& 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
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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
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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.
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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.
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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.
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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).
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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. .
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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.
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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.
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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.
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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.
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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).
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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.
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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.
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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?
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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.
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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.
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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.
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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?
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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.
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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?
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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?
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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.
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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.
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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.
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SESSION m
OTHER INNOVATIVE STRATEGIES
FOR AIR POLLUTION CONTROL
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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.
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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.
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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.
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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?
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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.
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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.
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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.
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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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