and a GCA/NAPAP Program Approach.
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Results;
SUMMARY OF FINDINGS
AREA AND MOBILE SOURCE
ESTIMATED 1985 (TONS/YR.) EMISSIONS OF NOX AND SO2
Workbook
Mobile 3
Mobile
Source:
Other
Area:
NO-
84,767
17,403
SOo
3,544
4,749
Energy PEI/DOE
Balance Combustion
NOX
83,579
23,253
SOo NO
3,998 80,811
7,234 49,402
SO-i
3,026
22,420
Total: 102,170 8,293 106,832 11,232 130,213 25,446
ASSESSMENT OF METHODOLOGIES
EPA/Workbook MWCOG PEI/DOE GCA/
Criteria MOBILE 3 En.Bal. Combust. NAPAP
Comprehensiveness: High High High High
Level of Effort
Required: High Moderate Low Very High
Technical Exper-
tise Required: High Moderate Low Moderate
Data Requirements: Extensive Moderate Low Extensive
Complexity of
Application: High Moderate Low High
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For overall credibility, ease of application and economy of
effort (assuming agency familiarity with the use of the
MOBILE 3 Model), the EPA Workbook/MOBILE 3 modeling approach
is the methodology of choice.
For ease of application, internal consistency, and
flexibility in application to substate areas, the PEI/DOE
Combustion approach is, by far, the easiest to apply.
For transferability to other analytical purposes (e.g.,
local and regional energy consumption analysis) and
transparency of approach, the MWCOG Energy Balance method
provides apparently credible results with moderate levels of
input of staff time and expertise.
Because of the serious deficiency in availability of
documentation, the GCA/NAPAP methodology is by far, the most
difficult approach to apply.
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State; Michigan
Study; Emissions Inventory Verification Procedures
Key Word: Emissions Inventory
Purpose;
Since the early 1970s, Michigan has conducted an annual inventory
for air emissions covering approximately 10,000 stationary sources.
Annual inventory updates are conducted on about 4,000 of these
sources. Approximately 3,000 of these facilities were assessed an
annual surveillance fee. The fee, which was discontinued in 1984,
was based in large part on the annual rate of emissions of various
pollutants. The annual fee ranged from $55 to $16,000 per facility
per year. Because the fee was based upon the inventory information
collected, it was important that the information be accurate. In
addition, it was necessary for the state to develop procedures for
verifying the emissions rates and resolving differences between the
facility owner and the state. This project attempted to document
and describe the procedures that Michigan used to verify emissions
rates and determine whether they could be used by other states.
Results:
Four "key elements are most important in reviewing and verifying
the emissions data.
o Provide the source owner with the current inventory data at
the same time updates or corrections as requested.
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o Any corrections, additions, or changes made by the source
owner should be reviewed by agency personnel familiar with
the source.
o After the inventory data has been collected and emissions
estimates have been made, screening programs should be
utilized to identify those sources with emissions that fall
outside accepted bands or are unusually large. Each source
identified in the screening process should be rechecked.
o Source owners should be given the procedures to follow if
they wish to question or correct data.
It was assumed that the fee system would result in more accurate
emissions estimates. This, however, was not necessarily the case.
While the fee system was instrumental in ensuring that the
regulatory agency and the source owner agreed on the estimated
emissions rates, it did not necessarily improve the accuracy of
those estimates.
The advantage of the emissions inventory being tied to a fee system
is that all input data must be carefully scrutinized. Therefore,
while the fee system does not necessarily guarantee the accuracy
in emissions estimates, it does tend to ensure that there is
agreement on input data, methods of calculation, and verification
of the end results.
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State i Midwest Research Institute
Study; Review of Methodologies for Estimating Control Costs
for Acid Rain Precursors
Key Words; Control Modeling; Planning Criteria
Purpose;
This report summarized the results of a project to review available
methods for estimating the costs of measures to control emissions
of sulfur dioxide from utility burners. The methods that were
reviewed included models, procedures, or other techniques developed
and used in the STAR projects, plus those developed by EPA, the
Electric Power Research Institute, or other prominent organizations
involved in estimating control costs for large utility sources.
Results;
o The study brings together in one document information on
each cost estimating procedure or method.
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State: Missouri
Studies; Cost-Effectiveness Analyses of SC?2 Reduction
Alternatives at 3 Missouri Lead Smelters and Cost-
Effectiveness Analyses of 803 Reduction Alternatives at
13 Selected Missouri Utility Power Plants
Key Words: Fuel Switching? Scrubbers? Planning Criteria; Coal
Cleaning? Industrial Controls? New Technologies
Purpose:
The Missouri studies examined 13 power plants and 3 primary lead
smelters to identify cost-effective sulfur dioxide emissions
reduction strategies. The reports examine the site-specific costs
of S(>2 removal at each facility. One of the objectives of the
study was to identify factors that determine cost-effectiveness.
Another was to develop a standardized method of assessing each
source so that other states may utilize the procedure. The
following strategies were considered: flue gas desulfurization
(scrubbing); fuel switching; fuel blending; coal cleaning; least
emission dispatching? coal gasification; limestone injection; and
fluidized bed combustion. Only scrubbing and coal switching were
studied in detail.
Results;
o Sulfur dioxide emissions in Missouri totaled 1.2 million
tons in 1980. This makes Missouri the fifth largest sulfur
dioxide emitting state in the country.
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Of the power plants studied, the average allowable sulfur dioxide
emissions rate is 6.2 pounds per million BTU. The highest
allowable rate was 12.9 pounds per million BTU.
Over 90% of the sulfur dioxide emissions in Missouri are from
coal-fired power plants, and the 13 plants studied account for
95% of the utility emissions in the state.
The most cost-effective sulfur dioxide emissions strategies for
Missouri utilities are coal switching and forced oxidation wet
limestone fluidized gas desulfurization scrubbing.
Important information to consider in fuel switching is the cost
and characteristics of the coal available, transportation costs,
boiler design, and changes in particulate emissions caused by
changes in sulfur content, especially from electrostatic
precipitors.
Important considerations when examining the feasibility of flue
gas scrubbing at a particular plant are available space, sludge
disposal, coal characteristics, boiler size, and capacity
utilization.
The study applied two pre-selected sulfur dioxide control
techniques (coal switching and wet limestone scrubbing) to the
power plants and then determined on a plant-by-plant basis the
costs, expected emissions reductions, and cost-effectiveness.
Using this procedure, the project indicated that allowable sulfur
dioxide emissions could be reduced at the 13 power plants by
about 82%.
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The most cost-effective strategy for reducing sulfur dioxide
emissions at the lead smelters was increasing the use of the acid
plants already installed at two of the three facilities. This
would result in annual emissions reduction of 17,200 tons per
year.
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State; New Hampshire
Study; Development of a Methodology to Evaluate Costs and
Impacts ofAlternative Acid Rain Control Strategies in
New Hampshire
Key Words; Fuel Switching; Scrubbers; Cost; Planning
Criteria; Rate versus Target; Constraints
Purpose;
In 1985, New Hampshire passed its Acid Rain Control Act of 1985.
The act mandates emission reductions of at least 25% by 1991 from
1979-1982 baseline conditions. The act also requires an additional
25% reduction by 1996 if a national acid rain control program is
enacted. The New Hampshire study evaluated the cost-effectiveness
of six proposed strategies to meet the initial 25% reduction.
Results;
o According to the New Hampshire emissions inventory, the five
largest sources in New Hampshire are power plants owned by
Public Service of New Hampshire (PSNH). These account for
84% of the sulfur dioxide emissions in the state. The next
three largest emitters are the James River paper mills,
which account for 9% of the emissions. The remaining 7% are
caused by 25 other major sources.
o The least-cost solution would be to require fuel switching
at three of the five New Hampshire power plants — Merrimack
(coal-fired), Schiller (coal-fired), and Newington (oil-
fired) . The average cost would be $459 per ton of sulfur
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dioxide removed. Scrubbing would be two to three times more
expensive.
o The next-lowest cost option was to require fuel switching at
all major sources in New Hampshire. This strategy would
cost an average of $473 per ton of sulfur dioxide removed.
o The New Hampshire study also examined the equity concerns of
requiring all the S<>2 emissions to be incurred by Public
Service of New Hampshire. The New Hampshire law exempted
the James River facility from the 25% reduction requirements
because it had already reduced its emissions by 67.70% from
a baseline year. New Hampshire is considering having Public
Service reduce its emissions and having small emitters
reimburse the utility for their "share" of reduction
responsibilities, thus equitably distributing emissions
reduction costs.
The study examined difficulties encountered by applying the state-
wide cap:
o Commitments to NEPOOL foreclosed using facility retirement
or conservation to meet emissions reduction requirements.
o If the state-wide emissions total is near or at the cap,
each time a new emitter wants to enter the state, existing
sources may be forced to reduce emissions further using
expensive controls, or the new source may be prevented from
entering the state.
o Because of its bond rating, Public Service of New Hampshire
could not finance a major capital program like a flue
desulfurization system in the foreseeable future.
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State; New York — Strategy
Study; Evaluation of Sulfur Dioxide Emissions Reduction
Strategies from New York Utilities; A Guide for Other
States
Key Words; Fuel Switching; Scrubbers; Cost? Emissions Control
Modeling
Purpose;
The New York project studied the effects that federally mandated
emissions restrictions could have on the cost and supply of
electricity in the area. A model was used to assess the economic
costs of emissions reductions by New York utility sources of 30%
and 40%. The model was designed to simulate the supply and demand
of electric power in the state on an annual basis and to assess the
effects of different sulfur-in-fuel requirements on the cost of
electricity across the state. Expenses associated with compliance
were translated by the model into the electric rates to consumers.
Emissions reductions were simulated to occur in 1995 with the
reduction calculated from 1985 levels. The model considered three
alternatives to meet the emissions reduction requirements—fuel
switching, installation of flue gas desulfurization systems, and
least emissions dispatch.
Results;
o Five coal-fired facilities were identified as sources where
a 30% reduction could be attained. Use of lower sulfur oil
at a large facility provided the additional reduction
necessary to reach the 40% reduction target.
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The 30% reduction could also be attained by purchasing
electricity outside the state at substantial cost. This
resulted in a 44% increase (constant terms) in the cost to
consumers. The impact on electricity rates from fuel
switching and flue gas desulfurization were considerably
less—between 1.8 and 3.5%.
Between 40% and 45% of New York electricity comes from
sources that produce sulfur dioxide emissions. For states
that have few or no electricity generating sources that
generate emissions (i.e., hydroelectric), the resulting
increased costs will likely be greater.
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State; New York — Emissions Inventory
Study; Procedures for Estimating State-wide Sulfur Dioxide and
Nitrogen Dioxide Air Emissions
Key Words; Emissions Inventory
Purpose;
The purpose of the study was to serve as a guide to other states
in developing fuel consumption data for residential, commercial,
and industrial sources. The State of New York is used as an
example throughout.
Results;
o Once the fuel consumption data has been developed and major
point source fuel has been deleted, it can be used to
estimate area fuel emissions.
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State: North Carolina
Study; Alternative Emissions Offset Programs
Key Words: Emissions Trading; Planning Criteria
Purpose;
The North Carolina project examined three distinct components
needed to develop an acid deposition control program. It developed
an emissions inventory, examined economical conventional approaches
to meeting the requirements of the Stafford bill, and evaluated
alternative offset emissions credit trading strategies to reduce
emissions within the state.
The strategies for alternative offset programs studied included
ones where the state played an active role in creating and
brokering offset credits, and case-by-case programs where the state
played a more passive role. Both state-wide offset trading and
trading limited to regions within the state were examined. Also
considered were strategies allowing offset credit creation by all
sources, by major sources only, and by large sources only (greater
than 1,000 tons of sulfur dioxide per year).
Results;
Achieving the statutory limits established in the Stafford bill
could create economic hardship in North Carolina. The study
determined that a statutory target of 1.5 Ib/MMBtu could put most
of the emissions reduction burden on industrial boilers. The study
also determined that an "accommodative approach" to emissions
reduction must be made to allow for future growth in the state.
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The accommodative approach uses the SIP process to require
reductions from emitting facilities.
o The lowest-cost offset trading program is that which places
the fewest restrictions on the number of sources that are
allowed to participate in the program and creates credits
for trading. Constraints that limit the supply of credits
by the size or location of the unit inhibit the matching of
least-cost credits with the demand posed by new or expanded
industry and drive up costs.
o Programs based on state-brokered trade are generally less
costly than programs based upon case-by-case trading (where
the burden of negotiation costs limits the number of trading
partners available to supply credits).
o The extent of state involvement was greatest for brokered
cases, where the state acts as both buyer and seller of the
offset credits. This function requires the state to
establish an administrative apparatus to perform these
duties.
o Case-by-case offset trading where the state role is limited
to revising permits involves little administrative cost.
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State; Northeast States for Coordinated Air Use Management
Study: Appropriate Emissions Control Techniques for the New
England States
Key Words: Cost? Dispatch; Regional Approaches; Emissions
Control Modeling; Planning Criteria
Purpose:
The purpose of this project was to develop a regional analysis of
air quality emissions control alternatives and to develop tools to
allow the states to conduct specific analyses of promising
conventional and innovative emissions control techniques. A
regional economic emissions control model encompassing all major
sources was developed and tested. The cost control techniques and
strategies were based on the New England states 1982 emissions
inventory.
Results:
The study analyzed nine stationary source control techniques on
the basis of: cost, level of control, cost-effectiveness, level
of confidence, impact on existing facilities, and retrofit
considerations. In addition to stationary source control, the
study examined fuel switching and mobile source controls.
o An emissions cap on sulfur dioxide at 1982 levels in 1995
would be least expensive for the states involved. The
approximate cost is $10 million above the cost of generating
electricity to meet the region's expected 1995 demand.
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Maintaining both sulfur dioxide and nitrogen oxides
emissions at their 1982 levels combined with high growth
(3%) in the demand for electricity was the most expensive
scenario studied, costing $750 million above baseline.
Least emission dispatch presents a number of problems in New
England. These problems include institutional problems in
enforcement and the fact that New England is facing a
potential shortage of electric generating capacity.
Although the model's applicability may be limited to the
Northeast states region, problems could be resolved that
would make it a useful tool for other states and the EPA.
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State ; Northeast States for Coordinated Air Use Management
Study ; Maintaining State Emissions
Key Words: Rate versus Target; Deposition Modeling; Regional
Approaches
Purpose ;
This project included representatives from nine Northeast states
and two EPA Regional Offices and began with the premise that an
emissions reduction standard is likely to be instituted at the
federal level. This project examined the various forms that such
a standard could take, including an accommodative option, offset
option, average emissions rate option, and using deposition
modeling to develop a reduction or maintenance program following
development of the program options. Air agency directors and their
staffs were interviewed about the advantages and disadvantages of
the different strategies.
The study analyzed the various emissions reduction standards from
the perspectives of the participating states. In addition to
responding to the control options, the states addressed emissions
inventory development, maintenance of program options, resource
requirements, interstate trading opportunities, and equity
considerations .
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Results;
The accommodative option requires states to establish (or be
given) and document an increment for emissions growth at
some level set below the state-wide emissions cap, which
provides an available emissions allotment to accommodate
future growth.
The offset option would permit new sources or modifications
to existing sources with no net increase of emissions. The
basic premise is always to require an equivalent offset for
all emissions increases from a source.
No state involved in the study preferred an emissions cap
(in terms of tons per year) as a method of maintaining
emissions because Northeast states felt that the average
emissions rate approach could be implemented and enforced
more easily than the accommodative or offset option.
For states with low annual emissions, use of the average
emissions rate option partially solves constraints to growth
in emissions since this approach does not limit a single
state's total emissions.
With the exception of New York (where deposition modeling
has already been used in response to state legislation), the
states were interested in an approach based upon deposition
modeling but believed that the current state-of-the-art
models could not support such a program on a national or
regional level.
Northeast states expressed little confidence in their
ability to develop a regional program with the exception of
a multi-state, multi-company trading program.
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State: Northeast States for Coordinated Air Use Management
Study; Air Quality and Energy Conservation; Cutting the Cost of
Clean Air
Key Words; Energy Conservation; Public Utility Commissions;
Regional Approaches
Purpose;
The project focused on the relationship between energy conservation and
acid rain control and examined the role that energy conservation can
play in reducing emissions. NESCAUM organized a work group consisting
of staff from state air quality agencies, energy offices, public utility
commissions, representatives from utilities, research organizations, and
public interest groups throughout the country.
Two workshops were held in December 1987 and April 1988 for the work
group to discuss air quality programs and barriers to energy
conservation programs. The workshop participants discussed the major
provisions of federal and state acid rain legislation, recommended
changes to that legislation to encourage energy conservation, developing
and implementing least-cost energy plans, externalities in utility
planning, and managing successful conservation programs.
Results;
o Energy conservation can play an effective and economical role in
reducing emissions.
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In contrast to energy conservation, conventional acid rain
control techniques do not produce as many environmental, socio-
economic, or business benefits. In fact, they add to power
generation costs, do not stabilize demand or supply, and may
create undesirable secondary problems (i.e., scrubber wastes).
Passive programs, such as appliance efficiency standards, can
achieve significant long-term savings in electricity once
marketing to consumers has produced significant turnover in
appliances.
In the Midwest, which has excess generating capacity,
energy conservation may reduce the cost of complying
with acid rain legislation. In contrast, the Northeast
states are facing a tight supply of electricity. This
means that using conservation may result in postponing
new generating capacity, but may not result in
significant emissions reductions.
Public utility commissions are responsible for seeing
that the region's power needs are met. This often
conflicts with reducing emissions. Any departure from
the current mandate of least-cost planning may require
legislation, since consumers would be asked to pay for
benefits which arguably should be paid for by taxpayers.
The economic advantages of conservation become clear
when it is analyzed along with other energy supply
options as a part of least-cost planning.
Increasing dependency on cogeneration could result in a
large number of small emissions sources. Air programs,
therefore, need to plan their programs resources
accordingly.
Conservation is more likely to play an effective role in
an acid rain control program that places an absolute
limit, or cap, on emissions rather than in a program
that measures compliance by emissions rates.
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Better tools and approaches for predicting emissions
reductions resulting from conservation will help
encourage its use as part of an acid rain program.
Conservation programs can be effective if planners
recognize that barriers exist and design programs that
surmount these barriers.
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State: Northeast States for Coordinated Air Use
Management
Study; Education and Communication between the New England
Air Quality Control Divisions and Public Utility
Commission
Key Words; Public Utility Commissions; Dispatch; Regional
Approaches; Planning Criteria
Purpose;
Three workshops, attended by air, energy PUCs, and federal
agencies from seven Northeast states and Wisconsin, were held
to foster communication and cooperation between Northeast air
quality control agencies and public utility commissions.
Communication between these agencies is often minimal, which
limits their ability to cooperate on issues of mutual concern.
Results;
The NESCAUM project provided participants with an understanding
of the interrelationships between acid deposition control and
electricity capacity in the New England states. Some of the
topics discussed in the workshops were:
o Siting of new generating facilities; How can PUC and
air agency application reviewing processes be
accommodated? What criteria should be used when siting
a facility?
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o Energy Supply; What are the constraints on the supply
network? What are the impacts of using load management?
What information is necessary to make decisions?
o Rate-making process; When should front loading of costs
for small generators be encouraged? How will emissions
reductions taken within a service area for benefits
outside the territory be jointly reviewed?
Among the conclusions reached were:
o New England does not have a great deal of flexibility in
using environmental dispatch because of existing supply
constraints.
o State air quality control agencies and public utility
commissions each have their own procedures for reviewing
applications for new facilities. These differences are
based upon the fact that each agency has different goals
in mind when reviewing applications. Agencies must
learn to accommodate both air quality goals and the
demand for power in the region.
o Facilities with an average emissions rate below 1.2
pounds of sulfur dioxide per million BTU should not be
included in developing the average emissions rate.
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State; Ohio
Study; Estimation of the Cost ofReducing Sulfur Dioxide
Emissions in Ohio
Key Words; Scrubbersi Coal Cleaning? Fuel Switching;
Cost? Nox Reductions
Purpose;
The purpose of the Ohio study was to estimate more accurately
the costs associated with reducing sulfur dioxide and nitrogen
oxide emissions from electric utility boilers. Past studies
may have overlooked several factors which led to underestimated
expenses of retrofit technologies. The Ohio study focused on
five of the most representative of Ohio's 31 power plants. The
study examined both commercially available and emerging
emissions technologies.
Results;
o Emissions control costs may be considerably higher than
previous studies have indicated.
o Costs of flue gas desulfurization at the five plants
ranged from $573 per ton of sulfur dioxide removed to
$2,192 per ton.
o Physical coal cleaning was generally found to be more
cost-effective than flue gas desulfurization, but the
amount of sulfur dioxide removal is limited.
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Coal substitution and blending was often found to be the
most cost-effective technique, but no fuel price premium
was assigned to this option. Expected premiums, either
now or in the future, may make this option considerably
less attractive.
Emerging control technologies—which include indirect
spray drying, furnace sorbent injection, natural gas re-
burning, and selective catalytic reduction—were
generally found to be more cost-effective than
commercial technologies. The amount of sulfur dioxide
reduction is, however, generally limited from 40% to
70%.
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State; PEI Associates, Inc.
Study: Issues Associated with the Expanded Use of CEMs for
Potential Acid Rain Emissions Reduction Initiatives
Key Words; Cost; Emissions Rate Limit; Emissions Cap
Purpose;
The use of continuous emission monitors (CEMs) to measure
compliance in an acid rain control program is frequently
mentioned in various legislative approaches to acid rain
control. State air agencies generally have had little or no
experience with continuous emission monitoring to meet either
a total emissions cap or an emissions rate limit. The project
focused on identifying and seeking resolutions to some of the
uncertainties and problems related to expanded use of CEMs for
acid rain control programs.
Results;
o Currently, the U.S. lacks a well-defined national policy
on the use of CEMs for checking compliance and
enforcement. Current policies are not uniform (i.e.,
new and existing sources are subject to different
standards and compliance requirements). This is a sore
point with many sources, and many regard the agencies'
policies as unfair. In addition, many agencies and
sources believe that the current data requirements are
redundant. The EPA needs to formulate a policy that
will reduce data handling without compromising the
quality.
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Much apprehension exists about the accuracy and quality
of data generated by CEM systems. Some recent studies
carried out by the EPA, however, suggest that with
proper care and maintenance, CEM systems give fairly
reliable data. More studies and field surveys of actual
operating CEM Systems may be required to establish the
performance capabilities. The technology has been used
successfully abroad to verify continuous compliance.
Therefore, it is important to establish the quality of
U.S. instruments with those used abroad.
Although high capital and operating cost are valid
concerns, as the technology is further developed, these
costs could come down. In the long run, installing CEM
Systems may 1) reduce every quarter, 2) gain public and
agency good will for the company, 3) help the source to
reduce emissions and to operate the process optimally,
and 4) reduce the paperwork required to establish
compliance.
The way the program is currently envisioned there could
be an increased administrative load for both the air
agency and the emissions source. By using telemetry,
however, the Agency can reduce the frequency at which
the sources have to file emissions reports, which would
reduce the paperwork and the official formalities.
Also, as the program develops, the Agency can use an
approach similar to that used in Germany, where the
amount of data that needs to be handled is considerably
reduced.
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State; Pennsylvania
Study; Pennsylvania STAR Project. Phase I — Data Base
Refinement and Pennsylvania STAR Project,
Phase II — Strategy Development
Key Words: Emissions Inventory; Scrubbers; Cost;
Industrial Controls; Constraints; CEM
Purpose;
The Pennsylvania project consisted of two phases. In the first
stage, various emissions inventories for the state were
compared. The second phase examined how a 50% reduction in
sulfur dioxide emissions from 1985 levels could be achieved in
Pennsylvania.
Results;
o Utilities generate the bulk of total Pennsylvania point
source emissions for both sulfur dioxide (88%) and
oxides of nitrogen (84%). Process emissions contribute
only 5% for each pollutant.
o Total sulfur dioxide emissions in Pennsylvania declined
23% from 1980 to 1985. Oxides of nitrogen emissions
changed little over the same period.
o CEM data for SC>2 was compared to inventory data and EIA
data. Generally, agreement was reasonable except that
for scrubbed units, CEM data was greatly superior.
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o A comparison of emissions by utility operators versus
owners was made showing substantial changes in the
distribution of emissions.
o Applying BACT (scrubbers) by size or least cost appears
to be the most desirable sulfur dioxide allocation
method for the utility sector in Pennsylvania,
o Another option worthy of serious consideration is the
application of a 1,2 Ibs SO2/MMBtu emission limit at the
operator level. Under this scheme, approximately 590
thousand tons of S(>2 would be removed at a cost of $290
million. This plan has a cost-effectiveness of
$490/ton. This is the most equitable plan for all of
the utility operators,
o Dual alkali flue gas desulfurization systems were
considered for uncontrolled industrial coal-fired
boilers emitting over 100 tons per year of sulfur
dioxide. Costs were generally 2-3 times as much per ton
as for utility emissions. This demonstrates the
ineffectiveness of controlling a large number of units,
each having a relatively small reduction potential.
o In Pennsylvania, most large industrial sources have the
potential to reduce emissions by 50% to 90% with FGD
systems. Most emit less than 200 tons per year;
therefore, achieving a reduction of even 30,000
tons/year (2%) would require controlling over 100
sources in six different industries.
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Caution must be used in comparing the costs from this study
with the costs provided in similar studies. Many factors enter
into the determination of the final costs such as the costing
method and the levelization factor and carrying charge rate
used. The main purpose of this project was not to determine
the specific costs of reduction alternatives but rather to
provide a basis for comparison among the alternatives.
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State; South Coast Air Quality Management District
Study; Development of a Photochemical Air Quality Model
with Extensions to Calculate Aerosol Dynamics and
Visibility (September 1987)
Key Word; Deposition Modeling
Purpose;
California's South Coast Air Quality Management District has
developed the Urban Airshed Model (UAM) for use in the Southern
California area. Although the model is normally used to
predict ozone and NO2 formation, it can be extended to predict
PM^o visibility, and dry acid deposition as well. The model
was extended and applied to the Los Angeles area and evaluated
on August 8-9, 1984. Extensive ozone, NC>2, PM^o and visibility
monitoring data were collected.
Results;
o Simulation results for ozone and NC>2 indicate that the
model performs fairly well in the treatment of gas-phase
chemistry.
o Aerosol concentration predictions are reasonable given
the level of effort involved in developing the model and
the paucity of measurements of aerosol concentrations.
The uncertainties in aerosol measurement predictions
imply a less stringent evaluation of model performance
for PM]_Q. The model also gives better predictions of
longer-term average (24-hour) concentration of aerosols
as compared to the shorter-term averages (8-hour).
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Although the model results are encouraging, additional
work is required to fully understand the model's
response to different meteorological and emissions
parameters. In its present form, the model cannot be
used as a regulatory tool.
The extended UAM can be a usable application tool once
further refinements are made. A field measurement
program in the South Coast Air Basin is collecting
meteorological and air quality data needed to further
develop air quality models such as the extended UAM.
The data for further model development will not be
available until 1988.
A major acid rain control program should consider the
interrelationships of various control strategies for
acid formation and other air quality control programs.
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Tennessee
Study; A Study of SC>2 Emissions Reduction for a
Multi-state Utility
Key Words; Cost; Rate versus Target? Planning Criteria?
Fuel Switching; Scrubbers; Regional Approaches
Purpose;
The study examined the effectiveness, cost, and enforceability
of four alternative strategies—a systems cap, a state cap, a
plant cap, and a plant emissions rate limitation—for reducing
sulfur dioxide emissions on the Tennessee Valley Authority
(TVA) power system. A systems cap strategy, which would impose
an upper limit on the number of tons the TVA power system as
a whole could emit, would allow TVA to choose how the cap would
be met. A state cap strategy would impose a limit on sulfur
dioxide emissions that the TVA plants in each state could emit,
while a plant cap strategy would impose a similar upper limit
on each plant. A plant emissions rate limitation strategy
would impose a maximum allowable emissions rate on each TVA
plant, which would not exceed its tons-per-year cap. For each
strategy, TVA analyzed ways to achieve its share of either a
5, 10, or 12 million ton national reduction, assuming that the
entire amount would be achieved by reducing emissions at
utility sources alone.
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Results;
Annual costs for the 5 million ton reduction would range
from $0 to $255 million. The use of low-sulfur coal
would be the predominant control method. TVA's revenue
requirements in 1995 would increase from 0 to 4.5%.
Annual costs for the 10 million ton reduction would
range from $335 million to $940 million. Low-sulfur
coal would be used extensively, but scrubber retrofits
would also be required. Increases in revenue
requirements in 1995 would range from 8.1 to 20.3%.
Annual costs for the 12 million ton reduction would
range from $540 million to $1.23 billion. Extensive
scrubbing would be required. Increases in 1995 revenue
requirements would range from 12.4 to 26.4%.
A plant emissions limitation strategy would result in
much higher compliance costs. The system cap strategy
is the most cost-effective and would reduce costs 50% to
100% more than the plant emissions limitation strategy.
Compared to the air quality that could occur around TVA
plants in 1995 if no acid rain control legislation is
enacted, all of the reduction cases would result in
overall air quality improvement. The more inflexible
strategies would usually result in a greater system-wide
reduction and greater overall air quality improvement.
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Enforcement of emissions reduction under the plant
emissions limitation strategy would rely on the approach
already authorized by Section 110 of the Clean Air Act.
A systems cap strategy poses the additional requirement
of cooperation among states.
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State; Vermont
Study; Sensitivity to Alternative Maintenance Plan
Provisions in a State with Low Emissions
Key Words; Rate versus Target
Purpose;
Vermont is a small, rural state with few large emissions
sources and a low emissions base. The purpose of the Vermont
study was to determine whether such a state could meet
emissions reduction standards under various scenarios of
economic development.
The study consisted of three phases. The first phase involved
reviewing existing inventories, identifying and correcting
deficiencies, and compiling, in compatible form, data on the
180 largest emissions sources in Vermont for the period of 1980
to 1984. The second phase projected a number of possible
future emissions scenarios. The third phase examined whether
the required emissions reductions to demonstrate maintenance
could be achieved in sufficient quantity by Vermont.
The study considered two types of emissions caps. The first
is a total emissions cap where states cannot exceed a specified
level of emissions in terms of tons per year. The second is
an overall emissions rate limit, which would be defined in
terms of the amount of emissions per unit of production (i.e.,
Ibs per MMBtu).
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Results;
The choice of base year'may determine whether or not an
emissions tons target can be achieved.
An emissions rate limit of 1.2 Ibs./MMBtu could be
maintained by Vermont under all development scenarios by
establishing a state-wide 1.0% sulfur-in-fuel
regulation.
Permitting any new, large emissions source would make it
virtually impossible for Vermont to maintain an
emissions tons target.
The development of a regional emissions target would
offer the possibility of interstate emissions offsets
being available from the larger states in the region for
use by the smaller states. Such an offset would be a
small percentage of a large state's total emissions and,
therefore, could be politically feasible.
Generally, it appears that the more sources included in
the emissions target (e.g., all point sources vs. only
large point sources), the less difficult it is for a
small state like Vermont to meet the target.
From Vermont's perspective, it would be inequitable to
impose a maintenance program on low SC>2 emitting states
which would restrict their growth solely because the
state had started from a very low baseline.
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The emissions rate limit in conjunction with regional
emissions targets may be the most equitable approach
from the perspective of small, rural states like Vermont
with few large emissions sources and a low emissions
base.
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State; Western States Acid Rain Project
Study; Final Report on the Western States Acid Rain
(WESTAR) Project
Key Words; Emissions Inventory; Deposition Modeling;
Regional Approaches; Industrial Controls; NOX
Reductions; Cost
Purpose;
The project was a two-phase, multi-task project that
investigated acid rain issues in twelve states.
Results;
o The 1985 NAPAP is probably the best available inventory
of sources in the Western states. It will not, however,
reflect year-to-year variability that is unique to the
West, and in many cases will be inaccurate and probably
will not be available in a timely fashion.
o Important criteria to consider in developing an acid
deposition model for the West are the need to minimize
cost, the complexity of the terrain, and flexibility to
handle visibility and ozone. The models with the
greatest potential of meeting the criteria are
ERT/MESOPUFF-II and SAI/RIVAD.
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None of the sampling efforts planned or underway will
acquire all of the necessary data needed for conducting
receptor modeling in the West. Coordination among the
sponsors is lacking, and most studies do not design
their sampling efforts with receptor modeling in mind.
Two issues that represent potentially significant
roadblocks to implementing an effective acid deposition
program are: (1) the current lack of data and tools to
evaluate source/receptor relationships, define
standards, and identify areas requiring protection from
acid deposition; and (2) the lack of a mechanism to
resolve interstate conflicts successfully.
The most cost-effective controls of sulfur dioxide of
20% or less can be obtained from industrial boilers.
Reductions greater than 20% would require extensive
control of smelters and some electric utility boilers.
The marginal cost of control for the 30% sulfur dioxide
reduction scenario is more than double the marginal cost
of the 20% reduction scenario. The cost-effectiveness
of both sulfur dioxide and oxides of nitrogen controls
diminishes rapidly for reduction targets greater than
20%.
Oxides of nitrogen emissions are best obtained through
further control of utility boilers. Tighter control of
oxides of nitrogen emissions from automobiles is also
economical if region-wide reductions greater than 20%
are required.
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A twelve state regional approach can achieve emissions
reduction targets for sulfur dioxide at significantly
less cost than a state-by-state approach. A regional
approach would require legislation that would establish
regional reduction targets instead of state-specific
targets and would allow interstate emissions trading.
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State; Wisconsin — Tri-State Study
Study; Advanced Utilities Simulation Model
Key Words; Regional Approaches; Fuel Switching; Cost;
Plant Retirement; Emissions Control Modeling;
Life Extension; Emissions Trading
Purpose;
Wisconsin used the Advanced Utilities Simulation Model to
examine how a cost-effective sulfur dioxide emissions reduction
program might be achieved in the state. The study also
considered whether it might be cost-effective to develop a
regional air emissions reduction program (which would also
include Minnesota and Michigan) rather than a state program.
Results;
o A 50% reduction in 1995 in sulfur dioxide emissions
could be achieved in Wisconsin by switching coal power
plants to low-sulfur coals.
o Marginal costs for sulfur dioxide control in Minnesota
and Michigan were less than in Wisconsin for certain
units at the 50% state-wide reduction level.
o Whether early retirement of power plants is an
economically feasible strategy for emissions reduction
depends upon the following: (1) the level of excess
generating capacity on the utility system; (2) whether
the facility is needed to maintain transmission system
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stability; and (3) the cost for alternative emissions
reduction steps at the same facility.
Power plant life extension, which has become more
widespread as the cost of new power plants has risen,
affects emissions reductions in two ways: (1) older,
higher emitting plants may be in service longer than
originally anticipated, which affects forecasts of
future emissions levels; and (2) by including emissions
reduction steps in the course of a life extension
program, it is possible that reduction may be achieved
more inexpensively than if undertaken separately.
Emissions trading or leasing is a viable option for
utility systems with excess generating capacity.
Emissions reduction plans that impose source-specific
limitations, however, preclude environmental dispatch as
a compliance option.
State public utility commissions have a clear role in
overseeing emissions trading made by utilities that they
regulate.
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State; Wisconsin — Public Service Commissions
Study; STAR Report and the Potential Role of Public
Service Commissions in Implementing National Acid
Rain Control Policies
Key Words; Public Utility Commissions? Emissions Trading;
Cost; Energy Conservation; Environmental
Dispatch
Purpose;
The Wisconsin Public Service Commission (PSC) report analyzed
the following means of reducing emissions from utility systems:
energy conservation; least emissions or environmental dispatch;
early plant retirement; bulk power purchases; electric rate
design; and power plant life extension. Potential roles that
could be played by PUCs in implementing and monitoring
interstate emissions reduction agreements are discussed in the
report. Historic interactions between the Wisconsin PSC and
the Wisconsin Department of Natural Resources (DNR) on air
quality matters are reviewed. Finally, the Wisconsin DNR and
PSC jointly sponsored a conference on "The Potential Role of
Public Service Commissions (PSCs) in Implementing National Acid
Rain Control Policies."
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Results:
Depending upon the level of emissions reduction
required, an energy conservation reduction strategy may
substantially lower the cost to consumers of emissions
reductions as well as the overall cost of providing
energy services.
The viability of early power plant retirement will vary
with each specific situation. In general, early
retirement will be more economical for utility systems
with considerable excess generating capacity and a few
older plants with high SC>2 emissions reduction costs.
Bulk power purchases may reasonably be considered as an
emissions reduction measure where other clean-up options
are costly and other utilities have capacity for sale.
The overall impact on emissions of both utilities
should, however, be considered. While the purchasing
utility's emissions will decrease, the seller's will
possibly increase. If regulations vary among companies
or among regions, the impact of using power purchases to
reduce emissions in one area may result in increased
emissions in another. Those responsible for
administering emissions reduction rules will need to
consider possible regional impacts of power sales and
purchases.
The Wisconsin PSC and the Wisconsin DNR have a long
history of cooperation. This relationship has been
formalized in a Cooperative Agreement.
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The Wisconsin DNR had established a 3.2 Ibs. SO2 per
million BTUs of heat input at each power plant. The DNR
allowed utilities to request a variance if compliance
would result in an unreasonable hardship. At DNR's
request, the PSC agreed to take on the responsibility of
advising DNR on the reasonableness of utility hardship
claims. DNR retains the final responsibility for
granting or denying waiver requests.
Wisconsin recently adopted an emissions rate limit to be
in place by 1993. It calls for a corporate-wide
emissions rate (utility by utility) of 1.2 pounds of SC>2
per million BTUs of heat input. This would be averaged
on a corporate basis over all the fossil-fueled plants.
In addition, an overall SC>2 emissions target of 325,000
tons per year was included. This was set as a target
rather than a cap to give utilities additional
flexibility. However, since approaching the target
would lead to legislative and DNR review of the
utilities performance, it is believed that the utilities
would be leery of approaching the target.
Utilities maintain that emissions trading must be
allowed if acid rain control is to be conducted in a
reasonable, cost-effective manner. Agencies, however,
are concerned about the effect that trading would have
on agency resources.
Although it appears that the current trend among policy-
makers is to remove any subsidy provision from acid rain
legislation, the concept is strongly supported by
Illinois, Ohio, and Indiana, all of which would incur
great cost to meet proposed limits.
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Many states and utilities are of the opinion that
reductions should be set in two of more phases to
provide more time to design and implement the means to
achieve mandated emissions reduction. They believe that
clean coal technology cannot be in place on a commercial
scale by 1993.
Information on nitrogen oxide emissions is too
insufficient to include these emissions in acid rain
legislation.
Acid rain legislation will likely define the nature and
extent of communication and coordination between air
pollution control agencies and public utility
commissions.
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State; Wisconsin — Model Program
Study: Model State Acid Rain Control Program
Key Words; Planning Criteria; Emissions Trading; Energy
Conservation; Environmental Dispatch; Cost;
Industrial Controls; Plant Retirement
Purpose;
The goal of Wisconsin's model program was to develop a
management plan that would allow state decision-makers to
quickly implement an emissions reduction program if mandated
by the federal government. Because it is not known what form
such a program might take, five alternative control plans were
developed for electric utilities and three alternative control
plans were prepared for industrial sources. Each plan was
evaluated according to the following criteria: cost and
control methods; secondary environmental impacts; legal
enforceability and compliance requirements; and socio-economic
impacts.
Results;
o Regardless of the reduction level, if the choice of
control techniques is left to the states, then the
opportunity to design cost-effective reduction
strategies maximized.
o The overall cost of meeting sulfur dioxide emissions
reduction requirements could be lessened if emissions
control requirements are integrated within the broader
context of state-wide utility planning.
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Opportunities to lower the overall cost of meeting
state-wide emissions requirements may exist if trading
of emissions sources is allowed.
Conservation has the potential, depending upon the
reduction level, of substantially lowering emissions
reduction costs to consumers as well as lowering the
overall costs of providing energy services.
Environmental dispatch can play a role in reducing the
cost of sulfur dioxide control in a state with excess
capacity. As the reduction requirements become more
stringent, the value of this option lessens.
The disposal of solid waste could become a significant
problem in states where scrubbers are needed to meet the
reduction level.
In general, as an emissions reduction program becomes
more flexible, the legal enforceability and compliance
issues become more complex and time consuming.
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State Acid Rain Program
Results of the State Survey
Appendix B
Office of Air and Radiation
Office of Atmospheric and Indoor Air Programs
Emerging Programs Staff
U.S. Environmental Protection Agency
401M Street, SW
Washington, DC 20460
March 1989
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Results of the State Survey
on the
State Acid Rain Program
On November 8, 1988, STAPPA/ALAPCO mailed fifty-nine surveys to state and
local air agencies and planning organizations to solicit their views on the usefulness of
the STAR Program. As of December 20,1988, a total of thirty-three responded; twenty-
four of these participated in the STAR Program and nine did not. First, the responses
of the non-participating States are summarized briefly; then responses of the partici-
pating States are summarized in more detail.
Non-participating States generally indicated interest in STAR project results but
were almost eveiily divided on the question of whether they wanted to be involved in
future programs of this type. Many of the non-participants cited resource constraints
for "what if planning and indicated that regular Section 105 funding was falling short
on the permanent, high-priority areas. On the question of whether States should
institutionalize on-going strategic planning, respondents were evenly divided. Some
indicated that current resources are inadequate to meet EPA's day-to-day require-
ments and would not permit contingency planning. Some believed such planning to be
a good idea. One indicated that this should be an EPA function. Even non-participating
States were familiar with STAR UPDATE memoranda from EPA and were interested
in the progress of the Program.
The remaining twenty-four respondents participated either directly in the STAR
Program or indirectly through regional projects. Over 90% of the respondents indicated
a desire to be involved in another program like STAR, although several (even some
indicating interest) would be reluctant to participate because of shortage of financial
and staff resources. Several participating States and organizations exceeded initial
estimates of time and cost, and contributed some of their own funding to complete the
projects. Over 70% of respondents indicated that they were able to participate only
because the Section 105 funding mechanism was used. Almost a third of those
responding indicated difficulty participating in activities like STAR due to difficulty in
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accepting "one-time" funding. The choice of Section 105 to fund STAR projects gave
some States the impression that STAR activities were "taking away" from funds that
would have been better spent on "base-line" programs required by the Clean Air Act.
This suggests that EPA might have done a better job emphasizing the supplemental
nature of the special Congressional appropriation.
Three-quarters of the respondents indicated that EPA successfully maintained a
"policy-neutral" posture relative to the need for a control program; but, only 50%
believed that maintaining this posture was useful. Some respondents believed that a
"policy-neutral" position restricts the flow of useful, constructive information to the
Congress, such that proposed legislation cannot incorporate important findings, thus
continuing the risk of "bad" legislation. Additionally, this policy may inhibit State
enthusiasm because studies are undertaken without certainty that they will be useful.
Additional detail on State responses may be found in the closing section of this
summary.
More than half of the respondents maintained an awareness of the STAR Program
through STAR UPDATE memoranda from EPA, participation in national workshops,
through STAPPA/ALAPCO, and through personal contacts with EPA staff and STAR
participants. Responding States were evenly divided in their opinions on the role of the
Regional Offices of EPA: a third believed the Regions played an important and effective
role; a third believed their role was only somewhat important and effective; and a third
believed that the Regional Offices were not important or effective. Only about half of
the respondents indicated that other mechanisms (outside of STAR) were used to
prepare for a potential acid rain control program. Of these mechanisms, States most
frequently used meetings or conferences sponsored by environmental or citizen groups;
followed by an even split between: in-state interagency meetings, State-sponsored
meetings or workshops, Regional Office meetings, industry-sponsored meetings, and
contractor studies initiated by EPA.
Over 60% of respondents indicated that States should consider using a portion of
program resources to institutionalize on-going strategic planning to identify and assess
emerging issues and future program needs. Of the dissenting third, resource con-
straints were cited as a primary reason for not undertaking such an effort. One State
indicated that any contingency planning effort has difficulty demonstrating a cost-
effective expenditure of resources.
In response to the question of the importance placed by the State on the STAR
Program, States indicated that participation in the STAR Program was very important
for examining potential implementation issues, identifying data needed for program
implementation, identifying actual program benefits and costs, and improving inter-
state air pollution control program interactions. The STAR Program was moderately
important for improving the recognition of the diversity of source types, control costs,
impacts, and regulatory processes among the States, and for identifying program
resource needs.
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Details of Response and Summary of State Comments
Responses of participating States are summarized and tabulated in the same
sequence as the original questionnaire. Comments provided by States are included
without attribution. A blank copy of the questionnaire is included at the end of the
tabulation.
Knowledge of STAR Program
How familiar are you with the STAR projects and results? (Please check as
many answers as appropriate).
14 58% I am knowledgeable of my own project.
15 63% I am knowledgeable of projects in my general region.
6 25% I am generally knowledgeable of all STAR projects.
2 8% I am not knowledgeable but want to gain knowledge of the
STAR results.
Based on your present knowledge, wouldyou wanttobe involved if other STAR-
like initiatives were developed by EPA and the States?
22 92% Yes, my state would want to be involved again in other
STAR-like programs.
Comments:
• our state] benefited significantly from participating in the STAR project.
However, the resources devoted to its completion exceeded Section 105
funds allocated for that purpose. Although [we] continue to believe that
such projects are valuable, they also must compete with other more
immediate programs and legal obligations for inadequate resources.
• if time and resources permit.
1 4% Yes, my state was not involved but would want to be in future
programs of this type.
1 4% No, my state would not want to participate in future one time
programs like STAR.
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Comments:
The reason that we would feel reluctant to participate in any future one-
time projects is not a bad reflection on STAR; we simply do not have,
because of funding (and staff) shortage, staff resources which can be
diverted any more for one-time limited-duration projects unless they are
"critical," even if funding is available to theoretically compensate for the
staff resources spent.
Program Management and Funding
How did you maintain an awareness of the STAR program? (Please check as
many answers as appropriate.)
14 58% Through STAPPA/ALAPCO's Acid Rain Committee and general
STAPPA/ALAPCO meetings and newsletters.
15 63% Through participation in either or both STAR workshops.
2 8% Through STAR-TRAK (EPA's computer project tracking system).
17 71% Through STAR UPDATE memorandums from EPA.
6 25% Through my EPA Regional Office.
13 54% Through personal contact with individuals involved in the
STAR projects.
2 8% Through other sources ~ Western States Acid Rain Project
Did the Regional Offices play an important and effective role in this program ?
1 29% XesJIow?
Comments:
• periodic correspondence/communication.
• facilitated in the management of the project and the acquisition of outside
expertise.
• in negotiation of scope of work and project monitoring.
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Region I (not our Regional office) administered the projects in which we
participated and appeared to provide adequate contract/organizational
support.
helpful in review of project products and attended and participated in
meetings.
by assisting with the funding of STAR projects.
7 29% Somewhat. How and why not more?
Comments:
mostly funding.
partially funded project coordinator, little policy lead involvement.
regional office tracked the project but did not review its content.
most important to quickly approve project with minimum realization of
efforts.
served to focus effort within the time schedule, yet allowed flexibility in
our state's STAR project.
8 33% No. Why not?
Comments:
[(comments summarized from lengthy comment) State was originally
enthusiastic about their project. The Region advocated an EPA contractor
that the State did not want to use. State "expended a tremendous amount
of resources" only to be frustrated and delayed by the Regional Office.
Project was cancelled.]
they were not involved in [our] project.
only provided contract oversight; new ground was being broken and EPA
Regional office had no experience.
the WESTAR project was managed by the Western States and not EPA.
little involvement because we did not ask for it.
regional offices did not (usually) attend WESTAR meetings.
not interested.
Region 10 played no role — acid rain low priority.
8% No response.
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In your opinion, did EPA maintain a "policy neutral" posture relative to the
need for an acid rain control program? Please give examples.
18 75% Yes
Comments:
• was willing to fund innovative regulatory reduction plans.
» there was no policy lead involvement from EPA.
• they kept denying that there was any policy implications.
• STAR project discussions rarely if ever addressed appropriateness of a
control program.
• EPA was not involved with our project.
• workshop presentations were "policy neutral."
« open-mindedness and exploration of topics from various perspectives by
David Bassett.
• EPA placed restrictions, however, in the scope of our project (i.e., no
source attribution work).
• but, I think it was generally a waste of time on EPA's part.
• did not preclude analysis of alternatives that would support a given
posture, based on our state project.
EPA staffed WESTAR; meetings were "facts" oriented.
4 17%
Comments:
» there were conflicts between regional offices and headquarters as to what
areas were responsible for the alleged acid rain problems.
• Region 1 felt there should be an acid rain program.
» EPA had at that time no acid rain policy — it was difficult to change their
postures to support efforts.
• they emphasized the need for time to complete NAPAP projects.
2 8% No response
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46941 Understanding implementation time frames.
17% 25% 38% 17% 4%
96711 Identifying actual control program benefits
38% 25% 29% 4% 4% and costs.
94731 Improving interstate air pollution control
38% 17% 29% 12% 4% program interactions.
7 11 5 0 1 Improving the recognition of the diversity of
29% 46% 21% 4% source types, control costs, impacts, and
regulatory processes among the States.
48912 Providing a national focus for the discussion
17% 33% 38% 4% 8% of acid deposition issues and concerns.
1 0 0 4 19 No benefits resulted.
4% 17% 79%
1 0 0 1 22 My state did not participate.
4% 4% 92%
Should States consider using a small part of their program resources to in-
stitutionalize on-going strategic planning to indentify and assess emerging
issues and future program needs? Why or why not?
15 63% Yes
Comments:
• helps reduce crisis management although limited funding makes this
difficult.
• a regional association like WESTAR is needed to discuss issues associated
with regional air pollution.
• long term funding will decrease if States do not stay on the "point" for
emerging issues.
• very important to constantly look ahead; prepare background for new
issues ~ CO2, stratospheric ozone.
• because the agency will need to respond to these issues regardless, it is
better to prepare (plan) ahead of time.
• it is cost-effective to work together, but choose a better project than acid
rain.
• we do this already to keep from being taken by surprise. We cannot
always do something about it, but we are able to prepare as best as
possible.
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10
planning increases the chances of program success.
I consider that part of the role of air quality agencies.
several of the West's most important air quality problems are regional in
scope and must be approached from an interstate basis. Coordination of
other program areas is enhanced.
State acid rain control projects may have a major impact on future
development of the State.
the State programs are on the front lines so to speak. They become aware
of emerging issues which are not sensed on a national level so readily.
This should not preclude national EPA leadership.
it's more efficient to identify potential problems and plan for their
resolution (prevention) than to react after the fact.
Should States consider using a small part of their program resources to in-
stitutionalize on-going strategic planning to indentify and assess emerging
issues and future program needs? why or why not? (Question repeated for
clarity)
8 33% No
Comments:
• it takes all of existing resources to maintain the core programs. There are
no equitable trade-offs that have been identified.
• low priority; controls from existing programs also control acid
precipitation.
• resources are too limited and most issues require focused, national
attention. Periodically, issues such as acid rain may justify this type of
effort.
• insufficient funding available.
• it is already being done. There is no need to make it a grant commitment.
• funds are already spread too thin.
• even though this should be done, the shortage of funding means that even
some "critical" projects are not funded, much less something like this that
is never seen as critical at the moment.
• it is too difficult to keep funds and to show resources are cost effective.
Also, issues/programs change too quickly.
1 4% No response
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11
What other mechanisms outside of the STAR program, have you used for
within-state, multi-state, or state/federal interaction in preparing for a
potential acid rain control program? How useful were they (3 - very useful,
2 - moderately useful, 1 - somewhat useful, 0 - not useful)?
a 2 1 0_ no resp.
57309 Within-State interagency meetings
21% 29% 12% 38%
6 4 1 1 12 State sponsored workshops or meetings with
25% 17% 4% 4% 50% other States.
3 6 3 2 10 Regional EPA sponsored meetings with States.
12% 25% 12% 8% 42%
2 3 4 3 12 EPA originated contractor studies.
8% 12% 17% 12% 50%
2 4 3 2 13 Industry sponsored meetings or conferences.
8% 17% 12% 8% 54%
1 8 1 1 13 Environmental or citizen group sponsored
4% 33% 4% 4% 54% meetings or conferences.
1100 22 Other.
4% 4% 92%
Comments:
interagency analysis of proposed acid rain legislation.
reports from industry and environmental groups.
WESTAR has been the only mechanism. APCA technical papers/journals
have been source of research info, but not control program analysis.
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GENERAL COMMENTS
[our state] was an active participant in the WESTAR group. We found the interaction
with air quality officials from other Western States to be beneficial. EPA needs to
fund additional work on a regional level. WESTAR needs to be continued and to
receive EPA funds to sponsor research and monitoring of importance to the West on
various air quality issues: acid deposition, visibility degradation, and smoke
management.
• The Western States STAR project was very productive in terms of positioning the
West for future policy decisions. However, it does not appear that the findings of the
study will be used for this purpose. EPA needs to give attention to ensuring that the
results of such studies will have more than a shelf life.
• Resources, financial and manpower, were very limited given the magnitude of the
research tasks. Personnel assigned to the STAR project were drawn from non-air
pollution control operations and thus true STAR project costs to the State are
substantially greater than program funding indicates.
There continues to be a deficiency in the formulation of policy options that reflect the
acid deposition reduction requirements to protect sensitive water bodies. Even within
New England it seems each State will be proceeding in its own initiatives. A greater
coordination of efforts will be required in working out a national program.
• In retrospect, programs such as STAR should focus on a more narrow range of issues.
An executive summary with bullet-like information should be distributed to
succinctly identify program's key findings. To justify several million dollars
investment, state and federal policymakers, legislators, and others who may have
impact on language in federal legislation must be provided brief, understandable key
points which can be championed.
• Because the topic was "new" in terms of regulations and there were a number of
different approaches being considered in Congress, the STAR projects considered a
large number of implementation issues. It would be easier to focus on the really
important issues if the number were reduced.
• I believe the WESTAR organization is a valuable forum to solve Western problems,
but I do not perceive acid rain to be a major Western problem. Some problems which
I believe are important center around PMIO and CO SIP development, valley
stagnation modeling, and permit review.
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With as many things going on in air pollution control as there is, [we] have not been
able to justify spending time on evaluating acid rain legislation regarding impacts on
our electric and smelter industry. The STAR study was and is useful to us as it
provides insight into the problems and cost of SO2 control that we would not have
otherwise had.
I hope that when acid rain legislation goes through, the Congress will have realized
the need for funding state and local agency efforts to implement the acid rain bill.
We participated in the WESTAR project. Aside from the acid deposition work of the
group, we found that WESTAR provided an important forum for discussion of
regional issues; development of Western positions on air issues (as a Western
NESCAUM) and exchange of views on a variety of program topics. As you know,
the Western states would like to continue the association to deal with regional haze,
PM -10, ozone, and slash burning.
I hope that EPA will seriously consider other STAR-like project funding in the future.
It has been very useful to us.
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