& EPA
        United States
        Environmental Protection
        Agency
Office of Air Quality
Planning and Standards
Research Triangle Park. NC 27711
EPA-452/S-92-001
June 1992
         HIGHLIGHTS OF THE EPA
        INNOVATIVE REGULATORY
         STRATEGIES WORKSHOP

       MARKET-BASED INCENTIVES
      AND OTHER INNOVATIONS FOR
        AIR POLLUTION CONTROL
                JANUARY 15-17, 1992

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        HIGHLIGHTS OF THE

 EPA INNOVATIVE REGULATORY

     STRATEGIES  WORKSHOP
MARKET-BASED INCENTIVES AND

    OTHER INNOVATIONS FOR

    AIR POLLUTION CONTROL
    Summary of Workshop Discussion Sessions

            January 15-17, 1992
             Washington, DC
    Georgetown University Conference Center
               Sponsored by:

         U.S. Environmental Protection Agency

          Air Quality Management Division
            Office of Air and Radiation      (J 5

                               R*2
                  and            /; l

           ReguJatory Innovations Staff      ^'^ IL 60604-3590 ' ^ Fi°Qf
        Office of Policy, Planning and Evaluation

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This report has been reviewed by the Office of Air Quality Planning and Standards,
U.S. Environmental Protection Agency (EPA),  and has been approved for publication.
Any mention of trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Furthermore, the EPA is not endorsing any
particular program featured in the workshop; the programs included were chosen to
illustrate key issues associated with various innovative strategies.
Questions and comments on the document should be directed to the workshop
chairperson:

                            Conniesue Oldham, Ph.D.
                            Telephone (919) 541-7774
                           Regulatory Strategies Section
                            Ambient Standards Branch
                     Air Quality Management Division (MD-12)
                    Office of Air Quality Planning and Standards
Technical support was provided by the Radian Corporation.
A companion document entitled "Summary of Innovative Regulatory Strategy Programs
Found in the Literature and Popular Press,"  EPA-452/S-92-002, identifies a wide range
of innovative programs being developed or implemented.
                                EPA-452/S-92-001
                                      ii

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                             TABLE OF CONTENTS
Section                                                                       Page

Introduction	   1
Innovative Regulatory Strategies Workshop Agenda  	   3
List of Acronyms  	  7

SESSION I:  Innovative Uses of Taxes and Fees for Stationary and Mobile Sources  ...    8

      Louisiana Environmental Scoring System 	   9
      Feebates	12
      Alternative Fuels:  First Discussion Group  	17
      Alternative Fuels:  Second Discussion Group	20

SESSION II:  Marketable Permits for Stationary, Mobile, and Area Sources	24

      Marketable Permits Market Mechanisms: First Discussion Group	25
      Marketable Permits Market Mechanisms: Second Discussion Group  	29
      Emission Trading Programs:   Enforcement	32
      Marketable Permits: Technical Issues	37
      Locomotive Emissions Trading  	41

SESSION HI:  Other Innovative Strategies for Air-Pollution Control	44

      Media Programs   	45
      Employer-Based Trip Reduction Programs  	47
      Unocal Old Car Buyback Program  	'.	51

SESSION IV:  Dialogue on Issues Leading to Future Research  	54

      Dialogue on Issues Leading to Future Research Agenda  	55

APPENDIX:  PARTICIPANT LIST	'	A-l
                                    iii

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                                  INTRODUCTION

    The Clean Air Act Amendments of 1990 allow, and in some cases require, States to
adopt market-based strategies or other innovative types of air pollution control.  The U.S.
Environmental Protection Agency's (EPA's) innovative regulatory strategies program seeks
to encourage and facilitate, as appropriate, the development, demonstration, and
implementation of a wide range of innovative regulatory air pollution programs, including
market-based, informational, and pollution prevention approaches.
    This 3-day  national workshop, attended by over two hundred people from Federal, State,
and local agencies, industry, environmental and public interest groups, and the academic
community highlighted issues associated with a variety of innovative, market-based strategies
which are currently being developed or used by State and local authorities around the
country.  Documentation of innovative regulatory programs identified but not presented at the
workshop will be available as a separate EPA report.  It should be noted that EPA is not
endorsing any particular program presented at the workshop or addressed in this summary
report, but is providing information that might be helpful to State and local agencies in
designing their  own programs.

OBJECTIVES

    The purpose of the EPA Innovative Regulatory Strategies Workshop was to bring
together and facilitate discussions  among individuals with practical experience or interest in
developing market-based strategies for air pollution control.  The workshop was designed to:
                    Promote the consideration and use of market-based
                    regulatory strategies;
                    Explore design and implementation issues related to
                    strategies such as marketable emission permits, pollution
                    fees, and transportation controls;
                    Facilitate peer exchange of information and ideas on
                    actual programs (either existing or being developed); and

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              •     Identify implementation obstacles and other issues for
                    further research.
    To achieve these objectives, the workshop was divided into three sessions: taxes and
fees, marketable permits, and other innovative regulatory strategies for air pollution control.
As indicated in the final agenda that follows, each session began with a series of case studies
that illustrated key elements of the various strategies and related actual experiences with
innovative regulatory programs.  Summaries of the case  studies are found in the  notebook
distributed at the workshop.
    The case studies presented  in each session were followed by facilitated small group
discussions where issues illustrated by a specific case study were addressed in greater detail.
At least three concurrent small group discussions were held following the case studies in each
session.  This document contains summaries of the issues addressed during each  of those
small group discussions. These summaries report the actual content of the discussions and
do not reflect the EPA's interpretation of the discussions.
    A fourth workshop session was held which consisted of a general discussion, by all
participants, of issues needing further research.  The  results from that session are also
included in this document and will be considered by the  EPA  in the development of a future
research  agenda.

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            INNOVATIVE REGULATORY STRATEGIES WORKSHOP
                                   AGENDA
                        WEDNESDAY, JANUARY 15, 1992

11:00 a.m. - 1:00 p.m. Registration

1:00 p.m.             Welcome and Overview
  Welcome
Barry Korb, Workshop Moderator
Director, Regulatory Innovations Staff
Office of Policy, Planning and Evaluation, U.S. EPA
  Opening Remarks   John Seitz, Director
                     Office of Air Quality Planning and Standards
                     Office of Air and Radiation, U.S. EPA
                            and
                     Maryann Froehlich, Acting Director
                     Office of Policy Analysis
                     Office of Policy, Planning and Evaluation, U.S. EPA
  Overview of
  U. S. Programs
John O'Connor, Senior Program Manager
Radian Corporation
       and
Linda Critchfield
Acid Rain Division
Office of Air and Radiation, U.S.  EPA
  Keynote Address    William Rosenberg, Assistant Administrator
                     Office of Air and Radiation, U.S. EPA
Session I

2:30 - 5:45 p.m.

  Introduction
Innovative Uses of Taxes and Fees for Stationary and Mobile
Sources
Barry Elman
Regulatory Innovations Staff
Office of Policy, Planning and Evaluation, U.S. EPA

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  INNOVATIVE REGULATORY STRATEGIES WORKSHOP AGENDA (Continued)

  Case Studies        Louisiana Environmental Scoring System/
                       Property Tax Exemptions
                     John Glenn
                     Louisiana Department of Environmental Quality
                     Baton Rouge, Louisiana

                     Drive Plus:  Sales Tax/Rebate Based Upon Vehicle Emissions
                       and Fuel Efficiency
                     Deborah Gordon
                     Union of Concerned Scientists
                     Berkeley, California

                     Alternative Fuels Programs
                     Kevin McCarthy
                     Office of Legislative Research
                     Hartford, Connecticut

  Concurrent Small Group Discussions

                         THURSDAY, JANUARY 16, 1992

Session n            Marketable Permits for Stationary, Mobile, and Area Sources
8:15 a.m. - 12:15 p.m.

  Introduction        Karen Martin
                     Office of Air Quality Planning and Standards
                     t)ffice of Air and RadiatiohVU.S. EPA

  Case Studies        South Coast Marketable Permits Program:
                       VOC and NOX Sources
                     Pat Leyden
                     South Coast Air Quality Management District
                     Los Angeles, California

                     Locomotive Emissions Trading
                     Marijke Bekken
                     California Air Resources Board
                     Sacramento, California

                     Wood Stove/Fireplace Marketable Permit Program
                     Nicholas Kirsch
                     Telluride Transit Company
                     Telluride, Colorado

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  INNOVATIVE REGULATORY STRATEGIES WORKSHOP AGENDA (Continued)

  Concurrent Small Group Discussions

Luncheon
12:30 p.m.

  Luncheon Speaker  Richard Morgenstern, Acting Assistant Administrator
                     Office of Policy, Planning and Evaluation, U.S. EPA
Session HI
2:00 - 5:30 p.m.

  Introduction
  Case Studies
Other Innovative Strategies for Air Pollution Control
Conniesue Oldham
Office of Air Quality Planning and Standards
Office of Air and Radiation, U.S. EPA

Free Bus Ride/Voluntary No Drive Day
Ray Bishop
Tulsa City/County Health Department
Tulsa, Oklahoma

Media Programs to Encourage Carpooling
Lynn Sonntag
Disney Productions
Los Angeles, California

Employer-Based Trip Reduction Programs
Sarah Siwek
LA County Transportation Commission
Los Angeles, California

SCRAP (Old Car Buy Back  Program)
Terrence Larson
Unocal
Los Angeles, California
  Concurrent Small Group Discussions

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  INNOVATIVE REGULATORY STRATEGIES WORKSHOP AGENDA (Continued)


                          FRIDAY, JANUARY 17, 1992
Session IV            Dialogue on Issues Leading to Future Research
9:00 a.m. -  12:00 p.m.

      This  session will provide an opportunity for all workshop attendees to:

      •     Share highlights' and synthesize issues  raised during the small group
            discussions
      •     Hear about additional programs identified by individuals in the concurrent
            small group discussions
      •     Participate in the definition of a future research agenda
Closing Remarks

Adjourn
12:00 p.m.
                           WORKSHOP COMMITTEE
Conniesue Oldham, Ph.D.
Workshop Chairperson
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. EPA

Karen Martin, Ph.D.
Regulatory Strategies Section Chief
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. EPA

Barry Elman
Air Innovations Program Manager
Regulatory Innovations Staff
Office of Policy, Planning and Evaluation
U.S. EPA

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                            LIST OF ACRONYMS

AVR         Average Vehicle Ridership
BACT        Best Available Control Technology
CAA         Clean Air Act
CAAA       Clean Air Act Amendments of 1990
CAFE        Corporate Average Fuel Economy
CNG         Compressed Natural Gas
C02         Carbon Dioxide
EPA         U.S. Environmental Protection Agency
HOV         High Occupancy Vehicle
I&M         Inspection and Maintenance
LAER        Lowest Achievable Emission Rate
LEV         Low Emission Vehicle
MACT       Maximum Achievable Control Technology
NESCAUM   Northeast States for Coordinated Air Use Management
NOX         Nitrogen Oxides
NSPS        New Source Performance Standard
NSR         New Source Review
PA YD       Pay As You Drive Auto Insurance
PSD         Prevention of Significant Deterioration
RACT       Reasonably Achievable Control  Technology
RFP         Reasonable Further Progress
ROG         Reactive Organic Gases
SCAQMD    South Coast Air Quality Management District
SIP          State Implementation Plan
SOX         Sulfur Oxides
STAPPA/    State and Territorial Air Pollution Program Administrators/
ALAPCO    Association of Local Air Pollution Control Officials
TCM         Transportation Control Measure
TRI         Toxic Release Inventory
VOC         Volatile Organic Compound
VMT        Vehicle Miles Traveled
                                      7

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              SESSION I








INNOVATIVE USES OF TAXES AND FEES FOR




   STATIONARY AND MOBILE SOURCES

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                                                                               Session I

               LOUISIANA ENVIRONMENTAL SCORING SYSTEM*


INTRODUCTION

Thirty-one individuals participated in this small group discussion.  The group included
persons from Federal and State government, industry, academia, and public interest groups.
Louisiana State government officials and some others in attendance considered the program
successful due to its ability to motivate industry compliance.  Their views are reflected under
the following sections on Louisiana Program Successes and Key Factors Motivating Industry
Compliance.  Some  industry participants, however, strongly opposed particular aspects of the
program, believing that it unfairly burdened corporate facilities. Their views are listed under
the section entitled Industry Concerns about the Louisiana Program.

There was considerable interest in the adaptability of this program to other jurisdictions.
There was general agreement that improvements in the program structure could be made;
however, most participants thought that the Louisiana Program provided a model, or at least
a starting point, for  development of similar programs. Suggestions made by individuals in
the group on ways to improve the program, as well as political and equity issues to be
considered before adopting a program, are also listed below.

HIGHLIGHTS

 •     Louisiana Program Successes

       •       Used  a multimedia approach.

       •       Rewarded improvement in compliance.

       •       Generated 5 million dollars in local revenues.

       •       Reported emission decreases  of 36 million pounds of toxic release inventory
              (TRI) air pollutants and 10 million pounds of criteria pollutants, based on the
              1-year life of this program.

       •       Emphasized pollution prevention rather than end-of-pipe control.

 4     Key Factors Motivating Industry Compliance

       •       Tax exemption privileges could be diminished for a long time.

       •       Score cards were  made publicly available.

       •       Companies engaged in competition to obtain good scores.
    This program was cancelled by the recently elected governing party.

                                          9

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                                                                        Session I

Industry Concerns About the Louisiana Program

•      Regulation was retroactive to 1990.

•      Emissions/employee ratio as a criterion for allocating bonus points was
       questioned.

•      Larger facilities thought they were unfairly burdened.

•      Use of tax structure to achieve environmental goals was viewed as unfair,
       especially since industry pays most of the State's property tax.

Possible Ways to Improve the Program or Similar Programs

•      Use a risk-based approach to award bonus points: weight environmental risks
       of various TRI chemicals.

•      Consider whether a facility is in a nonattainment area.

•      Reduce uncertainties for industry.

•      Phase in the program.

•      Consider implementing a formula to weigh historical environmental progress
       of sources in the scoring system.

•      Implement the program legislatively, not administratively.
                                                                 •
•      Run sample test scores before the regulation is issued to determine the
       effectiveness of the score card.

Policy Considerations

•      What type of approach best encourages environmental progress?

              Carrot (incentive) or stick (disincentive).
              Fixed target or open-ended?  Command-and-control approaches have
              required compliance with specific targets.  Open-ended approaches
              encourage continuous improvement, but are a new concept and create a
              degree of uncertainty for industry.

•      Industry needs regulatory certainty.

•      Potential conflict between agencies geared toward environmental protection
       and those geared toward economic development.
                                    10

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                                                                               Session I

      •      Factors including high toxic emissions, high unemployment, a weak economy,
             and support from the Governor, led to a favorable political climate for
             adopting the program.

      •      Programs implemented administratively, rather than legislatively, may be more
             vulnerable.

•     Equity Issues

      •      Establish regulations that reward good environmental citizens.

      •      Reward previous environmental efforts.

      •      Make fines commensurate with environmental impact.

      •      Evaluate whether tax structure is fair.
                                         11

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                                                                                Session I

                                     FEEBATES

INTRODUCTION

Approximately 70 individuals, representing a cross section of Federal, State, industry, and
environmental organizations attended the group discussion on feebates.  The following
discussion summary reflects the dialogue among individuals in the group.  Ideas are those of
individuals, and were not necessarily agreed upon by the group as a whole.  The group did
not come to a consensus on the effectiveness of the program in reducing emissions. All
comments about Drive Plus refer to the proposed program in California.  Comments about
feebates refer to programs similar to Drive Plus,  but not to a specific program.

HIGHLIGHTS

 •     Drive Plus  and Emissions Reductions

       •     The  goal of Drive Plus is to reduce the sales-weighted average of vehicle
             emissions.  The program is designed to lower the average, not to impose a
             limit.

       •     The  group generally agreed that it  is difficult to determine the effect of Drive
             Plus on emissions reductions of criteria pollutants. Individual perspectives
             follow:

                    Drive Plus is based on the premise that a car's emissions over its useful
                    life are a function of its certified emissions [according to the Federal
                    test procedure (FTP)].  However, cars* do not maintain their initial
                    emission levels due to tampering and poor quality maintenance.  Their
                    rate of deterioration cannot be predicted by the FTP.  Thus, the small
                    improvements in certified emissions that Drive Plus attempts to achieve
                    may not be a significant factor in determining on-road emissions of
                    cars.

                    It is difficult to establish correct prices for automobile emissions
                    without being able to predict deterioration rates.

                    As long as a vehicle has potential to emit (has a tail pipe), its emission
                    level over time is not predictable. Therefore, the only way that Drive
                    Plus could assume a certain level of emissions reductions may be by
                    assigning fees to cars if they have potential to emit and assigning
                    rebates to cars if they do not (i.e., if they are electric or solar vehicles
                    that do not have a tail pipe).
                                          12

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                                                                         Session I

      Although the effect of Drive Plus on criteria pollutant emissions may be
      difficult to determine, the program does encourage people to buy more fuel-
      efficient cars. (FTP measurements of fuel economy provide more accurate
      measures of on-road fuel economy than emissions of criteria pollutants.) In
      addition, Drive Plus provides information to consumers regarding auto
      emissions.  Over time, the program is expected to cause reduced fleet carbon
      dioxide (CC^) emissions, as people buy cars with better fuel economy.
Cost of Drive Plus Program

•      It is difficult to estimate how much money Drive Plus will cost to implement.
       The program can be started with funds from the General Fund.  Such
       programs might also be started with funds from a vanity license plate fund.
       Once implemented, the program could be self-supporting.  Drive Plus program
       administrators may need to periodically adjust Drive Plus credit/surcharge
       schedules to ensure that surcharges cover the credits and program operating
       costs.

•      Surveys indicating how fees and rebates influence vehicle choice have already
       been conducted.  These initial surveys will help Drive Plus program
       administrators set surcharge and credit levels so that Drive Plus revenues just
       offset  Drive Plus credits and program costs.

•      Drive  Plus  may increase the average price of cars because manufacturers
       would have an incentive to build cars with more sophisticated pollution-control
       and fuel-economy technologies.

•      Based on the relative amounts of Drive Plus credits and surcharges for
       particular vehicle models, it is expected that consumers would decide whether
       to alter their preference of vehicles within and among vehicle classes.

•      Surcharges  and credits could be set to reflect the societal cost of vehicle
       emissions.  There is concern as to whether surcharge levels are likely to be
       large enough to affect consumer behavior.  The Drive Plus legislation
       currently being considered in California would impose surcharges roughly as
       large as $1,000 and credits roughly as large as $2,000.  The amount of fee or
       rebate would depend on the estimated vehicle model emissions,  based on
       application  of the FTP to  a few test cars of each model. If people respond to
       the Drive Plus program by buying cars with lower certified carbon monoxide
       (CO), nitrogen oxides (NOX), hydrocarbons (HC), and C02  emissions, the
       zero-point would decrease.  Furthermore,  as the differences among cars
       decrease, the rebates and  credits could decrease.
                                    13

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                                                                              Session I

4     CAFE Standards Versus Feebate Program

      •      Some individuals believed that market-based programs usually work best when
             there are no restrictions on the market. Some economists believed that, in
             theory, it would be better if Drive Plus were not layered on top of Corporate
             Average Fuel Economy (CAFE) Standards.

      •      However, others believed that CAFE Standards should be used to establish a
             floor and feebates used to move above that floor level.  Yet others believed
             that once prices are established, the CAFE Standards  could be removed.

      •      Feebates are also designed to give information to the consumer and to put a
             value on pollution.  Window  decals could  supply information on car emissions
             as well as fuel economy. The CAFE Standards do not require dealers to
             display information on emissions to the consumer.

•     Feebate Programs and Car Size Class

      •      Drive Plus credits and surcharges could be calculated within car-size classes or
             among  all classes.

      •      However, setting Drive Plus credit/surcharges according to car-size class sends
             a mixed message to the public.  A  relatively high-emitting large car may get a
             lower fee than a relatively low-emitting subcompact.

      •      Industry voiced concern that feebates can sway consumers to change their
             preference from one car class to another.

      •      However, Drive Plus is designed to make all types of vehicles manufactured
             more fuel efficient, regardless of their size.

OTHER PROGRAMS

*     Gasoline Tax

      •      Although Feebate programs are designed to improve fuel economy, and
             thereby reduce fuel consumption, a gasoline tax  might be as or more effective.

      •      However, a large tax would be needed to affect consumer behavior. In the
             present political climate, a large gasoline tax is not likely to be adopted.

      •      Some studies show that a gasoline tax would be  10 to 30 percent less
             successful in altering consumer behavior than an initial tax associated with
             vehicle purchase.

      •      Fuel costs constitute 10 to 15 percent of the operating cost of the car.
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                                                                         Session I

•      There is disagreement on whether consumers realize how much money fuel-
       efficient cars save over time through reduced gas consumption.

Inspection and Maintenance (I&M) Programs

•      Nontraditional I&M programs (using remote-sensing technology)  could target
       both old cars and new cars with high emission levels.  These programs could
       provide disincentives to tamper and incentives to better maintain serviceable
       vehicles.

•      New monitoring technology can record emissions of 1,000 cars per hour by
       using a remote sensor and a video snapshot of the license plate.

•      The majority of high-polluting cars flagged by sensors are cars that have
       evidence of tampering.

•      There is disagreement over the effectiveness of remote sensing.

SCRAP™ Programs

•      UnocaTs SCRAP™ program paid people in the Los Angeles basin $700 to junk
       pre-1971 cars in an effort to reduce vehicle pollution.  The results of the
       Unocal program revealed that:

             High emissions are not directly correlated with age, but rather with
             tampering and neglect.
             The total of 1975 cars account for more vehicle emissions than the total
             of cars from any other model year. That this total is a function of the
             average emissions of cars in that model year, the number of vehicles of
             that model year on the road, and the average miles driven by cars in
             that model year.
             The dirtiest 10 percent of the cars  account for over 50 percent of auto
             air emissions.

Registration Fees

•      Registration fees could be used to collect  money to buy old cars.         *

•      Cars could be registered and fees determined according to certified emissions
       level. However, the reliability of certified emissions levels is an issue.

•      Registration fees would affect cars currently on the road, biit not vehicle sales.

Pay As You Drive Auto Insurance (PA YD)

•      The PA YD concept could be used in conjunction with other programs to create
       incentives to encourage drivers to choose  alternate forms of transportation and
       to reduce the number of miles driven.
                                    15

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                                                                               Session I

•    Automobile Safety

      •      Feebates could be used to achieve policy objectives other than fuel efficiency
             and emissions reductions.  They could be used, for example, to encourage
             vehicle safety.

      •      Vehicle safety information is available to consumers in magazine/book stores.
             However, this information is not made readily available to consumers while in
             the car lot looking at a car.

FUTURE DIRECTIONS

4    Complexity versus Simplicity

      •      A combination of programs would seem to resolve the issue of reducing
             emissions levels associated with polluting older cars and new cars.

      •      Some believed that a collection of programs would confuse the consumer and
             that the best program would be the simplest one.

*    Other

      •      Some regulators argued that feebate programs need to focus on criteria
             pollutant emissions reductions.

      •      An overall-question remaining after the discussion was whether the regulatory
             focus should be on new cars or on old cars, and if both, whether the two
             objectives should be accomplished through the same or separate programs.

      •      In addition, programs need to be evaluated to ensure that the consumer is
             aware of a vehicle's emissions and any resulting costs.
                                          16

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                                                                               Session I
                              ALTERNATIVE FUELS:
                                First Discussion Group
INTRODUCTION
The group that attended this discussion appeared to be interested primarily in current
developments concerning alternative fuels.  There were approximately  10 attendees in this
group. Most were from State environmental agencies.  The fuel industry and a foreign auto-
maker were also represented.  The bulleted items below reflect comments expressed by
individuals during the discussion.

HIGHLIGHTS

 •    Resources

      •      The costs of converting and installing alternative fuel stations depend on the
             type of station and fuel used.  For example, quick-fill stations, which operate
             like gas stations, are more expensive to install than slow-fill stations. Slow-fill
             stations, on  the other hand, can refuel vehicles over night, and thus are
             appropriate for fleets.

      •      Fuels to Drive our Future (National Research Council, Commission on
             Engineering and Technical Systems.  Washington, DC:  National Academy
             Press, 1990) is a good assessment of alternative fuels; useful resource for
             evaluating capital costs, but not for evaluating fuel distribution costs.

      •      Organizations, such as the American Gas Association, can provide information
             about the costs and savings of using different alternative fuel options.

 •    Emissions

      •      Two theories on how areas can move out of nonattainment status:

                    Use newer, cleaner cars; and
                    Use cleaner fuel with lower vapor pressures.

      •      Adoption of California's low emission vehicle (LEV) program is not
             necessarily cost effective in all areas.  Some States (e.g., Connecticut) may not
             receive enough emission credits initially to make it a worthwhile venture.

      •      Transferability  of alternative fuels programs is difficult.  Cost effectiveness
             and actual emissions reductions will vary among geographical and socio-
             economic regions.

      •      Need to evaluate alternative fuel choices in regard to specific air pollution
             problems.
                                          17

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                                                                                Session I

      •      Compliance can result not only from converting existing vehicles, but also by
             replacing gasoline vehicles with alternative-fueled vehicles.

      •      Compressed natural gas (CNG) conversion equipment can be transferred
             between cars.

4     Market

      •      Arizona has tried different alternative fuels.  The usefulness and availability of
             fuels in different areas  within the State are determining their market niche.

      •      Conversions are only a bridge strategy until dedicated-fuel vehicles are  more
             accessible.

      •      Some alternative fuel theories assert that all fossil fuels will need to be
             replaced.

      •      Some thought that successful fuels will compete in the marketplace regardless
             of whether incentives are offered.

      •      Others thought that CNG may be the only fuel able to compete in the
             .marketplace without incentives.

OTHER PROGRAMS

      •      Mobil Corporation is in the process of opening a natural gas filling facility in
             Brooklyn, New York.  It will cost $300,000 to install  two pumps.

      •      Oklahoma's alternative fuels program was developed for two reasons.

                    Both environmental and energy groups supported it.
                    The State needed a new market for natural gas  production.

       •      Oklahoma's program began in 1987 and includes several incentives.
             Legislation was proposed in 1989, and the bill passed both houses with no
             votes against it in 1991.  The program includes all alternative fuels and
             requires emissions testing of vehicles. The changes in air quality since the
             program began have not been quantified because the area reached attainment
             before the legislation was passed.

       •      Northeast States for Coordinated Air Use Management (NESCAUM)
             sponsored an alternative fuel road rally this past fall with a route traveling
             through the capitals of the northeastern States.

       •     The Solar/Electric 500 race in Arizona brought people together, thus serving
             as a forum for exchange of ideas.  The race now has corporate sponsors and is
             expected to be held annually.
                                           18

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                                                                                Session I

       •      Arizona also educates the public on tax incentives, which include reductions in
             vehicle tax and registration tax for alternative-fueled vehicles.

       •      In Arizona, solar-powered cars may be successful in off-grid areas where there
             is no access to electricity and no charging capabilities.

       •      The State of New York provides dedicated parking for alternative-fueled
             vehicles.

       •      McDonell Douglas will circulate alternative-fueled vehicles among its
             employees.

       •      Toyota is conducting research on alternative-fueled vehicles in Japan and in the
             U.S., and demonstrating alternative-fueled vehicles in Japan.

FUTURE DIRECTIONS

       •      There was general agreement on the following points:

                 .  The public needs to be educated on safety issues concerning natural
                    gas. Those who have provided this type of education believe that
                    public perception can be changed.
                    Guidelines for the equipment used with alternative fuels are needed.
                    Some equipment does  not bum fuel as cleanly as  expected.
                    Some group members  thought that programs should not endorse any
                    particular fuel, but should remain "fuel-neutral" _to avoid providing
                    incentives for the wrong fuel (one that may not significantly reduce
                    emissions or may not be cost effective in the end).
                    A clearinghouse~for~information exchange on alternative fuels would be
                    helpful.
                    Some thought that money should be allocated directly to alternative
                    fuels programs, rather than to State offices.
                                          19

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                                                                                 Session I
                               ALTERNATIVE FUELS:
                               Second Discussion Group
INTRODUCTION
The second discussion group on alternative fuels consisted of 12 participants - from State
agencies, EPA Regional Offices, industry, and public interest groups. Although there
appeared to be group consensus on the types of issues associated with alternative fuel use
(fuel accessibility, user considerations, compliance, incentives, costs, and regulatory factors),
varying viewpoints on the specifics of these issues were expressed by participants.

HIGHLIGHTS

 •     Fuel Accessibility Issues

       •     Group members generally agreed that an infrastructure is needed  to promote
             the use of alternative fuels.   State representatives in the group cited the
             following issues that need to be addressed when developing an infrastructure:

                    Fuel delivery.
                    Fuel availability and guaranteed vehicle use.  An individual needs to
                    know that fuel is available before making an .investment in a vehicle.
                    Conversely, fuel suppliers  need a guarantee that demand exists before
                    spending money on a fueling station.
                    Emissions from  the total fuel cycle need to be evaluated, including fuel
                    production.
                    Ability to obtain repair parts.
                    Insurance considerations.
                    Parking and driving considerations, e.g., whether alternative-fueled
                    vehicles are allowed in parking garages, car washes, and tunnels.
                    What happens to obsolete  gas stations?
                    Eventually, one  fuel would emerge as the cleanest fuel and the cheapest
                   . to operate. If so, a plan for transition to this "winner" would  be
                    needed.
                    Niche markets (such as  methanol for transit buses) would  probably
                    emerge, influenced by regional characteristics and the availability of
                    different fuel types.
                    Altitude and other regional factors influence carburetor settings and air-
                    to-fuel ratios.  These differences make transporting fuel from one
                    region to  another difficult.
                    The need  for flexibility.
                    Rate structures need to be determined.
                                           20

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                                                                           Session I

       The group members generally agreed that supply and market issues can be
       factors.  Individual group members cited the following issues:

             Long-term supply of alternative fuels.
             Rationale for interfering in  the market includes expenditures, reduction
             of dependence on foreign oil, and diversification of fuel options.
             Criteria for determining which fuels to promote (e.g., climate
             differences, CC>2 issues, region-specific issues).
User Issues
       One State representative noted that the performance criteria that alternative-
       fueled vehicles must meet include acceleration, passing speed, driving range,
       and fuel tank size (e.g., propane tanks are large).

       An industry representative gave two reasons why industry is changing to
       alternative fuels.

              Concern for adequate supply of currently-used fuel.
              A way to reduce their costs.

       A State representative responded by stating that more information is needed
       about performance, including the pros and cons of each available alternative
       fuel. For example, California assumes that natural gas vehicles will be
       cleaner, but New York believes that is not necessarily the case.
Compliance
       It was noted that standards are needed to ensure that garages are retrofitting
       State fleets and individual vehicles correctly. Certified conversion kits,
       enforcement action, or Federal motor vehicle standards are needed.

       The group generally agreed that guidance is needed to monitor compliance.
       Individuals in  the group cited the following possibilities:

              A system approach (e.g., fuel evaporation).
              Monitoring techniques need to be applicable for all fuels and for the
              total fuel cycle.
              Current I&M programs do not accurately measure tailpipe emissions
              from vehicles fueled by CNG, so other monitoring techniques are
              needed for this fuel type.
              A Stedman laser measures emissions and takes a photograph of the
              license plate.
              Tuning up high emitters is probably the cheapest way to reduce
              emissions.
              Innovative Offsets — a bill planned to be introduced in California in
              January 1992.
                                     21

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                                                                         Session I
             Although clean fuel vehicles are exempted from complying with
             transportation control measures (TCM) under the Clean Air Act
             Amendments (CAAA), they still contribute to traffic congestion.
Incentives
•      Most of the group thought that incentives are needed for alternative fuels to be
       selected over current fuels. Individuals suggested the following:

             Emission Feebates.
             Coordination of incentives for alternative fuel use with gasoline
             programs, otherwise States would lose gasoline tax revenues.
             Taxes on imported oil (Japan and Great Britain, where fuel costs are
             four times greater than those in the United States  [ —$5/gallon] are
             increasing fuel efficiency).
             Preferential parking for alternative fuel cars.
             One State representative questioned whether the market would develop
             anyway, citing Kansas as  an example,  where Amoco is selling CNG
             despite  the absence of any incentives.

Costs — The group generally agreed on the following cost issues:

•      User costs include those at the pump, conversion costs, and the costs to own,
       maintain, and operate alternative  fuel vehicles.

•      Societal costs and benefits also should be considered.   Individuals cited the
       following as examples:

             Environmental.
             Fuel supply.
             Political.
             Balance of trade.
             Secondary economic impacts (increased costs of transportation passed
             on to consumers).
             Consumer - (costs of building new alternative fuel stations will increase
             fuel rates).

•      Short- and long-term costs should be considered.

•      One participant noted that current demand for alternative-fueled vehicles in the
       South Coast area (a result of the  rules requiring fleets to have a certain number
       of low-emitting vehicles) is not high enough to cover the automobile
       manufacturers'  production costs.  For this reason, the vehicles needed to meet
       the  regulations will have limited availability until the demand for them
       increases dramatically.
                                    22

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                                                                          Session I

Timing and Regulatory Issues — State representatives were concerned with the
following issues:

•      To get State implementation plan (SIP) credit, a program must provide real,
       quantifiable, and enforceable reductions.  The following concerns were cited:

              Fairness of current rules.
              Transferability.
              Need for criteria for mobile sources; stationary source criteria are not
              appropriate for mobile sources.
              Possibility of mobile source credits being traded to stationary sources.

•      Reevaluation of criteria for obtaining SIP credit for TCM's, including
       alternative fuel use.

•      Flexibility to deal with regional differences.

•      Effect of regulatory issues on market development.

•      Feasibility of large-scale alternative fuel programs to meet the CAAA
       mandates for mobile sources.  Will States be able to meet the approaching SIP
       deadlines?  If not, they will lose highway funds or receive a sanction.
       Alternative-fueled vehicles may not be  available soon enough to be an option
       for meeting mandates.
                                    23

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             SESSION H






      MARKETABLE PERMITS FOR




STATIONARY, MOBILE, AND AREA SOURCES
                 24

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                                                                              Session II

                MARKETABLE PERMITS MARKET MECHANISMS:
                               First Discussion Group

INTRODUCTION

The first market mechanisms discussion group had approximately 30 attendees. There
appeared to be an even distribution of group members from industry and regulatory agencies.
Several group members were from regulatory agencies in foreign countries, including the
Netherlands and Canada.  Information on the California Marketable Permits Program was of
most interest to the group.  Specifically, the attendees were interested in how the program
was being set up to avoid market problems or failure. The  following is a summary of
comments and concerns expressed by individuals in the discussion.  All comments  below that
refer to a specific program are referring to the SCAQMD proposed program, much of which
is still  evolving.

HIGHLIGHTS

 4     Adequate Market/Type of Market

       •     Will limited market activity still produce program benefits?  Most group
             members believed the activity would not be limited, and that not allowing
             credits to be banked for  more than  1 year will force activity. The SCAQMD
             does not consider holding credits an asset.

       •     Under the currently-proposed California Marketable Permits Program, all
             facilities covered under the program must have enough emissions credits to
             cover all emissions including credits for current operations and any increases.

       •     The following is a typical transaction under the currently-proposed program:  a
             plant plans for a major modification, which includes installing a boiler and
             increasing emissions above the significance level. A permit modification
             package is put together and submitted to SCAQMD.  The SCAQMD office
             gives the plant a list of potential sources of credits.  Next, the plant  uses the
             list to call brokers/representatives to find a company willing to sell their
             emissions credits.  If a sale occurs, a contract with terms and conditions would
             be drawn up.  No actual review of trading transactions will be conducted as
             they occur; however, a yearly audit is  expected.  The  SCAQMD will review
             and process permits.  If they are acceptable, the  SCAQMD does not need to
             get involved. The "new" source gets the emissions credits and the "old"
             source removes the credits from its ledger. The process can take from 30
             days to 3 years.

       •     Under the currently-proposed South Coast program, money gained from sale
             of an emission credit is an off-book asset and is not taxable. California is
             working with the Internal Revenue  Service on tax implications.  .
                                          25

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                                                                        Session II

•    Community Banks

•     If community banks are adopted, one possibility would be to require larger
      sources to donate a small percentage of their credits to a community emissions
      credit bank.  Small facilities could apply for credits from the community bank.
      It would be a "welfare bank" for those who could not afford to buy the
      credits, including municipalities.

•     One suggestion was to allow each large source to contribute 1.2 percent of its
      credits into the community bank.

•     The question of who can use the community bank is still to be addressed.

Where Do Credits Come From?

•     Presently, 85 percent of available emissions credits  are expected to come from
      plant shutdowns. There are also opportunities to receive credits from
      retrofitting.

•     Market prices will determine the cost of credits resulting from retrofits.

•     Under the proposed SCAQMD program,  existing sources can install additional
      control to receive tradeable credits.  Allowing this type of credit should
      encourage the development of new technology.

•     Although it is generally believed that the SCAQMD already requires  such high
      levels of control that surplus credits are limited, further reductions and
      regulations  have already been identified.  The SCAQMD constituents — or
      sources located in SCAQMD — generally agreed that stringent baseline
      controls cause the burden to fall on large sources.

•     The SCAQMD may include some restrictions on what qualifies as a shutdown.

Geographical Restrictions/Meeting Reductions Schedule

•     It is anticipated that the SCAQMD program will allow trading across
      geographical areas.  However,  this issue  is not resolved.

•      Industry does not generally expect the SCAQMD program to result in
      companies selling their credits  and moving elsewhere, thus causing a migration
       of jobs out of the area.

•      The SCAQMD plans to develop a monitoring program to flag  when migration
       of emissions may become a problem.
                                    26

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                                                                        Session II

•      California is looking at a 3-year "reconciliation" program for shifts in
       emissions.  Emissions  levels in various geographical areas will be examined
       every 3 years to determine whether regional shifts in emissions have occurred.

•      The percentage annual decline can be increased if the reasonable further
       progress (RFP) requirement is not being met.

•      If .SCAQMD wants to  reduce emissions and stay on schedule for reaching
       attainment status, some argue that they should consider buying emissions
       credits and  retiring them.

Commodities/Overlap

•      The proposed SCAQMD Marketable Permits Program may encourage quick
       use of credits to prevent hoarding.

•      Because traders will probably have only 1 year in which to use their credits
       under the current proposal, a futures market is unlikely.

•      It appeared that the SCAQMD Marketable Permits Program would apply to
       reactive organic gases  (ROG) and nitrogen oxide (NOX), but questions remain
       about the applicability  to air toxics.

•      The Marketable Permits Program may overlap with maximum available control
       technology  (MACT), new source performance standards (NSPS), lowest
       achievable emission reduction (LAER), best available control technology
       (BACT), or other technology-based standards.  It is assumed that those
       facilities subject to technology-based standards will not be participating in the
       Marketable Permits Program to meet these technology standards.  New sources
       and existing sources not subject to the above standards will be able to use the
       trading system under the current proposal.

•      Facilities regulated under the National Emissions Standard for Hazardous Air
       Pollutants (NESHAP)  for hazardous organic pollutants (HON) may be allowed
       to average emissions among emissions sources within a given facility.

Market Failure

•      Due  to industry's ability to develop new technologies, it is unlikely that  the
       market would fail.

•      If baseline emissions (Ibs/unit time) are incorrect, they may be reallocated
       under.the proposed "reconciliation" program.

•      It was generally believed that a market-based program can work, given that a
       sound regulatory approach  and  a workable enforcement program exist.
                                    27

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                                                                           Session II

      •     As an emissions trading program becomes larger in scope and transaction and
            administrative costs become higher, a less than perfect market structure is
            likely to develop.

4    Issue for Comment: One of the main issues facing SCAQMD is the trading of
      agency certificates versus allowance trading.

OTHER PROGRAMS

      •     Canada is considering a market-based NOX trading program for Ontario and
            part of British Columbia.  They are also considering a sulfur oxide (SOX)
            trading program.

      •     Houston, Texas, will start setting up a community bank for modifications or
            new sources.

      •     The Netherlands has a voluntary compliance program and an unsuccessful
            manure trading program.  Futures are traded between dairy farmers and people
            who need fertilizer.  However, transportation costs made this program
            unsuccessful.
                                        23

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                                                                             Session II

                MARKETABLE PERMITS MARKET MECHANISMS:
                              Second Discussion Group

INTRODUCTION

Approximately 35 people attended the second discussion group on marketable permit
mechanisms.  Of these, about half were from State and local agencies.  Industry, Federal,
and service corporation participants  made up the remainder of the group.  While almost
everyone contributed to the session, primary participants in the discussion were  three
economists, a representative of California's South Coast Air Quality Management District,
and a lawyer.                                                                     -

HIGHLIGHTS

 •     Elements Crucial for Program Success

       •     Most participants agreed that the following key elements of a marketable
             permit program are crucial to its success.

                   An emissions cap - preferably one that is well defined and stable over
                   time.
                   Differences in marginal control costs among potential participants —
                   adequate supply and demand.
                   Well-defined property "rights" - term and quantity of permit, and
                   provisions  for banking.
                   An adequate system for information dispersal and transaction
                   recordkeeping.
                   Adequate monitoring, tracking, and enforcement.

       •     There was a general consensus to define the commodity being traded as either
             "the right to emit" or "compliance opportunities."

 •     Uncertainties and Risks

       •     There was much discussion concerning the uncertainties associated with the
             marketable permit program, for both suppliers and consumers.  Continual
             upgrading of program trade rules and emissions caps (which audit and
             monitoring results may show are necessary) may discourage emitters from
             participating.  A risk-averse firm may opt for the perceived certainty of
             investing in BACT rather than  "risk" buying credits in a potentially unstable
             market.
                                         29

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                                                                        Session II

      The group identified the following as potential sources of permit uncertainty
      (i.e., issues that may require program revision as more information becomes
      available):

             Incremental VOC reactivity factors.
             Ambient ozone impacts by location in air shed, time of day, and
             season.
             Monitoring technology.

      It was noted by several participants  that some form of short-term
      grandfathering  of permits may help  to hedge risk. It was also generally agreed
      that the uncertainties and risks noted above are present regardless of whether
      or not a system is a  market-based one.                      ~~

      One major uncertainty associated with a marketable permits system is
      . transaction costs for potential participants.  Several people speculated that an
      incipient program  would only see trades within facilities at first. Inter-
      company  and industry trades will become common only after companies
      become more comfortable with the new permitting system and more familiar
      with their own control costs and opportunities  for further reductions.
Equity Issues
       Equity issues discussed how initial permit allocations are made, burdens to
       new and smaller sources, stationary versus mobile sources, exclusions from
       the program, and potential monopolizing of permits.

             It was generally agreed that initial allocation rations (not quantities)
             should remain constant over time for equitability and market stability.
             No consensus was reached on potential inequities to new and smaller
             sources,  though extending offset options to include mobile sources was
             mentioned.
             Most agreed  that mobile sources should be integrated into a program to
             relieve the stationary source burden, if possible.
             Although most felt that the market would be strong and diversified
             enough to avoid monopoly problems, a few were skeptical.

       It was noted that new sources probably would not be more disadvantaged
       under the SCAQMD Marketable Permits Program than under current New
       Source Review (NSR).
                                    30

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                                                                              Session II

      Market Character and Effects

      •      A few anticipated that the continual decreasing of the emissions cap proposed
             in the SCAQMD program will drive up permit prices, allowing only the
             highest value operations to remain within nonattainment zones. Many others
             noted that this last speculation is highly dependent upon control technology
             innovations.

      •      Most agreed that even after most stationary sources have achieved their
             maximum control levels, the ever-present demand for offset credits by new
             sources may continue to force the development of new technologies to reduce
             emissions.

      •      There was general agreement that a marketable permits program should be a
             free market, open to speculators.  The presence of speculators may help
             distribute information and thus achieve market equilibrium quicker than if the
             market were limited to a set number of participants. Also, most participants
             thought that a short-term (e.g., 2-year) banking limit should help minimize
             hording and other abuses (e.g., monopolizing).

      •      One person noted that the volume of trades alone should not be used to judge
             the success of a program.  Emissions reductions should also be considered.
FUTURE DIRECTIONS

Areas requiring further study were addressed throughout the session on a topic-by-topic
basis. Although there was no formal wrap-up at the session's end, there was general
consensus of the group on future directions.

The group generally believed that there are many uncertainties remaining, but most can only
be resolved by establishing programs and tracking their results.

      •      How successful these programs will be in promoting control innovations is
             unknown.

      •      Administrative, enforcement, and transaction costs are all unknown.  These
             costs must, however, be measured against the command-and-control approach
             costs (e.g., BACT analyses, legal costs, etc.) that are avoided. The costs of
             demonstrating compliance deserve a careful look.

      •      Regulators should watch for the development of environmental "hot spots,"
             adverse impacts on small business dynamics, and the inability of bureaucratic
             systems to change with new and better information.
                                         31

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                                                                              Session 11

               EMISSIONS TRADING PROGRAMS:  ENFORCEMENT

 INTRODUCTION

 A group of about 30 participants discussed enforcement issues.  This was a diverse group -
 including participants from State agencies,  the EPA, environmental groups, industry, and
 special interest groups.  The group agreed  that enforcement will need to be different for a
 market-based regulatory approach. However, the suggestions expressed by individuals varied
 widely.  Not much agreement was reached, but the discussion raised many questions and
 ideas for future research.

 HIGHLIGHTS

 •     The group agreed that there are many differences between Marketable Permits
       and Prescriptive Approaches.  Individuals cited the following specific differences:

       •      Enforcement and compliance for a marketable permits program should differ
              from that of command-and-control type regulations.  Emissions trading
              programs are not self-enforcing.

       •      Since market permits programs can trade credits or allowances, compliance
              needs  to be high enough to enable them  to be traded as commodities.

       •      Enforcement will change from source-by-source compliance measures (e.g.,
              work practice, rate-based, technology standards) to  compliance measures for
	       the entire facility and massive emissions caps.

       •      Because compliance will not be measured directly from concrete and
              observable events, but  will instead be measured after a series of complicated
              accounting events, new opportunities for violation may emerge, which may
              make violations harder to detect. Thus,  increased accountability measures will
              be appropriate.  If no new accountability measures are instituted, the number
              and types of violations will probably tend to increase.  Examples were given
              from lead phasedown.

       •      The market-based approach  needs tighter accountability.  Because parties will
              rely on others' credits for their own compliance,  trading  programs will require
              more confidence in the accuracy of reported emissions.   Better measuring
              methods are also needed.

       •      New requirements needed.

                    Tracking of trading transactions.
                    Feasibility of on-line computer monitoring.
                                          32

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                                                                       Session II

•     Unlike command-and-control approaches, marketable permits programs will
      consider capacity utilization and hours of operation of the facility.  Previous
      command-and-control regulations avoided limiting production.

•     Cost/Benefit analysis should be different. In developing market-based
      programs, the EPA must consider whether the efficiency gains will be greater
      than the administrative cost increases necessitated by increased monitoring.

The group generally agreed that costs would be different under the marketable
permits approach. Individuals cited the following concerns  and questions about
costs:

•     The costs of control may be lower for a market approach rather than for the
      current command-and-control regulatory scheme; however, the cost of
      monitoring  measures may be much larger.

•     How will this increased cost be assessed?

•     Will enforcement costs be financed through emissions fees collected annually?

•     Does a trade constitute a permit amendment?  If so, what is the EPA's cost to
      review  each transaction?

•     Will penalties reduce  incentives for facilities to remain in compliance?

•     New industry will have to purchase emissions credits prior to operation  before
      they can participate in the proposed SCAQMD Marketable Permits Program.
       All offset and NSR requirements will also apply.

There was concern among some about how to deal with criminal enforcement.
Individuals asked the following questions:

•      Do existing criminal statutes apply, or would a criminal element need to
       become part of the code?

•      Would the burden of proof shift to the regulatory agency to defend?

•      Would individuals who knowingly violate SIP requirements be criminally
       prosecuted?

•      How would falsification of records and bogus trades be penalized?

•      Would holder-in-due-course sanctions apply to the buyer or would the seller be
       penalized when falsified or counterfeit emissions credits are traded?

•      Will bulk of enforcement be civil enforcement, as is currently the situation?
                                   33

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                                                                       Session II

The members of the group generally believed that guidance for averaging is
needed.  Individuals expressed the following concerns:

•      Would daily, weekly, or 30-day averaging be required?

•      A daily cap is more stringent, as books need to be cleared each day. If an
       upset occurs, the facility would have to buy additional allowances before
       midnight.

•      With a longer averaging time, more people may be operating closer to their
       emissions cap, as the market will allow them to operate without a margin of
       safety. Will this cause aggregate emissions to increase?

Several group members mentioned the emergency upset provision and questioned
the interface with marketable permits. Specific concerns of individuals included
the following:

•      How will previously exempted malfunctions, upsets, shutdowns, and start-ups
       be treated under emissions caps?

•      Will the EPA give only 80 percent compliance credit?

•      Some thought industry in the SCAQMD seems willing to give up the
       malfunction/upset/shutdown/start-up exemption to get a longer averaging time
       period (monthly).

•      Upsets (accidental, unexpected events) .are counted as violations under the
       CAA  Operating Permits Program, but they can be used as defense  in violation
       of an  enforcement act.

•      If upsets are used as a defense in violation of an enforcement act under the
       proposed South Coast Marketable Permits Program, then the market may not
       work.

•      How should sources on the edge of the attainment/nonattainment areas be
       treated?  California Edison,  which is shifting its demand into an attainment
       area, is one such source.

•      The market needs to be tight so that industries cannot invent "side  games" to
       avoid compliance.

•      Some thought the penalty under emissions trading should equal or exceed the
       market value of the permit plus its time value for the period of  delayed
       compliance.  If not, incentives to violate would be built into the program.
                                   34

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                                                                            Session II

4     Several group members had questions about recordkeeping.

      •      What frequency will be adequate?

      •      What happens if records are not there? Need sanctions for failure to monitor.

      •      How will "reportable quantity" be defined? The larger the quantity, the
             greater the need to adhere to the trading system.

      •      What triggers a violation?

*     Other group members were curious-how the SCAQMD Marketable Permits
      Program would be integrated with current regulatory requirements. They had
      the following specific concerns:

      •      What happens if an individual unit's emissions are in violation of its permit?
             Would mini-emissions caps be used?

      •      How will the SCAQMD Marketable Permits Program be integrated with NSR
             and prevention of significant deterioration (PSD)?

      •      In the California program, current regulations are not being eliminated; rather,
             exemptions can occur through permit  revisions.

•     Some group  members questioned how public participation would be incorporated
      when using the SCAQMD Marketable Permits Program.  They asked:

      •      How will public input be accommodated  every time a trade takes place?

      •      Under Title V, the CAA Operating Permits Program, public participation is
             required for all new permits and permit modifications. This requirement
             means permit issuance will take time.  Will this process be required for all
             marketable permits transactions?

FUTURE DIRECTIONS

Although many unanswered questions were raised during the first part of the group
discussion, at the end, the group generally agreed on specific future directions needed to help
address some of the issues.

       •      Certify nongovernment groups for monitoring.

       •      Publish a schedule of fees for various violations so penalties will be known  in
             advance.
                                         35

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                                                                   Session II

Develop protocols for measuring credits and evaluating emissions reductions.

Work out legal details.

Define what triggers a violation.  Need to achieve near-perfect accountability
for a marketable permits program to work.

Evaluate the legality of netting emissions.

Develop a protocol to show emissions are 5 percent less each year, even if no
trading takes place.

Set up a program; give it time to work to  evaluate its performance.  Make
expectations realistic.

Instill confidence in this new  commodity.  Industry is hesitant to buy emissions
credits because they are not sure the program will work.
                             36

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                                                                               Session II

                  MARKETABLE PERMITS: TECHNICAL ISSUES

INTRODUCTION

Eighteen individuals participated in this small group discussion.  The group was a diverse
cross-section of Federal and State regulators, industry, and other groups. The group
explored a number of technical issues that must be addressed if a marketable permits
program is to be successful. The discussion focused on issues that have emerged in the
development of the SCAQMD Marketable Permits Program.  The issues of applicability,
establishing baseline emissions,  emissions averaging, quantification, design and
implementation, regulatory  considerations, and enforcement are outlined below. The group
considered applicability and baseline emissions to be particularly critical issues to be
resolved.  In addition  to technical issues, the group also discussed political considerations and
adaptability issues impacting program implementation.

HIGHLIGHTS

 •     Applicability

       •     Sources to be included in the SCAQMD program (one of the most important
             considerations).  Comprehensive applicability including all sources is
             desirable, but potentially difficult to administer. There is limited authority to
             regulate area sources, which account for approximately 25 percent of the ROG
             emissions in  the South Coast. Expanding the program's  applicability  to
             include new, mobile, and stationary sources is desirable, but difficult  to
             implement. A larger universe of sources creates a better market for trading,
             but a more limited number is easier to manage.  The universe of sources to be
             included in the program will be restricted by political reality, resources,
             authority, and enforceability.

       •     Size of a program primarily depends on available resources.

 •     Baseline

             Establishing both  facility and SIP (district) baseline emissions is potentially
             problematic and raises the following questions.

                    Will actual or allowable  emissions be used?
                    What baseline will be acceptable for SIP purposes?
                    What recordkeeping systems are needed?
                    How are fugitive emissions accounted for in the baseline?
                                          37

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                                                                        Session II

 Averaging

••      What emissions averaging period will be used-monthly, quarterly, or annual?
       The EPA policy has been to perform daily averaging, but the SCAQMD
       Marketable Permits Program may propose periods ranging from 30 days to
       1 year for emissions averaging.  Annual reductions may be more consistent for
       determining RFP.  On the other hand, long-term averaging may not capture
       varying emissions due to differences in production, and therefore must be
       demonstrated not to have a negative impact on the national ambient air quality
       standards (NAAQS).

 •      Feasible long-term approaches for achieving reductions through a marketable
       permits program include the following:

              Maximum daily emissions caps.
              Production/throughput limitations.
              Declining emissions  caps.

 Quantification

       It was  generally agreed that quantifying emissions is  necessary to establish a
       baseline and to inventory progress.  Reliable, credible quantifications for
       monitoring and enforcement are essential. Simplicity is a key requirement.  If
       a market-based approach succeeds in quantifying total emissions, enforcement
       efforts could be greatly simplified.

 Design and Implementation Issues

 •      The VOC reactivity may need to be considered when designing a program and
       implementing emissions trades.  The SCAQMD plans to track trades and any
       resulting shifts in VOC reactivity.

 •      Interpollutant trading is not allowed, and a one-to-one emissions offset ratio is
       being proposed for the South Coast.  Should interpollutant trading be allowed?
       At what ratio?

 •      Trading across  stationary and mobile sources needs to be addressed.

 Regulatory Considerations

 •      Relationship of a marketable permits program to CAA Air Toxics and NSR
       Programs.

 •      Conformity with CAA and  State regulations, and existing SIP's.
                                    38

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                                                                        Session 11

•      Integration with existing programs.

             Does it preempt or supersede existing programs?
             How does a program relate to the CAA Air Toxics, and Operating
             Permits Programs, as well as to Reasonably Achievable Control
             Technology (RACT) and LAER requirements?

•      Use of economic theory (marketable permits programs) to obtain emissions
       reduction through SIP's.

•      Guidelines needed on the use of prescriptive command-and-controi approaches
       and/or market-based approaches to facilitate RFP and achieve attainment.
       State regulations should not preclude the use of market-based approaches. The
       long-term impacts of a Marketable Permits Program are not known, but some
       participants believed that the Marketable Permits Program would both reduce
       overall costs and force the development of improved technology to
       accommodate  a  decreasing emissions limit.

Enforcement

       How are marketable permits enforced? Costs of penalties need to be directly
       related to severity of emissions.

Political Considerations

•      How to avoid creating disincentives when designing a program.

•      How to build  consensus with political, environmental, legislative, and public
       groups.

•      How to distribute responsibility for emissions equitably across mobile, area,
       and stationary sources.

•      How to change  the perception of a marketable permits programs. Public tends
       to view programs as allowing industry to increase its emissions through
       trading.

Adaptability Issues

•      How big is the problem in other areas and can the marketable permits
       approach be adapted to fit the need? It may only be applicable for
       nonattainment areas.

•      Can a program  be designed for larger geographical areas, including multistate
       areas?  What  is the best balance between program simplicity and a larger
       district or multistate nonattainment area?
                                   39

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                                                                       Session II



•     Have prescriptive command-and-control approaches been exhausted?




•     What sources and emissions should be included?




•     How good is the established permit system and  monitoring approach?




•     How precise does the measurement of emissions need to be?




•     How will marketable permit programs interface with  SEP's?




•     How good is the current emissions inventory?
                                   40

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                                                                              Session II

                       LOCOMOTIVE EMISSIONS TRADING

INTRODUCTION

The group discussion on Locomotive Emissions Trading was attended by approximately 20
individuals, from Federal, State, and industry organizations.  Overall, the discussion did not
focus on locomotive emissions trading, but rather on mobile source emissions trading in
general.  The bulleted points are, in general, the opinion of the individual commenter, and
not necessarily the consensus of the group.

HIGHLIGHTS

 •     Scope Issues

       •     Transportation is composed of two groups:  goods and people. The transport
             of goods must be handled differently from the transport of people.

       •     Locomotive emissions trading should be considered in the broader scheme of
             mobile sources.

       •     Ideas for transporting people include making alternative transportation
             mechanisms cheaper and more convenient, and making automobile companies
             responsible for their fleets.  However, some thought quantifying emissions
             could be a problem  if auto manufacturers are responsible for fleet emissions.
             Lack of maintenance and tampering can" increase vehicle emissions.

       •     Transportation of goods should focus on efficiency of transportation.  Compare
             the efficiency of airplane, truck, and car transport  to train transport.  Consider
             transporting freight  from city to city on trains instead  of trucks.

       •     Breadth of program (global vs. local)  should be considered.  The bigger the
             bubble, the more cost effective,  but the more complex. For example:

                    If we start with  smaller, local programs, we could then see the bigger
                    picture and try to fit the programs together.
                    Starting with the big picture disregards all the unique,  area-specific
                    characteristics of local structures.  The politics far exceed the technical
                    issues.
                                          41

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                                                                         Session 11

Regulatory Issues

•      Adding market incentives on top of command-and-control programs raises
       certain concerns:

             It could be inefficient and more expensive. Industry may not be able to
             afford inefficient pollution control programs.  Industrial plants leave
             areas that are too expensive.
             Many do not fully trust market incentives.  Skepticism keeps regulators
             from leaping towards a market-based program.  Regardless of
             inefficiency, however, adding market-based incentives to command-
             and-control programs will probably be an improvement. Small steps to
             a  market-based program rather than an immediate changeover will be
             necessary.
             Contradiction may exist between requirements of command-and-control
             and market-based programs.  Market-based programs will  require
             associated mechanisms to avoid the constraints associated with the CAA
             (i.e., RACT approval requires 2 years for review; yet, meanwhile,
             trading is occurring).

•      Regulatory uncertainty.  Some people believed there is more regulatory
       uncertainty associated  with command-and-control programs than with market-
       based incentive programs.  Instead of worrying about a new standard being
       created, industry has flexibility to act according to what the market dictates.
       However, others pointed out that regulatory uncertainty also exists with
       market-based incentives, but in different forms. Any regulation has its
       associated uncertainty.

•      Local versus State control.  Even though local agencies would rather control
       their local (basin) programs, the State needs to control mobile source programs
       because they cross local boundaries.

•      Use of mobile source  emissions reductions as offsets for stationary sources: the
       offset program probably should not require exact emissions (i.e.,  estimates will
       have to do).

•      Penalties must be very high for cheaters in order to avoid program misuse.

•      Market strategies for mobile sources may need more latitude than is seen in
       stationary source market programs.

•      One participaQt offered the idea of allowing an offset program within existing .
       TCM's.  Specifically, the participant suggested a consortium of businesses that
       would spend their  TCM monies on an emissions reduction program such as
       electrifying mass transport rather than trying to coerce their employees to
       carpool,  etc.
                                    42

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                                                                         Session II

Geographical Issues

•      Topography changes, geographical differences, location, and timing make
       creating a bubble over mobile sources difficult.

•      Consider putting a bubble over a route instead of over an area (basin).
       However, California needs to put bubbles over a basin to control localized air
       pollution problems.

Equity Issue

       In establishing a locomotive emissions trading program, no advantage should
       be given to those who have not tried  to clean up their emissions in the past.

Safety Issue

       May be conflicting objectives.  For example, adding a car to a train for safety
       purposes might conflict with a goal to reduce emissions.
                                    43

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         SESSION m

OTHER INNOVATIVE STRATEGIES
 FOR AIR POLLUTION CONTROL
            44

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                                                                             Session III

                                MEDIA PROGRAMS

INTRODUCTION

The media programs discussion group attracted approximately 25 participants.  The
participants were primarily from local, State, or Federal agencies, or from special interest
groups.  During the discussion, many different media approaches and socio-behavioral
theories were described. A summary follows of individual comments and ideas mentioned
during this discussion.

HIGHLIGHTS

 •    Socio-Behavioral Issues

      •     Local governments often do not use social or behavioral  methodologies
             appropriately.  Some governments try to take measurements later, without first
             testing for a baseline.  These programs cost money and without adequate
             testing, it is hard to show that they are economically feasible.

      •     Sophisticated methodologies that can quantify the influence of media-based
             programs do exist.

       •     Socio-behavioral models, as well as engineering practices,  should be used to
             comply with the new CAAA.  The EPA should develop  evaluation criteria for
             incentive programs to be considered for SIP credits.

       •     Most people seem to want to participate in  solving air pollution problems.
             Communication to a group of people rather than individuals will have a more
             quantifiable impact.

 ^    Motivation

       •     Alternative strategies for air quality programs were compared to the "No
             Smoking" campaign. People may not be as motivated to carpool as they are to
             stop smoking. Some feel the recycling program, which was introduced  in
             acceptable phases, is a better analogy.  The key to a successful program of any
             kind is offering a convenient substitute.

       •     School children usually make the best subjects.

       •     Transportation in the Los Angeles area is inconvenient.   Most people in
             Southern California do not use shuttles because they are  less convenient than
             driving.  Air quality managers should consider convenience when planning
             programs, because most people will choose the least inconvenient option.
                                         45

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                                                                              Session III

             The cost saved by not operating individual vehicles is critical and should be
             used to evaluate total program costs and benefits.  There should be no wasted
             environmental effort.

             Comfort will motivate more people to use mass transit.  Asking people what
             would motivate them to use mass transit is also helpful.

             What is fair compensation for using mass transit instead of individual vehicles?
             Survey to determine preferences.

             The Walt Disney Company program and other high visibility programs can get
             the message out to many people.
OTHER PROGRAMS

       •     Atlanta has van pooling, which goes to individual homes or pick-up points.
             This program has high administrative costs.

       •     Colorado's Eco-Pass program allows employers to sign up all of their
             employees for bus passes at a cost of $12 per year.  The program began to fill
             the previously empty buses and ridership increased 30 percent.

       •     Riding mass transit  in downtown Pittsburgh is free.  A drawback to this
             program is that people must drive their vehicles into the downtown area to use
             the service.

       *     Dash shuttles in California are convenient.  They also work well when they
             are sufficiently available.  To make them more available,  demand must be
             increased.

       •     Van pooling in the San Francisco area took passengers away from the mass
             transit system  rather than away from their individual cars.

FUTURE DIRECTIONS

       •     Marketing programs require time and money.  Rely on the experience of the
             experts, such as advertising agencies.

       •     Consider long-term approaches.  We are living with past mistakes of strategies
             that caused more problems.  Need  to assess long-term costs.

       •     Share media expense through corporate or interest group sponsorship to raise
             public awareness.
                                          46

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                                                                           Session III

               EMPLOYER-BASED TRIP REDUCTION PROGRAMS

INTRODUCTION

Twenty-eight individuals from various organizations participated in this small group
discussion.  Several programs to reduce single occupancy vehicle travel were highlighted:
SCAQMD, Pima County Association of Governments, Bay Area Economic Forum, State of
Washington, and University of Washington. While some participants believed that employer-
based programs were not the most effective method of reducing emissions, others emphasized
that mandated trip reduction programs are relatively easy to develop, and that they do
encourage other beneficial changes in individual behavior.  Political considerations and
technical issues impacting program implementation were also discussed.

HIGHLIGHTS

4    Additional Information About the SCAQMD Employer Trip Reduction Program

      •     An on-site coordinator is required.  The coordinator usually is someone who
             has other responsibilities and only devotes part of their time to coordinating
             the Trip Reduction Program.  This requirement was controversial.

      •     A staff of 33 is required to review the implementation plans, which usually
             takes 2 to 3 hours per plan.
                                                         • .
      •     Approximately 7500 plans per year are submitted.

      •     With preliminary information, SCAQMD estimates  company costs at $40 to
             $1000 per employee per year.

4    Technical and Program Design Issues of Employer-Based Trip Reduction
      Programs

      •     Employer-based programs have a limited span of control.  They do not reach
             the 70 percent of trips  that do not involve commuting to and from work.

      •     Trained staff should be available when a program is implemented.

      •     Nonsolo driving options should be rewarded proportionately to their ability to
             increase Average Vehicle Ridership (AYR).

      •     Elected, private  sector review boards enhance the credibility and success of the
             travel reduction program.

      •     A guaranteed ride home should be available to anyone using an alternate
             transportation mode; otherwise trip reduction programs may be subject to
             union activity for benefitting some workers and not others.
                                         47

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                                                                       Session III

•     Options to driving a single occupancy vehicle need to be available before a
      travel reduction program is implemented.

•     Employer incentives become an employee benefit in some circumstances and
      thus are taxable.

•     Changes in individual behavior are difficult to achieve and are most likely to
      occur when there is a change in an individual's life, such as moving or
      switching jobs. Rewards also motivate behavior changes.

•     Implementing trip reduction programs is more difficult in areas where there is
      no mass transit system.  Whether a well-developed mass transit system exists
      significantly impacts whether innovative travel reduction programs are
      successful.

•     Gains in trip reductions have been achieved through ridesharing.
      Telecommuting Jias also been effective  in some areas.

•     Determining the baseline against which to measure travel reductions can be
      problematic.  The Metropolitan Planning Office initially set the AVR for the
      Los Angeles area, but the SCAQMD is now building a database on  which to
      base AVR. Census Bureau data and specific employer data were used in
      Seattle.

Political Considerations

•     For programs to be equitable, previous good environmental behavior needs to
      be rewarded.  To use 1992 as a baseline year for AVR would ignore the past
      efforts of employers to  reduce ridership.

•     Authorities are influential in shaping program development.  Developing
      programs that are legislated  are easier than  developing programs that are not,
      but legislated programs may not be the most effective.

•     Some participants believed that employer-based trip reduction programs were
      not the most effective or appropriate approach to reducing air pollution.  There
       is evidence, however, that changes in behavior resulting from employer-based
       programs may be transferable to other decisions that individuals make.

•      Motivating individual and group behavioral changes is difficult, but a key
       factor in achieving program success.

•      Federal laws  taxing emplgyer benefits and allowing collective bargaining can
       impact employer-based  programs.
                                   48

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                                                                              Session III

       •      Impacting mobile source emissions, the largest source of some emissions, is
             difficult. Mobile source emissions result largely from individual behavior, but
             sufficient political and economic factors to encourage reaching the individual
             are not currently available. It is questionable whether employers should be
             accountable for employee behavior outside of the workplace.

       •      Air regulatory standards need to be attainable. For example, SCAQMD would
             have to achieve 60 percent nonsolo ridership by the year 2010 in order  to meet
             CAA requirements. They currently are at 4 percent, and expect
             implementation of a mass transit system  to increase nonsolo ridership to 10
             percent.  -

       •      Collaboration of industry,  labor, transportation planners, and the regulated
             community is essential  for program success.

OTHER PROGRAMS

+     Pima County Association of Governments

       •      The Pima County Association of Governments is the Metropolitan Planning
             Organization (MPO) coordinating  the local ordinance based  Travel Reduction
             Program for the Tucson regional area.  The 1988 local ordinances require that
             employers  with more than 100 full-time equivalent employees at a site to
             participate  in the travel reduction program to increase employee alternate mode
             usage and decrease vehicle'miles traveled in the daily work  commute.

       •      Program began in 1989.  In its third year, the alternate mode usage has
             increased by 20 percent and the weekly vehicle miles traveled have decreased
             by 3 percent.

       •      Local employers use a  combination of approaches to reduce employee
             ridership.  Approximately 180 employers are  involved.

       •      A key feature of the program is an elected task force of employer participants
             that establishes policy and reviews appeals.

       •      Yearly costs to implement the program are estimated to be $13 per employee
             for the corporation and $4.50 per  plan for the government.  Fixed
             administrative costs account for 70 to 80 percent of the expenditures, while
             approximately 25 percent of the costs are variable.
                                          49

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                                                                             Session III

•     Bay Area Economic Forum

             The Bay Area Economic Forum, a partnership of business and government
             leaders, has proposed a market-based approach to reducing traffic congestion
             in the San Francisco area.  Their recommendations include the following.

                    Smog Fees: Charging smog fees based on actual vehicle emission
                    levels, proportional to miles driven.
                    Enhanced Vehicle Inspection Program:  Requiring more frequent
                    vehicle inspections to bring vehicles up to standard.
                    Bridge and Highway Tolls:  Charging new or higher tolls on bridges,
                    new highways, and congested sections of existing highways,
                    particularly at peak periods.
                    Employee Incentives: Instituting travel allowances for employees
                    instead of free parking, as an incentive to use options to driving alone.
                    High Occupancy Vehicle (HOV) Lane Network:  Creating a regional
                    network of HOV lanes.
                    Gas Tax Increase:  Significantly increasing the gasoline tax to finance
                    transportation  improvements and improve options to driving alone.

4     Bay Area Air Quality Management District

      Currently developing a travel reduction plan.

•     State of Washington

      Local ordinances to implement travel reduction programs are required by October
       1992 under Washington State law.  A task force of public and private sector
      representatives met together  to develop the rules, which included  performance
      objectives. The task force actively put pressure on the legislature to develop the
      package, having anticipated the need for travel reduction programs under the CAAA.

f     University of Washington

      The University has increased parking fees to reduce travel in single occupancy
      vehicles.  Parking fee revenues are used to provide additional transit services.  The
      increased parking fees have been politically acceptable because there is an obvious
      benefit (the convenient location of their vehicles) to the individuals who paid the fees.
                                          50

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                                                                            Session III

                    UNOCAL OLD CAR BUYBACK PROGRAM

INTRODUCTION

The group discussion on the Unocal Old Car Buyback Program was attended by
approximately 50 individuals from Federal, State, and industry. The discussion focused on
the logistics of this program, including its strengths and weaknesses.  There was also
discussion on if and how the program might be adopted in different States, given regional
differences.  The group did not come to a consensus as  to the overall effectiveness of this
program for offsetting emissions.

HIGHLIGHTS

4     Clarification by Unocal representatives on the SCRAP™ Program.

       •      Gasoline was drained and sold; fluids, batteries, and tires were removed.
             Exhaust systems  were removed in cars to be recycled to prevent lead
             contamination.

       •      Hydrocarbon emissions at the tailpipe ranged from 2 grams per mile to 87
             grams per mile.

       •      Program seemed  to be best suited for regions with the following characteristics
             (e.g., Southern California, Houston).

                    Moderate climate (no salt on the roads).
                    Wide range of income distribution.
                    High stationary source control costs.

       •      Instead of receiving emission credit for this project, Unocal received a
             compliance extension. In a  separate incident, a  California cogeneration plant
             scrapped 50 cars in response to a court settlement for an emission violation.

       •      The program bought cars that were manufactured before 1971  (California had
             no NOX standard then).

       •      Remaining Questions

                    How might a SCRAP™ program be combined with an I&M program?
                    Maintenance fees could provide an incentive to scrap cars.

                    How many cars were headed to the junk yard anyway? Did this
                    program remove any additional ones?
                                         51

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                                                                       Session III

             Other possible years to choose for the program could have been pre-
             1975, when catalytic converters were added in California.  Catalytic
             converters were required in other parts of the country in 1975 or 1976.

Use of remote sensors as an alternative to the SCRAP™ Program.

•      Remote sensors could be tested under normal driving  conditions at a cost of
       about 50 cents  per test.  Based on this screening, high-emitting cars could be
       scrapped or repaired.  This approach would target high-emitting cars instead of
      just old cars.

•      Concern was expressed that the remote sensors are not completely reliable
       because they measure emissions under uncontrolled conditions.

Concerns about SCRAP™ and similar programs.

•      Vehicles taken  out of circulation might be replaced with imports from
       neighboring States.  The SCRAP™ program could work in Los Angeles, a
       major city, where the mountains and other terrain provide geographical
       isolation. Program might not work in a State such as Tennessee,  which is
       easily accessible by other States.

•      In the SCRAP™ study, cars were considered not to be in  the retirement stage if
       they could be driven and if they were registered.

•      Is this pilot test statistically valid considering the uncertainty surrounding
       whether many  of the cars would have been retired anyway?  A way to find out
       Would be to sign up a certain number of vehicles, scrap a few, and then hold a
       lottery on the remainder.  A longitudinal study on the remainder could be done
       to determine the fate of the remaining cars. Are they taken  to the junkyard?
       How much longer are they driven?

•      Both small-volume and long-term programs can be problematic.  The Unocal
       program, was implemented quickly and only lasted a short time, so people did
       not have time to abuse the program. Long-term programs would  allow people
       to have time to exploit the program.

•      Choice to consider only old cars was questioned.  New cars can have high
       emissions not only due to neglect of maintenance and tampering, but also
       because they are driven more.

•      Did the program actually take any cars off the  road?  First people who
       volunteer would be scrapping their cars anyway.
                                   52

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                                                                        Session III

•      Alternate approach might be to give a coupon to use on the purchase of a new
       car.  However, a coupon approach might be ineffective because it has no
       measurable impact on air quality.  Another possible approach could be to have
       tough standards like they have in Japan, where inspection fees for old cars are
       so expensive that it is difficult to keep cars on the road, especially  tampered
       ones.

•      To use a car buyback program  to gain emission offset credits, the buyback
       program would need to demonstrate how many years a given car had been on
       the road and, thus the displaced vehicle miles traveled (VMT).

•      Car buyback programs may be unsuccessful at reducing VMT.  As older cars
       are scrapped, they are replaced with new cars that result in higher  VMT. On
       the other hand, $700 is not enough to stimulate new car sales in a 1:1 ratio.

Equity Issues

•      A program like SCRAP™ might increase the price of old cars as they become
       more scarce, thus making it more difficult for low income people to purchase
       used cars.  The $700 rebate may not be sufficient to replace the old car.

•      The impacts  of a program like SCRAP™ should be considered along with other
       possible pollution reduction  programs and their effect on low income people
       (e.g., more stringent regulations result in a refinery closing down and people
       losing their jobs).

•      Louisiana representatives believed  a program like SCRAP™ might receive less
       response in their State, as people there depend on old cars for transportation.

•      The age of a car might not be the best basis for inclusion in such programs.
       However, a program based on the car's age is easy  to implement and
       minimizes cheating.

•      The potential for car importation for profit must be  addressed along with other
       "gaming" potential.

•      The I&M requirements for currently operating vehicles might need to be
       increased.  Costs could be minimized by having students in technical schools
       repair cars.
                                   53

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         SESSION IV

    DIALOGUE ON ISSUES
LEADING TO FUTURE RESEARCH
            54

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                                                                             Session IV

       DIALOGUE ON ISSUES LEADING TO FUTURE RESEARCH AGENDA


The following list is a summary of ideas expressed in the general discussion session on issues
leading to future research.  The list is organized only by topic; there is no prioritization of
ideas nor agreement on the feasibility of accomplishment within a meaningful timeframe.

Approximately ninety persons participated in this session.  The discussion was conducted  as a
"brainstorming session." Thus, an attempt has been made to report all ideas expressed on
the "next steps" in the further development of innovative regulatory strategies.

HIGHLIGHTS

>     Taxes and Fees

       •      Need to estimate elasticities of substitution  for inputs and elasticity of demand
             for emissions.

       •      Need to get data and set baseline emissions for taxes.

       •      Evaluate how to implement rulemaking and statutory processes.

       •      Determine how to select the process to establish  the program.

       •      Assess how to value and  monetize environmental externalities. Utility sector
             efforts to evaluate environmental costs and  benefits, as well as regulatory
             impacts, may be useful.

       •      Examine how often to change the structure of, and taxes for, the program.

       •      Are tax revenues politically acceptable?

       •      Would use of a revenue-neutral tax plan be appropriate?

       •      The proper universe of sources to achieve maximum impact needs to be
             determined.

       •      How do taxes impact various segments of the population, especially the poor?

       •      Income tax implications of parking fees should also be identified.

       •      A mechanism linking fees to emission reduction goals is needed.

       •      Better program evaluation, including baseline data and progress over time,  is
             needed.
                                          55

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                                                                         Session IV

•      Fees should support both the infrastructure and the development of services
       that those who pay fees will use.

•      The academic and economic community should be involved in applied
       research.

•      If a good mass transit system  is in place, parking fees can be externalized; the
       amount of fees should reflect  the real value of the parking place.  For
       example, a car in which three people rode should cost less to park than one in
       which one person rode.

•      Establish the relative net levels of classes of pollutants so that proposed rates
       will reflect proportional  changes.

•      The link between land use and transportation needs to be recognized; a land
       use fee may be appropriate.

•      The interface between the CAA, the Transportation Act, and SIP planning
       should be carefully examined. Air quality regulators should be involved; all
       planning should not be done by transportation managers.  The Federal highway
       bill has provisions that may be used to assist in achieving air quality goals, and
       should be utilized.

Marketable Permits

•      The EPA's BACT/LAER Clearinghouse is a useful source of information.

•      Social, behavioral, political, and operational differences between command-
       and-control and market-based approaches need to be considered.

•      A government's  role in establishing market-based programs should be to define
       the market, help start the market, define market success,  and intervene when
       early indications of problems  appear.

•      An analysis of all social costs of a market-based approach, including who is
       bearing the costs, should be conducted to ascertain that no group is unfairly
       impacted.
                    4

•      A  strategy to include mobile and area sources, as well as stationary sources, in
       marketable permits programs  needs to be developed.

•      Research into long-term, market-based approaches is not  viable  at present.

•      It should not be  assumed that command-and-control approaches  have a higher
       probability of success than  market-based approaches.
                                    56

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                                                                        Session IV

•      Establishing appropriate values for credits under the marketable permits
       program is  difficult. -  Credit values must be justifiable.  Marketable permits
       programs should focus on emissions 'that are not regulated.

•      The EPA and the States should work together to solve complex problems in
       order to avoid litigation.  An example would be the implementation of SIP
       demonstration requirements.

•      Command-and-control approaches have  been developed  by engineers and
       lawyers.  Refocusing this entrenched culture to understand the economic
       market-based approaches will require training.  Examining successful market-
       based programs such  as the acid rain program is one approach.  Additional
       pilot studies also need to be developed.

•      Public education regarding market-based approaches is needed.

Other Innovations

•      A mechanism for researchers in the field to share information should be
       established.

•      What features of voluntary programs are successful in motivating change?  Do
       altruism and self-interest motivate change?

•      Transportation-sector expertise and pollution prevention options should be
       utilized.

•      Cradle-to-grave options for mobile sources should be investigated.

•      Reducing single occupancy vehicle travel requires significant behavioral
       changes; complex solutions by  multiple  groups are needed to effect such
       change.

•      Industry needs stability and assurance that voluntary programs will work.

•      Conducting joint workshops with other organizations,  such as State and
       Territorial Air Pollution Program Administrators (STAPPA), may be valuable.
                                    57

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    APPENDIX




PARTICIPANT LIST

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Charles Aarni
Regulatory Agency Liason
Chevron USA Products
P.O. Box 97
El Segundo, CA  90245
(213)615-5285
 Steven Ahearn
 Dept.  of Commerce,  Energy Office
 3800  North Central  Ave.
 Suite 1200
 Phoenix,  AZ  85012
 (602)280-1420
Vince Albanese
Mgr., Marketing & Technology
Nalco Fuel Tech.
P.O. Box 3031
Naperville, IL
(708)983-3254
 Youbert Alkhato
 6192  Cahalan Ave.
 San Jose,  CA  95123
 (408)739-0718
Bob Anderson
Research Manager
American Petroleum Institute
1220 L St.,  NW
Washington,  DC  20005
(202)682-8534
 Glen Anderson
 Senior Economist
 Environmental Defense Fund
 128  E.  Hargett St.
 Raleigh,  NC  27601
 (919)821-7793
John Anderson
Air Quality Engineer
NC Air Quality Section
127 Cardinal Drive Ext.
Wilmington, NC  28405
(919)395-3900
 Edward Apple
~Dir.  of Envir.  Strategies
 S  C Johnson Wax
 1525  Howe  St.,  #105
 Racine,  WI  53403
 (414)631-2761
Jane Armstrong
Sr. Project Manager
U.S. EPA, OMS
2565 Plymouth Road
Ann Arbor, MI  48105
(313)668-4441
 Dale  Aspy
 U.S.  EPA,  Region 4
 Mobile Source Task Force
 345 Courtland St.
 Atlanta,  GA  30365
 (404)347-5014
John Atcheson
Pollution Prevention Division
U.S. EPA, OAR
Waterside Mall
401 M St.,  SW (PM-222B)
Washington, DC  20460
(202)260-4164
 Beth  Auerbach
 Of  Counsel
 Oppenheimer,  Wolff,  & Donnelly
 1020  19th St.,  NW,  Suite 400
 Washington,  DC   20036
 (202)293-5096
                                A-l

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Jim Austin
Ass't. to Senator Owen
NY State Senate
310 Legislative Office Bldg.
Environmental Conserv. Committee
Albany, NY  12247
(518)455-3411
Rick Baker
Environmental Scientist
Radian Corporation
P.O. Box 201088
Austin, TX  78720-1088
(512)454-4797
Steve Bard
Texaco, Inc.
2000 WestChester Ave.
White Plains, NY  10650
Rosie Barrera
Director, Environmental Affairs
Greater Houston Partnership
Government Relations Dept.
1100 Milam, 25th Floor
Houston, TX  77002
(713)658-2430
Adrian Barrera-Roldan
Researcher
Institute Mexicano del Petroleo
Eje Central Lazaro Cardenas #152
Mexico City, 07730 Mexico, D.F.
011-525-567-9246
Dave Bassett
Pollution Prevention Division
U.S. EPA
401 M St., SW   (PM-222B)
Washington, DC  20460
(202)260-2720
Chuck Bausell                        Christl Beck
Asst. Dir. RCED Econ. Analysis Group Mgr., Commodity & Envir. Taxation
U.S. General Accounting Ofc.         Ministry of Treasury & Econ.
Rm. 1826                   	        7 Queens Park Crescent
441 G Street, NW                     Frost Bldg., 5th Floor
Washington, DC  20548                Toronto, Ontario  M7A 1Y7  Canada
(202)376-9725                        (416)327-0234
Catherine Beckley
Legal & Regulatory Counsel
Cosmetic Toiletry Fragrance Assn.
1101 17th St. NW
Suite 300
Washington, DC  20036
(202)331-1770
Marijke Bekken
Assoc. Air Pollution Specialist
Air Resources Board
Off-Road Control Section
9528 Telstar Ave.
El Monte, CA  91731
(818)575-6684
Jeff Bernard
Planning Assoc.
Mobil Oil Corporation
3225 Gallows Road
Fairfax, VA  22037
(703)846-4752
Laura Bishard
Colorado Dept. of Health
Clean Air Colorado
4210 East llth Ave.
Denver, CO  80220
(303)331-8559
                               A-2

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Ray Bishop
Mgr., Air, Waste, & Vector Programs
Tulsa City/County Health Dept.
4616 E. 15th.Street
Tulsa, OK  74112
(918)744-1000
Buzz Breedlove
Senior Consultant
California Senate Off.
1020 N Street
Suite 565
Sacramento, CA  95814
(916)445-1727
of Research
Jack Broadbent
Office of Planning & Rules
South Coast AQMD
21865 E. Copley Drive
PO Box 4939
Diamond Bar, CA  91765-0938
(714)396-3119
Jack Brown
Environmental Health Director
City-County Health Dept.
1900 East 9th St.
Wichita, KS  67214
(316)268-8457
Matthew Brown
Telecom. & Energy
City of New York
75 Park Place
6th Floor
New York, NY  10007
(212)788-6587
Larry Bruneel
The Keystone Center
2033 M St., NW
Suite 900
Washington, DC  20036
(202)223-0030
Cy Buchert                           Madeleine Burns
Dir.,  Policy Analysis & Planning Div. Nissan Research & Development
Dept.  of Environmental Quality       750 17th Street, NW
PO Box 82263                         Suite 902
7290 Bluebonnet Dr.                  Washington, DC  20006
Baton .Rouge, LA  70884-2231          (202)466-5284
(504)765-0735
Jan Bush
Deputy Air Poll. Control Officer
Bay Area Air Quality Mgmt. Dist.
939 Ellis St.
San Francisco, CA  94109
(415)749-4943
Larry Byrum
Dir., Air Monitoring & Analysis  Div
Oklahoma State Dept. of Health
1000 NE 10th St.
MCO201
Oklahoma City, OK  73117-1299
(405)271-5220
Kateri Callahan
Legislative Professional
Van Ness, Feldman & Curtis
1050 Thomas Jefferson St., NW
Washington, DC  20007
(202)298-1800
Juan Carlos Belausteguigo
Professor, Dept. of Economics
World Wildlife Fund
401 Pershing Drive
Silver Springs, MD  20970
(301)585-8147
                                A-3

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Laurel Carlson
Dept. of Envir. Protection
Air Quality Control
1 Winter St., 7th Floor
Boston, MA  02108
(617)292-5630
                                     Cathy Carruthers
                                     Economics Unit Leader
                                     WA State Dept. of Ecology
                                     MS-PV11
                                     Olympia, WA  98504-8711
                                     (206)459-6014
Lisa Carter
Research Assistant
Jack Faucett Associates
4550 Montgomery Ave.
Suite 300 N
Bethesda, MD  20814
(301)961-8800
                                     J. Cale Case
                                     Vice President
                                     Palmer Bellevue Corporation
                                     111 W. Washington St.
                                     Suite 1247
                                     Chicago, IL  60602
                                     (312)807-4848
John Chamber1in
U.S. EPA, OPPE
401 M Street, SW (PM-221)
Washington, DC  20460
(202)260-2762
                                     Yin-Pong _Chang
                                     Environmental Engineer II
                                     N.C. Air Quality Section
                                     919 N. Main Street
                                     PO Box 950
                                     Mooresville, NC  28115
                                     (704)663-1699
                                     David Clarke
                                     Managing Editor
NJ Dept. of Env. Protection & Energy Inside EPA Weekly Report
401 E. State St.                     PO Box 7167
2nd Floor   CN 027                   Ben Franklin Station
         NJ  08625-0027              Washington, DC  20044
                                     (703)892-1011
Sandra Chen
Air Quality Regulatory Devel. Dept.
Trenton, NJ  08625-0027
(609)633-1122
William Cochran
Environmental Engineer II
NC Div. of Envir. Mgmt.
127 Cardinal Drive Ext.
Wilmington, NC  28405
(919)395-3900
                                     Sandra Colt
                                     Program Director
                                     American Lung Association
                                     723 Piedmont Ave., NE
                                     Atlanta, GA  30365-0701
                                     (404)872-9653
David Conr.oy
Chief, Planning & Tech. Evaluation
U.S. EPA, Region 1
JFK Federal Bldg., (APS)
Boston, MA  02203
(617)565-3255
                                     Nancy Cookson
                                     Counsel
                                     Chemical Manufacturers Assn,
                                     2501 M St.,  NW
                                     Washington,  DC  20037
                                     (202)887-1241
                             A-4

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Linda Cooper
Workshop Coordinator
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy»
Research Triangle Park, NC  27709
(919)541-9100
Paul Cooper
Technical Support
Hillsgorough Co. Envir.  Prot.  Comm,
1410 North 21st St.
Tampa, FL  33605
Steven Coppola
Counsel, Legal Dept.
DuPont Company
1007 Market St.
(D-7152)
Wilmington, DE  19898
(302)773-0149
Andres Corona Juarez
Division Estudios Economicos
Institute Mexicano del Petroleo
M-40, L-23, Ila Sec. Ermita Z
Mexico City, 09180 Mexico, D.F.
011-525-368-2313
Linda Critchfield
U.S. EPA, ARD
401 M Street, SW  (ANR-445)
Washington, DC  20460
(202)260-7915
Ted Cromwell
Manager, Air Programs
Chemical Manufacturers Assoc,
2501 M Street, NW
Washington, DC  20037
(202)887-1383
Tony D'Aquila
Environmental Protection Comm.
1410 N. 21st Street
Tampa, FL  33605
(813)272-5530
Rosalie Day
Economist, Air Division
U.S. EPA, Region 5
77 W. Jackson, AT-18J
Chicago, IL  60604
(312)353-632
David DeBruyn
Grants Manager
U.S. EPA, Region 10
1200 Sixth Ave.
Seattle, WA  98101
(206)553-4218
Leland Deck
Economist
U.S. EPA, OAQPS
MD-12
Research Triangle Park, NC
(919)541-5294
27711
Bill Dennison
Dennison & Assoc.
4 Cintilar
Irvine, CA  92720
(714)752-4150
Joe DiLeo
Assoc. Editor, Clean Air Report
Inside Washington Publishers
1225 Jefferson Davis Hwy
Suite 1400
Arlington, VA  22202
(703)892-8516
                               A-5

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Abby Dilley
Vice President
The Keystone Center
2033 M St.,  NW      #900
Washington,  DC  20036
(202)842-0160
                     Jerry Dion
                     Prog. Mgr., Policy & Ping. Energy  Of
                     Arizona Dept. of Commerce
                     3800 North Central Ave.
                     Suite 1200
                     Phoenix, AZ  95012
                     (602)280-1420
James Dodds
Attorney
Texas Air Control Board
12124 Park 35 Circle
Austin, TX  78753
(512)908-1119
                     Ira DomsTcy
                     Mgr.,  Air Quality Planning
                     Arizona Dept. of Envir. Quality
                     2005 N. Central Ave.
                     Phoenix, AZ  85004
                     (602)257-2321
Michael Doonan
U.S. EPA, OPPE
401 M St., SW
Washington, DC
(202)260-6914
20460
Patrick Dorais
California EPA
555 Capitol Mall
Suite 525
Sacramento, CA  95814
(916)322-2858
Dean Drake
Environmental Activities
General Motors
30400 Mound Rd.
Warren, MI  48090-9015
(313)947-1804
                     John Duffe
                     Transportation & Air Quality Planner
                     Dept. of Natural Resources
                     PO Box 7921
                     Madison, WI  53707
                     (608)267-0806
James Ehlmann
Environmental Activities
General Motors,,
30400 Mound Road
Warren, MI  48090-9015
(313)947-1799
                     Harold Elkin
                     Sun Co. of Pennsylvania
                     100 Matsonford Rd.
                     Radnor, PA  19807
                     (215)293-6340
Barry Elman
Air Innovations Program Manager
U.S. EPA, OPPE
401 M Street, SW  (PM-221)
Washington, DC  20460
(202)260-2727
                     Ralph Engel
                     President
                     Chemical Specialties Mfrs.
                     1913 Eye St., NW
                     Washington, DC  20006
                     (202)872-8110
                           Assn.
                               A-6

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Densford Escarpeta
Environmental Engineer
NY State DEC
Division of Air Resources
50 Wolf Rd.
Albany, NY  12233
(518)457-6379
                                     Stephen Farber
                                     Professor
                                     LSU Dept. of Economics
                                     Dept. of Economics, CEBA  Bldg,
                                     LSU
                                     Baton Rouge, LA  70803
                                     (504)388-3791
Scott Farrow
Council on Environmental Quality
Exec. Office of the President
722 Jackson Place, NW
Washington, DC  20503
(202)895-5750
                                     Fereidun Feizol"lahi
                                     Research Division
                                     California Air Resources
                                     P.O. Box 2815
                                     Sacramento, CA  95812
                                     (916)323-1509
                         Board
Larry Feldcamp
Partner
Baker & Botts
910 Louisianna
Houston, TX  77002
(713)229-1573
                                     Denise Fenn
                                     Radian Corporation -
                                     P.O. Box 13000
                                     3200 Chapel Hill Rd./Nelson Hwy.
                                     Research Triangle Park, NC  27709
                                     (919)541-9100
Victor Ferrante
Mechanical Engineer
HUD
451 7th St.
Rm. 6270
Washington,
             SW
            DC  20410
(202)708-0798
Maura Fitzpatrick
Director, Office of Air Policy
NYC Dept. of Env. Protection
59-17 Junction Blvd. llth Floor
Corona, NY  11368
(718)595-4462
Sherry Fontaine
Assistant Workshop Coordinator
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy.
Research Triangle Park, NC  27709
(919)541-9100
                                     Kelly Fortin
                                     Environmental Engineer
                                     U.S. EPA, Region 9
                                     75 Hawthorne St.
                                     A-5-1
                                     San Francisco, CA  94105-3901
                                     (415)744-1259
Stephen Fotis
Attorney
Van Ness, Feldman & Curtis
10-50 Thomas Jefferson St. ,
Suite 700
Washington, DC  20007
(202)298-1800
                           NW
Cathy Fraga
8000 Center Park Dr.
Suite 270
Austin, TX  78754
(512)835-6112
                              A-7

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Diane Franks
Chief, Air Quality Policy & Plnng.
MD Dept. of the Environment
2500 Broening Hwy.
Baltimore, MD  21224
(410)631-3250
Douglas Fratz
Scientific Affairs
Chemical Specialties Mfrs. Assn.
1913 Eye St., NW
Washington, DC  20006
(202)872-8110
Conan Furber
President
CMF Associates
P.O. Box 850
2 E. Mechanic St.
Gardiner, ME  04345
(207)582-4300
Carl Garvey
U.S. EPA, OGC .
401 M Street, SW,  (LE-132L)
Washington, DC  20460
(202)260-7984
Phil Geis
Group Leader
Proctor & Gamble Co.
11520 Reed Hartman Hwy.
Cincinnati, OH  45241-2422
(513)626-4347
Alan Gignoux
SEIA
777 N. Capitol St.
Washington, DC  20037
(202)408-0660
Lee Gill
Policy Directorate
Environmental Canada
10 Wellington St.
Ottawa, Ontario  K1A OH3 Canada
(819)994-5156
Tracy Gionfriddo
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy.
Research Triangle Park, NC  27709
(919)541-9100
John Glenn
Policy & Planning Administrator
Dept. of Environmental Quality
7290 Bluebonnet Drive
P.O. Box 82263
Baton Rouge, LA  70884
(504)765-0720
Haynes Goddard
Economist
U.S. EPA, ORD
RREL
26 M.L. King Drive
Cincinnati, OH  45268
(513)569-7685
Joe Goffman
Environmental Defense Fund
1616 P St., NW
Washington, DC  20036
(202)387-3500
Eun-Sook Goidel
Environmental Protection Specialist
U.S. EPA
401 M Street, SW,  (PM-222B)
Washington, DC  20460
(202)260-3296
                               A-8

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Debbie Gordon
Senior Policy Analyst
Union of Concerned Scientists
Transportation Program
2397 Shattuck Ave., Suite 203
Berkely, CA  94704
(510)843-1872
                  John Gove
                  Principal Air Poll.
                  CT DEP
                  165 Capitol Ave.
                  Hartford, CT  06106
                  (203)566-2690
                    Control  Eng,
Joyce Graf
Science Department
Cosmetic Toiletry Fragrance Assn.
1101 17th St.,  NW
Suite 300
Washington, DC  20036
(202)331-1770
                  Randy Guensler
                  Research Engineer
                  Univ. of California at
                  207 First Street
                  Davis,  CA  95616
                  (916)758-1030
                       Davis
Laurie Gwyn
Southern California Gas Co.
Environment & Safety
PO Box 3249
Los Angeles, CA  90051-1249
(213)244-2580
                  Wayne Hardie
                  Los Alamos Nat'1 Laboratory
                  PO Box 1663
                  MS-B299
                  Los Alamos, NM  87545
                  (505)667-2119
Steve Harper
Project Manager
ICF
9300 Lee Hwy
Fairfax, VA  22031
(703)934-3018
(703)268-2118
David Harrison
Vice President
Nat'l Economic Research Assc., Inc.
One Main St.
Cambridge, MA  02142
(617)621-0336
Janet Hathaway
Senior Attorney
Natural Resources Defense Council
1350 New York Ave. NW
#300
Washington, DC  20005 '
(202)783-7800
                  Lisa Haugen
                  Environmental Proitection Specialist
                  U.S. EPA,  Region 7
                  726 Minnesota Ave.
                  Kansas City,  Ks  66101
                  (913)551-7877
Seth Heminway
U.S. EPA, OAQPS
401 M St., SW  (EN-341-W), SSCD
Washington, DC  -20460
(703)308-8711
                  Laura Herbert
                  Environmental Engineer
                  NC Dept.  of Environmental Mgmt.
                  Interchange Bldg.
                  59 Woodfin Place
                  Asheville, NC  28801
                  (704)251-6208
                               A-9

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Marion Herz
Assoc.,  Envir. Health
American Lung Association
1726 M St., NW
Washington, DC  20036
(2.02)785-3355
Mark Hester
Attorney
General Motors
P.O. Box 33122
Detroit, MI  48232
(313)974-1790
John Hewings
Supervisor, Regulation Development
Ontario Ministry of Envir.
Air Resources Branch
880 Bay St., 4th Fl.
Toronto, Ontario  M5S 1Z8 Canada
(416)326-1655
Tom Hilliard
State Tax Notes Magazine
507 13th St., SE
Washington, DC  20003
(202)546-7542
Troy Hillier
Office of Management & Budget
725 17th St., NW, Room 3019
Washington, DC  20503
(202)395-3084
Jacob Hollinger
Environmental Defense Fund
Pollution Prevention Alliance
1616 P Street, NW
Washington, DC  20036
(202)387-3500
Melissa Home
Environmental Mgmt. Analyst
AER*X
1990 M St., NW
Suite 610
Washington, DC  20036
(202)463-6909
David Hoskins
Attorney
Sidley & Austin
1722 I St., NW
Washington, DC  20036
(202)736-8367
Dwight Howes
Government Affairs
CNG
1819 L Street, NW
Suite 900
Washington, DC  20036
(202)833-3900
Larry Hudson
Mgr., Alternative Fuel Vehicles
NY State Energy Res. & Devel.
2 Rockefeller Plaza
Albany, NY  12223
(518)465-6251 X209
Richard Hughes
Engineer
Texas Air Control Board
12124 Park 35 Circle
Austin, -TX  78753
(512)908-1554
John Huyler
Senior Associate
The Keystone Center
1320 Pearl St., #300
Boulder, CO  80302
(303)444-4777
                             A-10

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
John Irwin
Director
KS Dept. of Health & Envir.
Bur. of Air & Waste Mgmt.
Forbes Field, Bldg. 740
Topeka, KS  66620
(913)296-1593
Andrew Jacques
Health & Envir. Affairs
American Petroleum Institute
1220 L St., NW
Washington, DC  20005
(202)962-4705
William James
Dir, Public Finance Dept.
Prudential Securities Inc.
100 Gold St.
New York, NY  10292
(212)776-3963
Brad Johnson
Mgr., Corporate Planning
Potomac Elec. Power Co.
1900 Pennsylvania Ave., NW
Washington, DC  20068
(202)872-3561
Jim Jones
Associate Editor
Inside EPA Weekly Report
P.O. Box 7167.
Ben Franklin Station
Washington, DC  20044
(703)892-1011
Michael Jones
Chief, Ambient Standard Branch
U.S. EPA, OAQPS
MD-12
Research Triangle Park, NC   27711
(919)541-5656
Tom Jones
Sr. Staff Engineer
Union Carbide
P.O. Box 50
Hahnville, LA  70057
(504)468-4738
Roger Kanerva
Mgr., Environmental Policy
Illinois EPA
P.O. Box 1926
2200 Churchill Rd.
Springfield, IL  62794-9276
(217)785-5735
Gerald Keenan
Senior Vice President
Palmer Bellevue Corporation
111 W. Washington St.
Suite 1247
Chicago, IL  60602
(312)807-4848
Carter Keithley
President
Wood Heating Alliance
1101 Connecticut Ave.,
Suite 700
Washington, DC  20036
(202)857-1181
(WHA)
 NW
Linda Kelliher
Sr. Mgmt. Analyst
Meridian Corp.
4300 King St.
Alexandria, VA  22302
(708)998-3600
Judith King
Dir., Cong. & Regulatory Affairs
Amer. Furn. Manuf. Assoc.
918 16th St., NW
Suite 402
Washington, DC  20006
(202)466-7362
                              A-ll

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Nicholas Kirsch
Telluride Transit Company
P.O. Box 159
218 West Gregory St.
Telluride, CO  81435
(303)728-3512 .
Wolf Klassen
Dept. of Natural Resources
2300 N. Martin Luther King  Dr,
Milwaukee, WI  53212
(414)263-8512
Paul Kla'uman
Research Assistant
Lockheed Engineering & Sciences Co,
600 Maryland Ave., sw
Suite 600
Washington, DC  20024
(202)488-5854
Barry Korb
Chief, Regulatory Innovations  Staff
U.S. EPA, OPPE
401 M Street, SW, (PM-221)
Washington, DC  20460
(202)260-2689
Gerard Kraus
Chief, Organic Chem. Section
U.S. EPA, SSCD
401 M St., SW  (EN-341)
Washington, DC  20460
(703)308-8719
Jill Kupferberg-Cappadoro
Director of Marketing
Pinellas Suncoast Transist Authority
14840 49th St. N
Clearwater, FL  34622-2893
(813)530-9921
Terrence Larson
Mgr., Environmental Control
Unocal Corporation
911 Wilshire Blvd.
Suite 1114
Los Angeles, CA  90017
(213)977-7294
Mike Lawrence
Vice President
Jack Faucett Associates
4550 Montgomery Ave.
Suite 300 N
Bethesda, MD  20814
(301)961-8800
Michael Levin
Sr. Counsel
Nixon, Hargraves, Devans & Doyle
Attorneys at Law
1 Thomas Circle, NW, #800
Washington, DC  20005
(202)457-5541
William Lewis, Jr.
Attorney
Morgan, Lewis, & Bockius
1800 M Street, NW
Washington, DC  20036
(202)467-7145
Pat Leyden
Dep. Exec. Officer, Ping. & Rules
SCAQMD
21865 E. Copley Drive
P.O. Box 4939
Diamond Bar, CA  91765-0938
(714)396-3119
Alan Loeb
Energy/Envir. Policy Analyst
Argonne National Lab
9700 S. Cass Ave.
EID 900
Argonnne, IL  60439-4832
(708)752-6473
                                A-12

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Dennis Lunderville
Director
New Hampshire Air Resouces Div.
64 North Main St.
Caller Box 2033
Concord, NH  03302-2033
(603)271-1370
             Bruce Madariaga
             Economist
             U.S. EPA, ESD, OAQPS
             MD-13  '
             Research Triangle Park, NC   27711
             (919)541-5290
Rhonda Maddox
Environmental Engineer
U.S. EPA, SSCD
401 M St.,  SW (EN-341)
Washington, DC  20460
(703)308-8721
             Richard Mannix
             Crowell & Moring
             1001 Pennsylvania Ave.
             Washington, DC  20004
             (202)624-2958
Arthur Marin
Mobile Source Analyst
NESCAUM
85 Merrimac St.
Boston, MA  02114
(617)367-8540
             Andrea Martin
             Daniel R. Thompson, P.C.
             1620 I St., NW
             Suite 925
             Washington, DC  20006
             (202)293-5800
Karen Martin                         Tuck Masker
Chief, Regulatory Strategies Section Technical Director
U.S. EPA, OAQPS
MD-12
Research Triangle Park,
(919)541-5274
             Hearth Products Assn.
             1101 Connecticut Ave,
NC  27711    Suite 700
             Washington, DC  20036
             (202)857-1181
NW
Bharat Mathur
Mgr.,  APCD
Illinois EPA
2200 Churchill Rd.
Springfield, IL  62794-9276
(217)785-4140
             Nancy Mayer
             Environmental Engineer
             U.S. EPA, OAQPS
             MD-15
             RTF, NC  27711
             (919)541-5390
Susan Mayer
Environmental Policy Analyst
Congressional Research Service
Library of Congress
LM-423
Washington, DC  20540
(202)707-5936
             Kevin McCarthy
             Associate Analyst
             Office of Legislative Research
             Legislative Office Bldg., Room 5300
             Capitol Avenue
             Hartford, CT  06106
             (203)240-8400
                               A-13

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Janet McDonald
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy.
Research Triangle Park, NC  27709
(919)541-9100
Michael McGill
Executive  Director
Bay Area Economic Forum
200 Pine St., Suite 300
San Francisco,  CA  94104
(415)981-7117
Andy McGinn    _
Mgr., State & Local Relations
American Gas Association
1515 Wilson Blvd.
Arlington, VA  22209
(703)841-8597
 Bill McLean
 Economist
 Ministry of  Treasury & Economics
 7 Queens Park Crescent
 Frost  Bldg.,  5th Floor
 Toronto, Ontario  M7A 1Y7 Canada
 (417)327-0248
Gary McNeil
Consultant
Clegg & Associates
811 1st Avenue, Suite 200
Seattle, WA  98104
(206)623-7134
Melanie  Medina
Environmental Protection Specialist
U.S.  EPA,  OPPE,  OPA
401 M St.,  SW   (PM-221)
Washington,  DC   20460
 (202)260-9822
Joe Mendelson
Greenhouse Crisis Foundation
1130 17th St., NW, Suite 630
Washington, DC  20036
(202)466-2823
Robin Miles-McLean
Office  of  Policy,  Pl-anning,  & Evalua
U.S. EPA,  OPPE
'Waterside  Mall
401 M St.,  SW,  (PM-221)
Washington,  DC   20460
 (202)260-1126
Richard Morgenstern
Acting Assistant Administrator
U.S. EPA, OPPE
401 M St. SW  (PM-219)
Washington, DC  20460
(202)382-4332
 Patricia Morris
 Environmental  Scientist
 U.S.  EPA,  Region V
 77 W. Jackson
 Chicago, IL  60604
 (312)353-8656
Roger Morris
Office of Envir. Analysis
DOE
1000 Independence Ave., SW
Washington, DC  20585
(202)586-6707
 Brian  Morton
 Research  Triangle Institute
 P.O. Box  12194
 Research  Triangle Park,  NC  27709
 (919)541-7094
                              A-14

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                               ATTENDEE LIST
                      Innovative strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Peter Nagelhout
Regulatory Innovations Staff
U.S. EPA, OPPE
401 M St.,  SW  (AM-221)
Washington, DC  20460
(202)260-7015
Matt Naud
Associate
ICF
9300 Lee Hwy
Fairfax, VA  22031
(703)934-3933
Bob Nelson
Dir.,  Env. Affairs
Nat'1. Paint & Coatings Assoc.
1500 Rhode Island Ave., NW
Washington, DC  20005
(202)462-6272
Mary Nichols
Senior Staff Attorney
NRDC
617 S. Olive St., #1210
Los Angeles, CA  90020
(213)892-1500
Donna Nickerson
U.S. EPA, SSCD
401 M Street, SW  (EN-341W)
Washington, DC  20460
(703)308-8694
Elizabeth Nixon
Environmental Mgmt. Analyst
AER*X
1990 M St., NW
Suite 610
Washington, DC  20036
(202)463-6909
Alan Nogee
Energy Program Director
MASS PIRG
29 Temple Pi.
Boston, MA  02111-1305
(617)292-4800
Robert Nordhous
Partner
Van Ness, Feldman, & Curtis
1050 Thomas Jefferson St., NW
Washington, DC  20007
(202)298-1800
Carolyn Norris
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy.
Research Triangle Park, NC  27709
(919)541-9100
John O'Connor
Program Manager
Radian Corporation
P.O. Box 13000
3200 Chapel Hill Rd./Nelson Hwy.
Research Triangle Park, NC  27709
(919)541-9100
Gary O'Neal
U.S. EPA, Region 10
1200 6th Ave.,  MSHW-111
Seattle, WA  98101
Peter Okurowski
Technical Support Staff
U.S.EPA, Region 5
Motor Vehicle Emissions Lab
2565 Plymouth Rd.
Ann Arbor, MI  48105
(313)668-4242
                                A-15

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Conniesue Oldham
IRS Workshop Chairperson
U.S. EPA, OAQPS
MD-12
Research Triangle Park, NC
(919)541-7774
            27711
Amanda Ormond
Energy & Environmental Planner
Dept. of Commerce, Energy Office
3800 North Central Ave.
Suite 1200
Phoenix, AZ  85012
(602)280-1420
Ryuzo Oshita
Gov. Relations Tech. Group
Toyota Motor Corp. Services
1850 M St.,  NW
Suite 600
Washington,  DC  20036
(202)463-6832
                     Andrew Otis
                     U.S. EPA, OPPE
                     401 M Street, SW  (PM-221)
                     Washington, DC  20460
                     (202)260-2887
John Palmisano
President
AER*X, Inc.
1990 M St., NW
Suite 610
Washington, DC
(202)463-6909
20036
Angela Park
Sustainable Development Program
Center for Policy Alternatives
1875 Connecticut Ave., NW,  #710
Washington, DC  20008
(202)387-6030
William Pedersen
Perkins Coie
607 14th St.,  NW
Washington, DC  20005-2011
(202)434-9612
                     Anthony Peer
                     Manager, Intergovt'1. Coord.
                     Delaware Dept. of Transportation
                     P.O. Box 778
                     Dover, DE  19903
                     (302)739-4358
Richard Penna
Partner
Schnader, Harrison,
111 Nineteenth St.,
Suite 1000
Washington, DC  20036
(202)463-2966
                     Alan Powell
                     Environmental Engineer
    Segal & Lewis    U.S. EPA, Region 4
    NW               Air Division .
                     345 Courtland Street, NE
                     Atlanta, GA  30365
                     (404)347-5014
Nicholas Prassas
V.P., Public Finance Dept.
Prudential Securities Inc.
One Embarcadero Center
Suite 3860
San Francisco, CA  94111
(415)772-3630
                     Todd Ramsden
                     Environmental Protection Specialist
                     U. S. EPA, Office of Policy Analysis
                     401 M St., SW  (PM-221)
                     Washington, DC  20460
                     (202)260-7721
                                A-16

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Roger Raufer
Associate Director
Center for Energy/Environment
University of Pennsylvania
G-19 Meyerson Hall
Philadelphia, PA  19104
(215)898-2775
                  Douglas Raymond
                  Div. Director, Regulatory Affairs
                  Sprayon Products
                  26300 Fargo Ave.
                  Bedford Heights, OH  44146
                  (216)292-7400
Larry Rennacker
Planning Division
Santa Barbara Co. APCD
26 Castillian Dr.
B-23
Goleta, CA  93117
(805)961-8800
                  Bill Repsher
                  U.S. EPA, OE
                  Waterside Mall
                  401 M St.,  SW
                  Washington, DC
                  (202)260-2845
               (LE-134-A)
                20460
Harvey Richmond
Envir. Protection Specialist
U.S. EPA, OAQPS
MD-12
Research Triangle Park, NC  27711
(919)541-5271
                  Michael Riehle
                  Mgr.,  Policy Analysis
                  Unocal Corporation
                  1201 W. 5th St.
                  Los Angeles, CA  90017
                  (213)977-7311
Bill Roach
Supervisor, Market
Seattle Metro
MS 128
821 Second Ave.
Seattle, WA  98104
(206)684-1620
Development
Doug Roaldson
San Diego Gas & Electric
101 Ash St.,  EB-901
San Diego, CA  92101
Ernie Rosenberg
Dir., Ext. Affairs
Occidental Petroleum
1747 Pennsylvania Ave., NW
Washington, D. C.  20006
(202)857-3051
                  William Rosenberg
                  Assistant Administrator
                  U.S. EPA, OAR
                  401 M St., SW  (ANR-443)
                  Washington, DC  20460
                  (202)382-7400
Nikki Roy
Pollution Prevention Specialist
Environmental Defense Fund
1616 P St., NW
Washington, DC036  20036
(202)387-3500
                  John Rudd
                  U.S. EPA, OE
                  401 M St.,  SW
                  Washington, DC
                  (202)260-2864
               (LE-134A)
                20460
                               A-17

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
John Rugge
Subaru of America, Inc.
Regulatory Dept.
P.O. Box 6000
Cherry Hill, NJ  08304-6000
(609)488-8514
         Cheryl Russell
         Dir.,  Federal Environmental Affairs
         The Boeing Co.
         1700 No. Moore Street
         Arlington, VA  22209-1989
         (703)558-9605
Karen Sabasteanski
Policy Analyst
Air Pollution Control Dept.
P.O. Box 10089
Richmond, VA  23240
(804)786-2378
         Rafael Sanchez
         Chemical Engineer
         U.S. EPA, OAR/SSCD
         401 M Street, SW  (EN-341W)
         Washington, DC  20460
         (703)308-8730
Kathryn Sargeant
U.S. EPA, OMS
2565 Plymouth Rd.
Ann Arbor, MI  48105
(313)668-4441
         Nancy Saylor
         Policy Analyst
         Air Pollution Control Dept.
         P.O. Box 10089
         Richmond, VA  23240
         (804)786-1249
Claire Senary
U.S. EPA, Acid Rain Div,
401 M St., -SW (ANR-445)
Washington, DC  2046-a
(202)260-1746
         Will Schroeer
         U.S. EPA, OPPE
         401 M St.,  SW  (PM-221)
         Washington, DC  20460
         (202)260-1126
John Seitz
Director, OAQPS
U.S. EPA, OAR
MD-10
Research Triangle Park, NC
(919)541-5618
27711
Jim Sell
Senior Counsel
Nat.'l Paint & Coatings Assoc.
1500 Rhode Island Ave., NW
Washington, DC  20005
(202)462-6272
Arthur Sheffield                     Deborah Sheiman
Chief, Regulatory & Economic Affairs Resource Specialist
Environment Canada                   NRDC
Place Vincent Massey                 1350 New York Ave., NW
15th Floor                           Washington, DC  20005
Hull, Quebec  KIA OH3 Canada         (202)783-7800
(819)953-1172
                               A-18

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                                ATTENDEE LIST
                       Innovative  strategies  Workshop
                  Georgetown  University Conference Center
                            January 15-17,  1992
Ruth-Ann Shumaker
Technician
N.C. Air Quality Section
512 N. Salisbury St.
P.O. Box 29535
Raleigh, NC   27626
 (919)733-3340
                      Stephen Sinkez
                      Assistant Vice President
                      Mitsubishi Motors America,  Inc.
                      1111 19th St., NW
                      Suite 408
                      Washington, DC  20036
                      (202)223-3845
 Sarah Siwek
 Director
 L.A. Co. Transportation  Conun.
 818 West 7th St.
 Suite 1100
 Los Angeles, CA   90017
 (213)244-6278
                      Steve Sky-Peck
                      Environmental Quality Coordinator
                      Louisiana Dept. of Env. Quality
                      Legal Affairs & Enforcement Office
                      PO Box 82282
                      Baton Rouge, LA  70884-2282
                      (504)765-0399
:Marian Slavin
'Travel Reduction  Program Mgr.
 Pima Association  of  Governments
 177 N. Church Ave.,  #405
 Tuscon, AZ   85701
 (602)792-2952
                      Jason Smitherman
                      Administrator
                      Alternative Fuels Program
                      Okla. Office of Public Affairs
                      3301 N. Santa Fe
                      Oklahoma City, OK  73118
                      (405)521-4687
 Heidi  Snow
 Policy Analyst
 Center for  Policy Research
 444 North Capitol St.
 Suite  250
 Washington,  DC   20001-1572
 (202)624-5384
                      Lynn Sonntag
                      Senior Counsel
                      The Walt Disney Company
                      500 S. Buena Vista Street
                      Burbank, CA  91521-0321
                      (818)560-7094
 George  Spencer
 Editor
 Clean Air Week
 4418 MacArthur
 Washington,  DC
 (202)298-8202
Blvd.
 20007
Sam Spencer
Editor
Clean Air Week
4418 MacArthur Blvd.
Washington, DC  20007
(202)298-8202
 David Sprague
 OAPQS/OAR
 U.S. EPA
 Stationary Source Compliance  Div.
 401 M Street, SW, EN-341 W
 Washington,  DC   20460
 (703)308-8582
                      Cynthia Stahl
                      U.S. EPA, Region 3
                      841 Chestnut Bldg
                      Philadelphia, PA  19107
                      (215)597-9337
                              A-19

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Mathy Stanislaus
Huber, Lawrence & Abell
605 Third Ave.
New York, NY  10158
(212)455-5529
Carol Stanzak
Air Pollution Specialist
California Air Resources Board
Transportation Strategies Group
1102 Q Street, P.O. Box 2815
Sacramento, CA  95812
(916)445-0098
Sue Stendebach
Envir. Protection Specialist
U.S. EPA  ARD
401 M Street, SW, (ANR-445)
Washington, DC  20460
(202)260-1312
Patton Stephens
Staff Evaluator
U.S. General Accounting Office
Rm. 308
100 Indiana Ave., NW
Washington, DC  20001
(202)376-9714
Randy Stiles
Atmospheric Sciences Div.
Versar, Inc.
9200 Rumsey Rd.
Columbia, MD  21045
(410)964-9200
Barbara Stinson
The Keystone Center
P.O. Box 8606
Keystone, CO  80435-7998
(303)468-5822
Brenda Stoner
JSC
1015 15th Street, NW
Washington, DC  20005
Robin Sullivan
Environmental Engineer
U.S. EPA, Region 6
1445 Ross Ave.
6T-AP
Dallas, TX  75287
(214)255-7214
Roger Sung
Program Manager
Southern California Edison
2244 Walnut Grove Ave.
Rosemead, CA  91770
(818)302-9551
Martha Tableman
Associate
The Keystone Center
P.O. Box 8606
Keystone, CO  80435
(303)468-5822
Christine Terry
Director
Evansville EPA
Room 207, Civic Center Complex
1 NW Martin Luther King Blvd.
Evansville, IN  47708
(812)426-5597
Ivan Tether
Senior Counsel
Pacific Enterprises
633 W. Fifth St., #5400
Los Angeles, CA  90071
(213)895-5150
                               A-20

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Rich Theroux
Office of Management & Budget
725 17th St., NW, Room 3019
Washington, DC  20503
(202)395-3084
John Thomasian
Natural Resources
Nat.'1 Governors' Assoc.
444 No. Capitol St.
Washington, p. C.  20001
(202)624-7881
Michael Thompson
Assoc. Director, Legis. Affairs
Chemical Specialties Mfrs. Assn,
1913 Eye St.,  NW
Washington, DC  20006
(202)872-8110
Gus Tirado
Gov't. Affairs Tech. Group
Toyota Motor Corp. Services
1850 M St., NW
Suite 600
Washington, DC  20036
(202)463-6832
Tom Tyler
U.S. EPA, OPPE
401 M St.,  SW  (PM-221)
Washington, DC  20460
(202)260-2692
John Ungvarsky
Envirironmental Scientist
U.S. EPA, Region 9
Stationary Source Branch
75 Hawthorne St. (A-5-3)
San Francisco, CA  94105
.(415)744-1188
Eric Van De Verg
Project Director
Jack Faucett Associates
4550 Montgomery Ave.
Suite 300 N
Bethesda, MD  20814
(301)961-8800
Lucille Van Ommering
GARB Executive Office
P.O. Box 2815
Sacramento, CA  95812
(916)323-0296
Hans Van Zijst
Counselor for Environment
Netherlands Embassy
4200 Linnean Ave., NW
Washington, DC  20008
(202)244-5300
Ray Vogel
U.S. EPAr OAQPS
MD-15
Research Triangle Park, NC  27711
(919)541-3153
Gustave Von Bodungen
Administrator
LA Dept. of Envir. Quality
Air Qual. & Nuclear Energy
P.O. Box 82135
Baton Rouge, LA  70810
(504)765-0110
Jerry Wade
Research Economist
Maryland Dept. of Economics
and Employment Development
217 E. Redwood St., llth Floor
Baltimore, MD  21202
(301)333-6950
                                A-21

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
William Wason
Consultant
Environmental Solutions
123 Cleo Rand St.
San Francisco, CA  94124
(415)822-2991
Lawrence Watkins
Program Supervisor., TAO
SCAQMD
21865 Copely Dr.
Diamond Bar, CA  91765
(714)396-3246
Edward Watts
Economist
Dept. of Energy
1000 Independent Ave. SW
Washington, DC  20575
(202)586-8436
Richard Wegman
Attorney
Garvey, Schubert & Barer
1000 Potomac "St. NW
5th Floor
Washington, DC  20007
(202)965-7880
William West
Environmental Affairs
Southern California Edison
2244 Walnut Grove Ave.
Rosemead, CA  91770
(818)302-9534
Mike Whinihan
Senior Economist
General Motors
Rm. 15-255
Detroit, MI  48202
(313)556-3878
Jill Whynot
South Coast AQMD
21865 E. Copley Dr.
PO Box 4939
Diamond Bar, CA  91765-0938
(714)396-3104
Martin Wikstrom
Environmental Affairs Executive
NEMA
2101 L St., NW
Washington, DC  20037
(202)457-8487
Rich Wilcox
Project Manager
U.S. EPA, OAR
Technical Support Staff
2565 Plymouth Rd.
Ann Arbor, MI  48105
(313)668-4390
Darrell Williams
Project Manager
The Advocacy Institute
1730 Rhode Island Ave., NW
Suite 600
Washington, DC' 20036
(202)659-8475
Terri Wilsie
U.S. EPA, OPAR
401 M St., SW (ANR-443)
Washington, DC  20460
(202)260-1360
Steven Winberg
Director, Cofiring
CNG
625 Liberty Ave.
CNG Tower
Pittsburgh, PA  12522-3199
(412)227-1431
                                 A-22

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                               ATTENDEE LIST
                      Innovative Strategies Workshop
                  Georgetown University Conference Center
                            January 15-17, 1992
Anne Wittenberg
Senior Associate
ICF Inc.
1850 K St. NW
#1000
Washington, DC  20006
(202)862-1202
Verne Wochnick
Mgr., Government Affairs
Hughes Aircraft Company
Corporate Hdqtrs. P.O. Box 45066
Bldg C-l, M/S C129
Los Angeles, CA  90045-0066
(213)568-6318
Chris Wolz     -
Office of Management & Budget
725 17th St., NW, Room 3019
Washington, DC  20503
(202)395-3084
Ben Yamagata
Partner
Van Ness, Feldman & Curtis
1050 Thomas Jefferson Street, NW
Washington, DC  20007
(202)298-1800
Carl York
Chief, Regulatory Development Div.
MD Dept. of the Environment
2500 Broening Hwy.
Baltimore, MD  21224
(301)631-3245
Ellen Young
Attorney
Van Ness, Feldman & Curtis
1050 Thomas Jefferson Street, NW
Washington, DC  20007
(202)298-1800
Robert Youngman
Attorney
Garvey, Schubert & Barer
1000 Potomac St. NW
5th Floor
Washington, DC  20007
(202)965-7880
Marcia Zalbowitz
Consultant
Solar Electric Engineering
1915 Kalorama Rd., NW
Suite 102
Washington, DC  20009
(202)387-6185
                                A-23

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DUF

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