& 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 ------- 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 ------- This report has been reviewed by the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency (EPA), and has been approved for publication. Any mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. Furthermore, the EPA is not endorsing any particular program featured in the workshop; the programs included were chosen to illustrate key issues associated with various innovative strategies. Questions and comments on the document should be directed to the workshop chairperson: Conniesue Oldham, Ph.D. Telephone (919) 541-7774 Regulatory Strategies Section Ambient Standards Branch Air Quality Management Division (MD-12) Office of Air Quality Planning and Standards Technical support was provided by the Radian Corporation. A companion document entitled "Summary of Innovative Regulatory Strategy Programs Found in the Literature and Popular Press," EPA-452/S-92-002, identifies a wide range of innovative programs being developed or implemented. EPA-452/S-92-001 ii ------- 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 ------- ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- LIST OF ACRONYMS AVR Average Vehicle Ridership BACT Best Available Control Technology CAA Clean Air Act CAAA Clean Air Act Amendments of 1990 CAFE Corporate Average Fuel Economy CNG Compressed Natural Gas C02 Carbon Dioxide EPA U.S. Environmental Protection Agency HOV High Occupancy Vehicle I&M Inspection and Maintenance LAER Lowest Achievable Emission Rate LEV Low Emission Vehicle MACT Maximum Achievable Control Technology NESCAUM Northeast States for Coordinated Air Use Management NOX Nitrogen Oxides NSPS New Source Performance Standard NSR New Source Review PA YD Pay As You Drive Auto Insurance PSD Prevention of Significant Deterioration RACT Reasonably Achievable Control Technology RFP Reasonable Further Progress ROG Reactive Organic Gases SCAQMD South Coast Air Quality Management District SIP State Implementation Plan SOX Sulfur Oxides STAPPA/ State and Territorial Air Pollution Program Administrators/ ALAPCO Association of Local Air Pollution Control Officials TCM Transportation Control Measure TRI Toxic Release Inventory VOC Volatile Organic Compound VMT Vehicle Miles Traveled 7 ------- SESSION I INNOVATIVE USES OF TAXES AND FEES FOR STATIONARY AND MOBILE SOURCES ------- ------- Session I LOUISIANA ENVIRONMENTAL SCORING SYSTEM* INTRODUCTION Thirty-one individuals participated in this small group discussion. The group included persons from Federal and State government, industry, academia, and public interest groups. Louisiana State government officials and some others in attendance considered the program successful due to its ability to motivate industry compliance. Their views are reflected under the following sections on Louisiana Program Successes and Key Factors Motivating Industry Compliance. Some industry participants, however, strongly opposed particular aspects of the program, believing that it unfairly burdened corporate facilities. Their views are listed under the section entitled Industry Concerns about the Louisiana Program. There was considerable interest in the adaptability of this program to other jurisdictions. There was general agreement that improvements in the program structure could be made; however, most participants thought that the Louisiana Program provided a model, or at least a starting point, for development of similar programs. Suggestions made by individuals in the group on ways to improve the program, as well as political and equity issues to be considered before adopting a program, are also listed below. HIGHLIGHTS Louisiana Program Successes Used a multimedia approach. Rewarded improvement in compliance. Generated 5 million dollars in local revenues. Reported emission decreases of 36 million pounds of toxic release inventory (TRI) air pollutants and 10 million pounds of criteria pollutants, based on the 1-year life of this program. Emphasized pollution prevention rather than end-of-pipe control. 4 Key Factors Motivating Industry Compliance Tax exemption privileges could be diminished for a long time. Score cards were made publicly available. Companies engaged in competition to obtain good scores. This program was cancelled by the recently elected governing party. 9 ------- Session I Industry Concerns About the Louisiana Program Regulation was retroactive to 1990. Emissions/employee ratio as a criterion for allocating bonus points was questioned. Larger facilities thought they were unfairly burdened. Use of tax structure to achieve environmental goals was viewed as unfair, especially since industry pays most of the State's property tax. Possible Ways to Improve the Program or Similar Programs Use a risk-based approach to award bonus points: weight environmental risks of various TRI chemicals. Consider whether a facility is in a nonattainment area. Reduce uncertainties for industry. Phase in the program. Consider implementing a formula to weigh historical environmental progress of sources in the scoring system. Implement the program legislatively, not administratively. Run sample test scores before the regulation is issued to determine the effectiveness of the score card. Policy Considerations What type of approach best encourages environmental progress? Carrot (incentive) or stick (disincentive). Fixed target or open-ended? Command-and-control approaches have required compliance with specific targets. Open-ended approaches encourage continuous improvement, but are a new concept and create a degree of uncertainty for industry. Industry needs regulatory certainty. Potential conflict between agencies geared toward environmental protection and those geared toward economic development. 10 ------- Session I Factors including high toxic emissions, high unemployment, a weak economy, and support from the Governor, led to a favorable political climate for adopting the program. Programs implemented administratively, rather than legislatively, may be more vulnerable. Equity Issues Establish regulations that reward good environmental citizens. Reward previous environmental efforts. Make fines commensurate with environmental impact. Evaluate whether tax structure is fair. 11 ------- ------- Session I FEEBATES INTRODUCTION Approximately 70 individuals, representing a cross section of Federal, State, industry, and environmental organizations attended the group discussion on feebates. The following discussion summary reflects the dialogue among individuals in the group. Ideas are those of individuals, and were not necessarily agreed upon by the group as a whole. The group did not come to a consensus on the effectiveness of the program in reducing emissions. All comments about Drive Plus refer to the proposed program in California. Comments about feebates refer to programs similar to Drive Plus, but not to a specific program. HIGHLIGHTS Drive Plus and Emissions Reductions The goal of Drive Plus is to reduce the sales-weighted average of vehicle emissions. The program is designed to lower the average, not to impose a limit. The group generally agreed that it is difficult to determine the effect of Drive Plus on emissions reductions of criteria pollutants. Individual perspectives follow: Drive Plus is based on the premise that a car's emissions over its useful life are a function of its certified emissions [according to the Federal test procedure (FTP)]. However, cars* do not maintain their initial emission levels due to tampering and poor quality maintenance. Their rate of deterioration cannot be predicted by the FTP. Thus, the small improvements in certified emissions that Drive Plus attempts to achieve may not be a significant factor in determining on-road emissions of cars. It is difficult to establish correct prices for automobile emissions without being able to predict deterioration rates. As long as a vehicle has potential to emit (has a tail pipe), its emission level over time is not predictable. Therefore, the only way that Drive Plus could assume a certain level of emissions reductions may be by assigning fees to cars if they have potential to emit and assigning rebates to cars if they do not (i.e., if they are electric or solar vehicles that do not have a tail pipe). 12 ------- Session I Although the effect of Drive Plus on criteria pollutant emissions may be difficult to determine, the program does encourage people to buy more fuel- efficient cars. (FTP measurements of fuel economy provide more accurate measures of on-road fuel economy than emissions of criteria pollutants.) In addition, Drive Plus provides information to consumers regarding auto emissions. Over time, the program is expected to cause reduced fleet carbon dioxide (CC^) emissions, as people buy cars with better fuel economy. Cost of Drive Plus Program It is difficult to estimate how much money Drive Plus will cost to implement. The program can be started with funds from the General Fund. Such programs might also be started with funds from a vanity license plate fund. Once implemented, the program could be self-supporting. Drive Plus program administrators may need to periodically adjust Drive Plus credit/surcharge schedules to ensure that surcharges cover the credits and program operating costs. Surveys indicating how fees and rebates influence vehicle choice have already been conducted. These initial surveys will help Drive Plus program administrators set surcharge and credit levels so that Drive Plus revenues just offset Drive Plus credits and program costs. Drive Plus may increase the average price of cars because manufacturers would have an incentive to build cars with more sophisticated pollution-control and fuel-economy technologies. Based on the relative amounts of Drive Plus credits and surcharges for particular vehicle models, it is expected that consumers would decide whether to alter their preference of vehicles within and among vehicle classes. Surcharges and credits could be set to reflect the societal cost of vehicle emissions. There is concern as to whether surcharge levels are likely to be large enough to affect consumer behavior. The Drive Plus legislation currently being considered in California would impose surcharges roughly as large as $1,000 and credits roughly as large as $2,000. The amount of fee or rebate would depend on the estimated vehicle model emissions, based on application of the FTP to a few test cars of each model. If people respond to the Drive Plus program by buying cars with lower certified carbon monoxide (CO), nitrogen oxides (NOX), hydrocarbons (HC), and C02 emissions, the zero-point would decrease. Furthermore, as the differences among cars decrease, the rebates and credits could decrease. 13 ------- 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. 14 ------- Session I There is disagreement on whether consumers realize how much money fuel- efficient cars save over time through reduced gas consumption. Inspection and Maintenance (I&M) Programs Nontraditional I&M programs (using remote-sensing technology) could target both old cars and new cars with high emission levels. These programs could provide disincentives to tamper and incentives to better maintain serviceable vehicles. New monitoring technology can record emissions of 1,000 cars per hour by using a remote sensor and a video snapshot of the license plate. The majority of high-polluting cars flagged by sensors are cars that have evidence of tampering. There is disagreement over the effectiveness of remote sensing. SCRAP Programs UnocaTs SCRAP program paid people in the Los Angeles basin $700 to junk pre-1971 cars in an effort to reduce vehicle pollution. The results of the Unocal program revealed that: High emissions are not directly correlated with age, but rather with tampering and neglect. The total of 1975 cars account for more vehicle emissions than the total of cars from any other model year. That this total is a function of the average emissions of cars in that model year, the number of vehicles of that model year on the road, and the average miles driven by cars in that model year. The dirtiest 10 percent of the cars account for over 50 percent of auto air emissions. Registration Fees Registration fees could be used to collect money to buy old cars. * Cars could be registered and fees determined according to certified emissions level. However, the reliability of certified emissions levels is an issue. Registration fees would affect cars currently on the road, biit not vehicle sales. Pay As You Drive Auto Insurance (PA YD) The PA YD concept could be used in conjunction with other programs to create incentives to encourage drivers to choose alternate forms of transportation and to reduce the number of miles driven. 15 ------- Session I Automobile Safety Feebates could be used to achieve policy objectives other than fuel efficiency and emissions reductions. They could be used, for example, to encourage vehicle safety. Vehicle safety information is available to consumers in magazine/book stores. However, this information is not made readily available to consumers while in the car lot looking at a car. FUTURE DIRECTIONS 4 Complexity versus Simplicity A combination of programs would seem to resolve the issue of reducing emissions levels associated with polluting older cars and new cars. Some believed that a collection of programs would confuse the consumer and that the best program would be the simplest one. * Other Some regulators argued that feebate programs need to focus on criteria pollutant emissions reductions. An overall-question remaining after the discussion was whether the regulatory focus should be on new cars or on old cars, and if both, whether the two objectives should be accomplished through the same or separate programs. In addition, programs need to be evaluated to ensure that the consumer is aware of a vehicle's emissions and any resulting costs. 16 ------- ------- Session I ALTERNATIVE FUELS: First Discussion Group INTRODUCTION The group that attended this discussion appeared to be interested primarily in current developments concerning alternative fuels. There were approximately 10 attendees in this group. Most were from State environmental agencies. The fuel industry and a foreign auto- maker were also represented. The bulleted items below reflect comments expressed by individuals during the discussion. HIGHLIGHTS Resources The costs of converting and installing alternative fuel stations depend on the type of station and fuel used. For example, quick-fill stations, which operate like gas stations, are more expensive to install than slow-fill stations. Slow-fill stations, on the other hand, can refuel vehicles over night, and thus are appropriate for fleets. Fuels to Drive our Future (National Research Council, Commission on Engineering and Technical Systems. Washington, DC: National Academy Press, 1990) is a good assessment of alternative fuels; useful resource for evaluating capital costs, but not for evaluating fuel distribution costs. Organizations, such as the American Gas Association, can provide information about the costs and savings of using different alternative fuel options. Emissions Two theories on how areas can move out of nonattainment status: Use newer, cleaner cars; and Use cleaner fuel with lower vapor pressures. Adoption of California's low emission vehicle (LEV) program is not necessarily cost effective in all areas. Some States (e.g., Connecticut) may not receive enough emission credits initially to make it a worthwhile venture. Transferability of alternative fuels programs is difficult. Cost effectiveness and actual emissions reductions will vary among geographical and socio- economic regions. Need to evaluate alternative fuel choices in regard to specific air pollution problems. 17 ------- Session I Compliance can result not only from converting existing vehicles, but also by replacing gasoline vehicles with alternative-fueled vehicles. Compressed natural gas (CNG) conversion equipment can be transferred between cars. 4 Market Arizona has tried different alternative fuels. The usefulness and availability of fuels in different areas within the State are determining their market niche. Conversions are only a bridge strategy until dedicated-fuel vehicles are more accessible. Some alternative fuel theories assert that all fossil fuels will need to be replaced. Some thought that successful fuels will compete in the marketplace regardless of whether incentives are offered. Others thought that CNG may be the only fuel able to compete in the .marketplace without incentives. OTHER PROGRAMS Mobil Corporation is in the process of opening a natural gas filling facility in Brooklyn, New York. It will cost $300,000 to install two pumps. Oklahoma's alternative fuels program was developed for two reasons. Both environmental and energy groups supported it. The State needed a new market for natural gas production. Oklahoma's program began in 1987 and includes several incentives. Legislation was proposed in 1989, and the bill passed both houses with no votes against it in 1991. The program includes all alternative fuels and requires emissions testing of vehicles. The changes in air quality since the program began have not been quantified because the area reached attainment before the legislation was passed. Northeast States for Coordinated Air Use Management (NESCAUM) sponsored an alternative fuel road rally this past fall with a route traveling through the capitals of the northeastern States. The Solar/Electric 500 race in Arizona brought people together, thus serving as a forum for exchange of ideas. The race now has corporate sponsors and is expected to be held annually. 18 ------- Session I Arizona also educates the public on tax incentives, which include reductions in vehicle tax and registration tax for alternative-fueled vehicles. In Arizona, solar-powered cars may be successful in off-grid areas where there is no access to electricity and no charging capabilities. The State of New York provides dedicated parking for alternative-fueled vehicles. McDonell Douglas will circulate alternative-fueled vehicles among its employees. Toyota is conducting research on alternative-fueled vehicles in Japan and in the U.S., and demonstrating alternative-fueled vehicles in Japan. FUTURE DIRECTIONS There was general agreement on the following points: . The public needs to be educated on safety issues concerning natural gas. Those who have provided this type of education believe that public perception can be changed. Guidelines for the equipment used with alternative fuels are needed. Some equipment does not bum fuel as cleanly as expected. Some group members thought that programs should not endorse any particular fuel, but should remain "fuel-neutral" _to avoid providing incentives for the wrong fuel (one that may not significantly reduce emissions or may not be cost effective in the end). A clearinghouse~for~information exchange on alternative fuels would be helpful. Some thought that money should be allocated directly to alternative fuels programs, rather than to State offices. 19 ------- ------- Session I ALTERNATIVE FUELS: Second Discussion Group INTRODUCTION The second discussion group on alternative fuels consisted of 12 participants - from State agencies, EPA Regional Offices, industry, and public interest groups. Although there appeared to be group consensus on the types of issues associated with alternative fuel use (fuel accessibility, user considerations, compliance, incentives, costs, and regulatory factors), varying viewpoints on the specifics of these issues were expressed by participants. HIGHLIGHTS Fuel Accessibility Issues Group members generally agreed that an infrastructure is needed to promote the use of alternative fuels. State representatives in the group cited the following issues that need to be addressed when developing an infrastructure: Fuel delivery. Fuel availability and guaranteed vehicle use. An individual needs to know that fuel is available before making an .investment in a vehicle. Conversely, fuel suppliers need a guarantee that demand exists before spending money on a fueling station. Emissions from the total fuel cycle need to be evaluated, including fuel production. Ability to obtain repair parts. Insurance considerations. Parking and driving considerations, e.g., whether alternative-fueled vehicles are allowed in parking garages, car washes, and tunnels. What happens to obsolete gas stations? Eventually, one fuel would emerge as the cleanest fuel and the cheapest . to operate. If so, a plan for transition to this "winner" would be needed. Niche markets (such as methanol for transit buses) would probably emerge, influenced by regional characteristics and the availability of different fuel types. Altitude and other regional factors influence carburetor settings and air- to-fuel ratios. These differences make transporting fuel from one region to another difficult. The need for flexibility. Rate structures need to be determined. 20 ------- Session I The group members generally agreed that supply and market issues can be factors. Individual group members cited the following issues: Long-term supply of alternative fuels. Rationale for interfering in the market includes expenditures, reduction of dependence on foreign oil, and diversification of fuel options. Criteria for determining which fuels to promote (e.g., climate differences, CC>2 issues, region-specific issues). User Issues One State representative noted that the performance criteria that alternative- fueled vehicles must meet include acceleration, passing speed, driving range, and fuel tank size (e.g., propane tanks are large). An industry representative gave two reasons why industry is changing to alternative fuels. Concern for adequate supply of currently-used fuel. A way to reduce their costs. A State representative responded by stating that more information is needed about performance, including the pros and cons of each available alternative fuel. For example, California assumes that natural gas vehicles will be cleaner, but New York believes that is not necessarily the case. Compliance It was noted that standards are needed to ensure that garages are retrofitting State fleets and individual vehicles correctly. Certified conversion kits, enforcement action, or Federal motor vehicle standards are needed. The group generally agreed that guidance is needed to monitor compliance. Individuals in the group cited the following possibilities: A system approach (e.g., fuel evaporation). Monitoring techniques need to be applicable for all fuels and for the total fuel cycle. Current I&M programs do not accurately measure tailpipe emissions from vehicles fueled by CNG, so other monitoring techniques are needed for this fuel type. A Stedman laser measures emissions and takes a photograph of the license plate. Tuning up high emitters is probably the cheapest way to reduce emissions. Innovative Offsets a bill planned to be introduced in California in January 1992. 21 ------- Session I Although clean fuel vehicles are exempted from complying with transportation control measures (TCM) under the Clean Air Act Amendments (CAAA), they still contribute to traffic congestion. Incentives Most of the group thought that incentives are needed for alternative fuels to be selected over current fuels. Individuals suggested the following: Emission Feebates. Coordination of incentives for alternative fuel use with gasoline programs, otherwise States would lose gasoline tax revenues. Taxes on imported oil (Japan and Great Britain, where fuel costs are four times greater than those in the United States [ $5/gallon] are increasing fuel efficiency). Preferential parking for alternative fuel cars. One State representative questioned whether the market would develop anyway, citing Kansas as an example, where Amoco is selling CNG despite the absence of any incentives. Costs The group generally agreed on the following cost issues: User costs include those at the pump, conversion costs, and the costs to own, maintain, and operate alternative fuel vehicles. Societal costs and benefits also should be considered. Individuals cited the following as examples: Environmental. Fuel supply. Political. Balance of trade. Secondary economic impacts (increased costs of transportation passed on to consumers). Consumer - (costs of building new alternative fuel stations will increase fuel rates). Short- and long-term costs should be considered. One participant noted that current demand for alternative-fueled vehicles in the South Coast area (a result of the rules requiring fleets to have a certain number of low-emitting vehicles) is not high enough to cover the automobile manufacturers' production costs. For this reason, the vehicles needed to meet the regulations will have limited availability until the demand for them increases dramatically. 22 ------- 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 ------- SESSION H MARKETABLE PERMITS FOR STATIONARY, MOBILE, AND AREA SOURCES 24 ------- Session II MARKETABLE PERMITS MARKET MECHANISMS: First Discussion Group INTRODUCTION The first market mechanisms discussion group had approximately 30 attendees. There appeared to be an even distribution of group members from industry and regulatory agencies. Several group members were from regulatory agencies in foreign countries, including the Netherlands and Canada. Information on the California Marketable Permits Program was of most interest to the group. Specifically, the attendees were interested in how the program was being set up to avoid market problems or failure. The following is a summary of comments and concerns expressed by individuals in the discussion. All comments below that refer to a specific program are referring to the SCAQMD proposed program, much of which is still evolving. HIGHLIGHTS 4 Adequate Market/Type of Market Will limited market activity still produce program benefits? Most group members believed the activity would not be limited, and that not allowing credits to be banked for more than 1 year will force activity. The SCAQMD does not consider holding credits an asset. Under the currently-proposed California Marketable Permits Program, all facilities covered under the program must have enough emissions credits to cover all emissions including credits for current operations and any increases. The following is a typical transaction under the currently-proposed program: a plant plans for a major modification, which includes installing a boiler and increasing emissions above the significance level. A permit modification package is put together and submitted to SCAQMD. The SCAQMD office gives the plant a list of potential sources of credits. Next, the plant uses the list to call brokers/representatives to find a company willing to sell their emissions credits. If a sale occurs, a contract with terms and conditions would be drawn up. No actual review of trading transactions will be conducted as they occur; however, a yearly audit is expected. The SCAQMD will review and process permits. If they are acceptable, the SCAQMD does not need to get involved. The "new" source gets the emissions credits and the "old" source removes the credits from its ledger. The process can take from 30 days to 3 years. Under the currently-proposed South Coast program, money gained from sale of an emission credit is an off-book asset and is not taxable. California is working with the Internal Revenue Service on tax implications. . 25 ------- Session II Community Banks If community banks are adopted, one possibility would be to require larger sources to donate a small percentage of their credits to a community emissions credit bank. Small facilities could apply for credits from the community bank. It would be a "welfare bank" for those who could not afford to buy the credits, including municipalities. One suggestion was to allow each large source to contribute 1.2 percent of its credits into the community bank. The question of who can use the community bank is still to be addressed. Where Do Credits Come From? Presently, 85 percent of available emissions credits are expected to come from plant shutdowns. There are also opportunities to receive credits from retrofitting. Market prices will determine the cost of credits resulting from retrofits. Under the proposed SCAQMD program, existing sources can install additional control to receive tradeable credits. Allowing this type of credit should encourage the development of new technology. Although it is generally believed that the SCAQMD already requires such high levels of control that surplus credits are limited, further reductions and regulations have already been identified. The SCAQMD constituents or sources located in SCAQMD generally agreed that stringent baseline controls cause the burden to fall on large sources. The SCAQMD may include some restrictions on what qualifies as a shutdown. Geographical Restrictions/Meeting Reductions Schedule It is anticipated that the SCAQMD program will allow trading across geographical areas. However, this issue is not resolved. Industry does not generally expect the SCAQMD program to result in companies selling their credits and moving elsewhere, thus causing a migration of jobs out of the area. The SCAQMD plans to develop a monitoring program to flag when migration of emissions may become a problem. 26 ------- Session II California is looking at a 3-year "reconciliation" program for shifts in emissions. Emissions levels in various geographical areas will be examined every 3 years to determine whether regional shifts in emissions have occurred. The percentage annual decline can be increased if the reasonable further progress (RFP) requirement is not being met. If .SCAQMD wants to reduce emissions and stay on schedule for reaching attainment status, some argue that they should consider buying emissions credits and retiring them. Commodities/Overlap The proposed SCAQMD Marketable Permits Program may encourage quick use of credits to prevent hoarding. Because traders will probably have only 1 year in which to use their credits under the current proposal, a futures market is unlikely. It appeared that the SCAQMD Marketable Permits Program would apply to reactive organic gases (ROG) and nitrogen oxide (NOX), but questions remain about the applicability to air toxics. The Marketable Permits Program may overlap with maximum available control technology (MACT), new source performance standards (NSPS), lowest achievable emission reduction (LAER), best available control technology (BACT), or other technology-based standards. It is assumed that those facilities subject to technology-based standards will not be participating in the Marketable Permits Program to meet these technology standards. New sources and existing sources not subject to the above standards will be able to use the trading system under the current proposal. Facilities regulated under the National Emissions Standard for Hazardous Air Pollutants (NESHAP) for hazardous organic pollutants (HON) may be allowed to average emissions among emissions sources within a given facility. Market Failure Due to industry's ability to develop new technologies, it is unlikely that the market would fail. If baseline emissions (Ibs/unit time) are incorrect, they may be reallocated under.the proposed "reconciliation" program. It was generally believed that a market-based program can work, given that a sound regulatory approach and a workable enforcement program exist. 27 ------- Session II As an emissions trading program becomes larger in scope and transaction and administrative costs become higher, a less than perfect market structure is likely to develop. 4 Issue for Comment: One of the main issues facing SCAQMD is the trading of agency certificates versus allowance trading. OTHER PROGRAMS Canada is considering a market-based NOX trading program for Ontario and part of British Columbia. They are also considering a sulfur oxide (SOX) trading program. Houston, Texas, will start setting up a community bank for modifications or new sources. The Netherlands has a voluntary compliance program and an unsuccessful manure trading program. Futures are traded between dairy farmers and people who need fertilizer. However, transportation costs made this program unsuccessful. 23 ------- Session II MARKETABLE PERMITS MARKET MECHANISMS: Second Discussion Group INTRODUCTION Approximately 35 people attended the second discussion group on marketable permit mechanisms. Of these, about half were from State and local agencies. Industry, Federal, and service corporation participants made up the remainder of the group. While almost everyone contributed to the session, primary participants in the discussion were three economists, a representative of California's South Coast Air Quality Management District, and a lawyer. - HIGHLIGHTS Elements Crucial for Program Success Most participants agreed that the following key elements of a marketable permit program are crucial to its success. An emissions cap - preferably one that is well defined and stable over time. Differences in marginal control costs among potential participants adequate supply and demand. Well-defined property "rights" - term and quantity of permit, and provisions for banking. An adequate system for information dispersal and transaction recordkeeping. Adequate monitoring, tracking, and enforcement. There was a general consensus to define the commodity being traded as either "the right to emit" or "compliance opportunities." Uncertainties and Risks There was much discussion concerning the uncertainties associated with the marketable permit program, for both suppliers and consumers. Continual upgrading of program trade rules and emissions caps (which audit and monitoring results may show are necessary) may discourage emitters from participating. A risk-averse firm may opt for the perceived certainty of investing in BACT rather than "risk" buying credits in a potentially unstable market. 29 ------- Session II The group identified the following as potential sources of permit uncertainty (i.e., issues that may require program revision as more information becomes available): Incremental VOC reactivity factors. Ambient ozone impacts by location in air shed, time of day, and season. Monitoring technology. It was noted by several participants that some form of short-term grandfathering of permits may help to hedge risk. It was also generally agreed that the uncertainties and risks noted above are present regardless of whether or not a system is a market-based one. ~~ One major uncertainty associated with a marketable permits system is . transaction costs for potential participants. Several people speculated that an incipient program would only see trades within facilities at first. Inter- company and industry trades will become common only after companies become more comfortable with the new permitting system and more familiar with their own control costs and opportunities for further reductions. Equity Issues Equity issues discussed how initial permit allocations are made, burdens to new and smaller sources, stationary versus mobile sources, exclusions from the program, and potential monopolizing of permits. It was generally agreed that initial allocation rations (not quantities) should remain constant over time for equitability and market stability. No consensus was reached on potential inequities to new and smaller sources, though extending offset options to include mobile sources was mentioned. Most agreed that mobile sources should be integrated into a program to relieve the stationary source burden, if possible. Although most felt that the market would be strong and diversified enough to avoid monopoly problems, a few were skeptical. It was noted that new sources probably would not be more disadvantaged under the SCAQMD Marketable Permits Program than under current New Source Review (NSR). 30 ------- Session II Market Character and Effects A few anticipated that the continual decreasing of the emissions cap proposed in the SCAQMD program will drive up permit prices, allowing only the highest value operations to remain within nonattainment zones. Many others noted that this last speculation is highly dependent upon control technology innovations. Most agreed that even after most stationary sources have achieved their maximum control levels, the ever-present demand for offset credits by new sources may continue to force the development of new technologies to reduce emissions. There was general agreement that a marketable permits program should be a free market, open to speculators. The presence of speculators may help distribute information and thus achieve market equilibrium quicker than if the market were limited to a set number of participants. Also, most participants thought that a short-term (e.g., 2-year) banking limit should help minimize hording and other abuses (e.g., monopolizing). One person noted that the volume of trades alone should not be used to judge the success of a program. Emissions reductions should also be considered. FUTURE DIRECTIONS Areas requiring further study were addressed throughout the session on a topic-by-topic basis. Although there was no formal wrap-up at the session's end, there was general consensus of the group on future directions. The group generally believed that there are many uncertainties remaining, but most can only be resolved by establishing programs and tracking their results. How successful these programs will be in promoting control innovations is unknown. Administrative, enforcement, and transaction costs are all unknown. These costs must, however, be measured against the command-and-control approach costs (e.g., BACT analyses, legal costs, etc.) that are avoided. The costs of demonstrating compliance deserve a careful look. Regulators should watch for the development of environmental "hot spots," adverse impacts on small business dynamics, and the inability of bureaucratic systems to change with new and better information. 31 ------- Session 11 EMISSIONS TRADING PROGRAMS: ENFORCEMENT INTRODUCTION A group of about 30 participants discussed enforcement issues. This was a diverse group - including participants from State agencies, the EPA, environmental groups, industry, and special interest groups. The group agreed that enforcement will need to be different for a market-based regulatory approach. However, the suggestions expressed by individuals varied widely. Not much agreement was reached, but the discussion raised many questions and ideas for future research. HIGHLIGHTS The group agreed that there are many differences between Marketable Permits and Prescriptive Approaches. Individuals cited the following specific differences: Enforcement and compliance for a marketable permits program should differ from that of command-and-control type regulations. Emissions trading programs are not self-enforcing. Since market permits programs can trade credits or allowances, compliance needs to be high enough to enable them to be traded as commodities. Enforcement will change from source-by-source compliance measures (e.g., work practice, rate-based, technology standards) to compliance measures for the entire facility and massive emissions caps. Because compliance will not be measured directly from concrete and observable events, but will instead be measured after a series of complicated accounting events, new opportunities for violation may emerge, which may make violations harder to detect. Thus, increased accountability measures will be appropriate. If no new accountability measures are instituted, the number and types of violations will probably tend to increase. Examples were given from lead phasedown. The market-based approach needs tighter accountability. Because parties will rely on others' credits for their own compliance, trading programs will require more confidence in the accuracy of reported emissions. Better measuring methods are also needed. New requirements needed. Tracking of trading transactions. Feasibility of on-line computer monitoring. 32 ------- Session II Unlike command-and-control approaches, marketable permits programs will consider capacity utilization and hours of operation of the facility. Previous command-and-control regulations avoided limiting production. Cost/Benefit analysis should be different. In developing market-based programs, the EPA must consider whether the efficiency gains will be greater than the administrative cost increases necessitated by increased monitoring. The group generally agreed that costs would be different under the marketable permits approach. Individuals cited the following concerns and questions about costs: The costs of control may be lower for a market approach rather than for the current command-and-control regulatory scheme; however, the cost of monitoring measures may be much larger. How will this increased cost be assessed? Will enforcement costs be financed through emissions fees collected annually? Does a trade constitute a permit amendment? If so, what is the EPA's cost to review each transaction? Will penalties reduce incentives for facilities to remain in compliance? New industry will have to purchase emissions credits prior to operation before they can participate in the proposed SCAQMD Marketable Permits Program. All offset and NSR requirements will also apply. There was concern among some about how to deal with criminal enforcement. Individuals asked the following questions: Do existing criminal statutes apply, or would a criminal element need to become part of the code? Would the burden of proof shift to the regulatory agency to defend? Would individuals who knowingly violate SIP requirements be criminally prosecuted? How would falsification of records and bogus trades be penalized? Would holder-in-due-course sanctions apply to the buyer or would the seller be penalized when falsified or counterfeit emissions credits are traded? Will bulk of enforcement be civil enforcement, as is currently the situation? 33 ------- Session II The members of the group generally believed that guidance for averaging is needed. Individuals expressed the following concerns: Would daily, weekly, or 30-day averaging be required? A daily cap is more stringent, as books need to be cleared each day. If an upset occurs, the facility would have to buy additional allowances before midnight. With a longer averaging time, more people may be operating closer to their emissions cap, as the market will allow them to operate without a margin of safety. Will this cause aggregate emissions to increase? Several group members mentioned the emergency upset provision and questioned the interface with marketable permits. Specific concerns of individuals included the following: How will previously exempted malfunctions, upsets, shutdowns, and start-ups be treated under emissions caps? Will the EPA give only 80 percent compliance credit? Some thought industry in the SCAQMD seems willing to give up the malfunction/upset/shutdown/start-up exemption to get a longer averaging time period (monthly). Upsets (accidental, unexpected events) .are counted as violations under the CAA Operating Permits Program, but they can be used as defense in violation of an enforcement act. If upsets are used as a defense in violation of an enforcement act under the proposed South Coast Marketable Permits Program, then the market may not work. How should sources on the edge of the attainment/nonattainment areas be treated? California Edison, which is shifting its demand into an attainment area, is one such source. The market needs to be tight so that industries cannot invent "side games" to avoid compliance. Some thought the penalty under emissions trading should equal or exceed the market value of the permit plus its time value for the period of delayed compliance. If not, incentives to violate would be built into the program. 34 ------- Session II 4 Several group members had questions about recordkeeping. What frequency will be adequate? What happens if records are not there? Need sanctions for failure to monitor. How will "reportable quantity" be defined? The larger the quantity, the greater the need to adhere to the trading system. What triggers a violation? * Other group members were curious-how the SCAQMD Marketable Permits Program would be integrated with current regulatory requirements. They had the following specific concerns: What happens if an individual unit's emissions are in violation of its permit? Would mini-emissions caps be used? How will the SCAQMD Marketable Permits Program be integrated with NSR and prevention of significant deterioration (PSD)? In the California program, current regulations are not being eliminated; rather, exemptions can occur through permit revisions. Some group members questioned how public participation would be incorporated when using the SCAQMD Marketable Permits Program. They asked: How will public input be accommodated every time a trade takes place? Under Title V, the CAA Operating Permits Program, public participation is required for all new permits and permit modifications. This requirement means permit issuance will take time. Will this process be required for all marketable permits transactions? FUTURE DIRECTIONS Although many unanswered questions were raised during the first part of the group discussion, at the end, the group generally agreed on specific future directions needed to help address some of the issues. Certify nongovernment groups for monitoring. Publish a schedule of fees for various violations so penalties will be known in advance. 35 ------- Session II Develop protocols for measuring credits and evaluating emissions reductions. Work out legal details. Define what triggers a violation. Need to achieve near-perfect accountability for a marketable permits program to work. Evaluate the legality of netting emissions. Develop a protocol to show emissions are 5 percent less each year, even if no trading takes place. Set up a program; give it time to work to evaluate its performance. Make expectations realistic. Instill confidence in this new commodity. Industry is hesitant to buy emissions credits because they are not sure the program will work. 36 ------- Session II MARKETABLE PERMITS: TECHNICAL ISSUES INTRODUCTION Eighteen individuals participated in this small group discussion. The group was a diverse cross-section of Federal and State regulators, industry, and other groups. The group explored a number of technical issues that must be addressed if a marketable permits program is to be successful. The discussion focused on issues that have emerged in the development of the SCAQMD Marketable Permits Program. The issues of applicability, establishing baseline emissions, emissions averaging, quantification, design and implementation, regulatory considerations, and enforcement are outlined below. The group considered applicability and baseline emissions to be particularly critical issues to be resolved. In addition to technical issues, the group also discussed political considerations and adaptability issues impacting program implementation. HIGHLIGHTS Applicability Sources to be included in the SCAQMD program (one of the most important considerations). Comprehensive applicability including all sources is desirable, but potentially difficult to administer. There is limited authority to regulate area sources, which account for approximately 25 percent of the ROG emissions in the South Coast. Expanding the program's applicability to include new, mobile, and stationary sources is desirable, but difficult to implement. A larger universe of sources creates a better market for trading, but a more limited number is easier to manage. The universe of sources to be included in the program will be restricted by political reality, resources, authority, and enforceability. Size of a program primarily depends on available resources. Baseline Establishing both facility and SIP (district) baseline emissions is potentially problematic and raises the following questions. Will actual or allowable emissions be used? What baseline will be acceptable for SIP purposes? What recordkeeping systems are needed? How are fugitive emissions accounted for in the baseline? 37 ------- Session II Averaging What emissions averaging period will be used-monthly, quarterly, or annual? The EPA policy has been to perform daily averaging, but the SCAQMD Marketable Permits Program may propose periods ranging from 30 days to 1 year for emissions averaging. Annual reductions may be more consistent for determining RFP. On the other hand, long-term averaging may not capture varying emissions due to differences in production, and therefore must be demonstrated not to have a negative impact on the national ambient air quality standards (NAAQS). Feasible long-term approaches for achieving reductions through a marketable permits program include the following: Maximum daily emissions caps. Production/throughput limitations. Declining emissions caps. Quantification It was generally agreed that quantifying emissions is necessary to establish a baseline and to inventory progress. Reliable, credible quantifications for monitoring and enforcement are essential. Simplicity is a key requirement. If a market-based approach succeeds in quantifying total emissions, enforcement efforts could be greatly simplified. Design and Implementation Issues The VOC reactivity may need to be considered when designing a program and implementing emissions trades. The SCAQMD plans to track trades and any resulting shifts in VOC reactivity. Interpollutant trading is not allowed, and a one-to-one emissions offset ratio is being proposed for the South Coast. Should interpollutant trading be allowed? At what ratio? Trading across stationary and mobile sources needs to be addressed. Regulatory Considerations Relationship of a marketable permits program to CAA Air Toxics and NSR Programs. Conformity with CAA and State regulations, and existing SIP's. 38 ------- Session 11 Integration with existing programs. Does it preempt or supersede existing programs? How does a program relate to the CAA Air Toxics, and Operating Permits Programs, as well as to Reasonably Achievable Control Technology (RACT) and LAER requirements? Use of economic theory (marketable permits programs) to obtain emissions reduction through SIP's. Guidelines needed on the use of prescriptive command-and-controi approaches and/or market-based approaches to facilitate RFP and achieve attainment. State regulations should not preclude the use of market-based approaches. The long-term impacts of a Marketable Permits Program are not known, but some participants believed that the Marketable Permits Program would both reduce overall costs and force the development of improved technology to accommodate a decreasing emissions limit. Enforcement How are marketable permits enforced? Costs of penalties need to be directly related to severity of emissions. Political Considerations How to avoid creating disincentives when designing a program. How to build consensus with political, environmental, legislative, and public groups. How to distribute responsibility for emissions equitably across mobile, area, and stationary sources. How to change the perception of a marketable permits programs. Public tends to view programs as allowing industry to increase its emissions through trading. Adaptability Issues How big is the problem in other areas and can the marketable permits approach be adapted to fit the need? It may only be applicable for nonattainment areas. Can a program be designed for larger geographical areas, including multistate areas? What is the best balance between program simplicity and a larger district or multistate nonattainment area? 39 ------- Session II Have prescriptive command-and-control approaches been exhausted? What sources and emissions should be included? How good is the established permit system and monitoring approach? How precise does the measurement of emissions need to be? How will marketable permit programs interface with SEP's? How good is the current emissions inventory? 40 ------- Session II LOCOMOTIVE EMISSIONS TRADING INTRODUCTION The group discussion on Locomotive Emissions Trading was attended by approximately 20 individuals, from Federal, State, and industry organizations. Overall, the discussion did not focus on locomotive emissions trading, but rather on mobile source emissions trading in general. The bulleted points are, in general, the opinion of the individual commenter, and not necessarily the consensus of the group. HIGHLIGHTS Scope Issues Transportation is composed of two groups: goods and people. The transport of goods must be handled differently from the transport of people. Locomotive emissions trading should be considered in the broader scheme of mobile sources. Ideas for transporting people include making alternative transportation mechanisms cheaper and more convenient, and making automobile companies responsible for their fleets. However, some thought quantifying emissions could be a problem if auto manufacturers are responsible for fleet emissions. Lack of maintenance and tampering can" increase vehicle emissions. Transportation of goods should focus on efficiency of transportation. Compare the efficiency of airplane, truck, and car transport to train transport. Consider transporting freight from city to city on trains instead of trucks. Breadth of program (global vs. local) should be considered. The bigger the bubble, the more cost effective, but the more complex. For example: If we start with smaller, local programs, we could then see the bigger picture and try to fit the programs together. Starting with the big picture disregards all the unique, area-specific characteristics of local structures. The politics far exceed the technical issues. 41 ------- Session 11 Regulatory Issues Adding market incentives on top of command-and-control programs raises certain concerns: It could be inefficient and more expensive. Industry may not be able to afford inefficient pollution control programs. Industrial plants leave areas that are too expensive. Many do not fully trust market incentives. Skepticism keeps regulators from leaping towards a market-based program. Regardless of inefficiency, however, adding market-based incentives to command- and-control programs will probably be an improvement. Small steps to a market-based program rather than an immediate changeover will be necessary. Contradiction may exist between requirements of command-and-control and market-based programs. Market-based programs will require associated mechanisms to avoid the constraints associated with the CAA (i.e., RACT approval requires 2 years for review; yet, meanwhile, trading is occurring). Regulatory uncertainty. Some people believed there is more regulatory uncertainty associated with command-and-control programs than with market- based incentive programs. Instead of worrying about a new standard being created, industry has flexibility to act according to what the market dictates. However, others pointed out that regulatory uncertainty also exists with market-based incentives, but in different forms. Any regulation has its associated uncertainty. Local versus State control. Even though local agencies would rather control their local (basin) programs, the State needs to control mobile source programs because they cross local boundaries. Use of mobile source emissions reductions as offsets for stationary sources: the offset program probably should not require exact emissions (i.e., estimates will have to do). Penalties must be very high for cheaters in order to avoid program misuse. Market strategies for mobile sources may need more latitude than is seen in stationary source market programs. One participaQt offered the idea of allowing an offset program within existing . TCM's. Specifically, the participant suggested a consortium of businesses that would spend their TCM monies on an emissions reduction program such as electrifying mass transport rather than trying to coerce their employees to carpool, etc. 42 ------- Session II Geographical Issues Topography changes, geographical differences, location, and timing make creating a bubble over mobile sources difficult. Consider putting a bubble over a route instead of over an area (basin). However, California needs to put bubbles over a basin to control localized air pollution problems. Equity Issue In establishing a locomotive emissions trading program, no advantage should be given to those who have not tried to clean up their emissions in the past. Safety Issue May be conflicting objectives. For example, adding a car to a train for safety purposes might conflict with a goal to reduce emissions. 43 ------- SESSION m OTHER INNOVATIVE STRATEGIES FOR AIR POLLUTION CONTROL 44 ------- 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 ------- 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 ------- Session III EMPLOYER-BASED TRIP REDUCTION PROGRAMS INTRODUCTION Twenty-eight individuals from various organizations participated in this small group discussion. Several programs to reduce single occupancy vehicle travel were highlighted: SCAQMD, Pima County Association of Governments, Bay Area Economic Forum, State of Washington, and University of Washington. While some participants believed that employer- based programs were not the most effective method of reducing emissions, others emphasized that mandated trip reduction programs are relatively easy to develop, and that they do encourage other beneficial changes in individual behavior. Political considerations and technical issues impacting program implementation were also discussed. HIGHLIGHTS 4 Additional Information About the SCAQMD Employer Trip Reduction Program An on-site coordinator is required. The coordinator usually is someone who has other responsibilities and only devotes part of their time to coordinating the Trip Reduction Program. This requirement was controversial. A staff of 33 is required to review the implementation plans, which usually takes 2 to 3 hours per plan. . Approximately 7500 plans per year are submitted. With preliminary information, SCAQMD estimates company costs at $40 to $1000 per employee per year. 4 Technical and Program Design Issues of Employer-Based Trip Reduction Programs Employer-based programs have a limited span of control. They do not reach the 70 percent of trips that do not involve commuting to and from work. Trained staff should be available when a program is implemented. Nonsolo driving options should be rewarded proportionately to their ability to increase Average Vehicle Ridership (AYR). Elected, private sector review boards enhance the credibility and success of the travel reduction program. A guaranteed ride home should be available to anyone using an alternate transportation mode; otherwise trip reduction programs may be subject to union activity for benefitting some workers and not others. 47 ------- Session III Options to driving a single occupancy vehicle need to be available before a travel reduction program is implemented. Employer incentives become an employee benefit in some circumstances and thus are taxable. Changes in individual behavior are difficult to achieve and are most likely to occur when there is a change in an individual's life, such as moving or switching jobs. Rewards also motivate behavior changes. Implementing trip reduction programs is more difficult in areas where there is no mass transit system. Whether a well-developed mass transit system exists significantly impacts whether innovative travel reduction programs are successful. Gains in trip reductions have been achieved through ridesharing. Telecommuting Jias also been effective in some areas. Determining the baseline against which to measure travel reductions can be problematic. The Metropolitan Planning Office initially set the AVR for the Los Angeles area, but the SCAQMD is now building a database on which to base AVR. Census Bureau data and specific employer data were used in Seattle. Political Considerations For programs to be equitable, previous good environmental behavior needs to be rewarded. To use 1992 as a baseline year for AVR would ignore the past efforts of employers to reduce ridership. Authorities are influential in shaping program development. Developing programs that are legislated are easier than developing programs that are not, but legislated programs may not be the most effective. Some participants believed that employer-based trip reduction programs were not the most effective or appropriate approach to reducing air pollution. There is evidence, however, that changes in behavior resulting from employer-based programs may be transferable to other decisions that individuals make. Motivating individual and group behavioral changes is difficult, but a key factor in achieving program success. Federal laws taxing emplgyer benefits and allowing collective bargaining can impact employer-based programs. 48 ------- Session III Impacting mobile source emissions, the largest source of some emissions, is difficult. Mobile source emissions result largely from individual behavior, but sufficient political and economic factors to encourage reaching the individual are not currently available. It is questionable whether employers should be accountable for employee behavior outside of the workplace. Air regulatory standards need to be attainable. For example, SCAQMD would have to achieve 60 percent nonsolo ridership by the year 2010 in order to meet CAA requirements. They currently are at 4 percent, and expect implementation of a mass transit system to increase nonsolo ridership to 10 percent. - Collaboration of industry, labor, transportation planners, and the regulated community is essential for program success. OTHER PROGRAMS + Pima County Association of Governments The Pima County Association of Governments is the Metropolitan Planning Organization (MPO) coordinating the local ordinance based Travel Reduction Program for the Tucson regional area. The 1988 local ordinances require that employers with more than 100 full-time equivalent employees at a site to participate in the travel reduction program to increase employee alternate mode usage and decrease vehicle'miles traveled in the daily work commute. Program began in 1989. In its third year, the alternate mode usage has increased by 20 percent and the weekly vehicle miles traveled have decreased by 3 percent. Local employers use a combination of approaches to reduce employee ridership. Approximately 180 employers are involved. A key feature of the program is an elected task force of employer participants that establishes policy and reviews appeals. Yearly costs to implement the program are estimated to be $13 per employee for the corporation and $4.50 per plan for the government. Fixed administrative costs account for 70 to 80 percent of the expenditures, while approximately 25 percent of the costs are variable. 49 ------- 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 ------- Session III UNOCAL OLD CAR BUYBACK PROGRAM INTRODUCTION The group discussion on the Unocal Old Car Buyback Program was attended by approximately 50 individuals from Federal, State, and industry. The discussion focused on the logistics of this program, including its strengths and weaknesses. There was also discussion on if and how the program might be adopted in different States, given regional differences. The group did not come to a consensus as to the overall effectiveness of this program for offsetting emissions. HIGHLIGHTS 4 Clarification by Unocal representatives on the SCRAP Program. Gasoline was drained and sold; fluids, batteries, and tires were removed. Exhaust systems were removed in cars to be recycled to prevent lead contamination. Hydrocarbon emissions at the tailpipe ranged from 2 grams per mile to 87 grams per mile. Program seemed to be best suited for regions with the following characteristics (e.g., Southern California, Houston). Moderate climate (no salt on the roads). Wide range of income distribution. High stationary source control costs. Instead of receiving emission credit for this project, Unocal received a compliance extension. In a separate incident, a California cogeneration plant scrapped 50 cars in response to a court settlement for an emission violation. The program bought cars that were manufactured before 1971 (California had no NOX standard then). Remaining Questions How might a SCRAP program be combined with an I&M program? Maintenance fees could provide an incentive to scrap cars. How many cars were headed to the junk yard anyway? Did this program remove any additional ones? 51 ------- Session III Other possible years to choose for the program could have been pre- 1975, when catalytic converters were added in California. Catalytic converters were required in other parts of the country in 1975 or 1976. Use of remote sensors as an alternative to the SCRAP Program. Remote sensors could be tested under normal driving conditions at a cost of about 50 cents per test. Based on this screening, high-emitting cars could be scrapped or repaired. This approach would target high-emitting cars instead of just old cars. Concern was expressed that the remote sensors are not completely reliable because they measure emissions under uncontrolled conditions. Concerns about SCRAP and similar programs. Vehicles taken out of circulation might be replaced with imports from neighboring States. The SCRAP program could work in Los Angeles, a major city, where the mountains and other terrain provide geographical isolation. Program might not work in a State such as Tennessee, which is easily accessible by other States. In the SCRAP study, cars were considered not to be in the retirement stage if they could be driven and if they were registered. Is this pilot test statistically valid considering the uncertainty surrounding whether many of the cars would have been retired anyway? A way to find out Would be to sign up a certain number of vehicles, scrap a few, and then hold a lottery on the remainder. A longitudinal study on the remainder could be done to determine the fate of the remaining cars. Are they taken to the junkyard? How much longer are they driven? Both small-volume and long-term programs can be problematic. The Unocal program, was implemented quickly and only lasted a short time, so people did not have time to abuse the program. Long-term programs would allow people to have time to exploit the program. Choice to consider only old cars was questioned. New cars can have high emissions not only due to neglect of maintenance and tampering, but also because they are driven more. Did the program actually take any cars off the road? First people who volunteer would be scrapping their cars anyway. 52 ------- 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 ------- SESSION IV DIALOGUE ON ISSUES LEADING TO FUTURE RESEARCH 54 ------- Session IV DIALOGUE ON ISSUES LEADING TO FUTURE RESEARCH AGENDA The following list is a summary of ideas expressed in the general discussion session on issues leading to future research. The list is organized only by topic; there is no prioritization of ideas nor agreement on the feasibility of accomplishment within a meaningful timeframe. Approximately ninety persons participated in this session. The discussion was conducted as a "brainstorming session." Thus, an attempt has been made to report all ideas expressed on the "next steps" in the further development of innovative regulatory strategies. HIGHLIGHTS > Taxes and Fees Need to estimate elasticities of substitution for inputs and elasticity of demand for emissions. Need to get data and set baseline emissions for taxes. Evaluate how to implement rulemaking and statutory processes. Determine how to select the process to establish the program. Assess how to value and monetize environmental externalities. Utility sector efforts to evaluate environmental costs and benefits, as well as regulatory impacts, may be useful. Examine how often to change the structure of, and taxes for, the program. Are tax revenues politically acceptable? Would use of a revenue-neutral tax plan be appropriate? The proper universe of sources to achieve maximum impact needs to be determined. How do taxes impact various segments of the population, especially the poor? Income tax implications of parking fees should also be identified. A mechanism linking fees to emission reduction goals is needed. Better program evaluation, including baseline data and progress over time, is needed. 55 ------- Session IV Fees should support both the infrastructure and the development of services that those who pay fees will use. The academic and economic community should be involved in applied research. If a good mass transit system is in place, parking fees can be externalized; the amount of fees should reflect the real value of the parking place. For example, a car in which three people rode should cost less to park than one in which one person rode. Establish the relative net levels of classes of pollutants so that proposed rates will reflect proportional changes. The link between land use and transportation needs to be recognized; a land use fee may be appropriate. The interface between the CAA, the Transportation Act, and SIP planning should be carefully examined. Air quality regulators should be involved; all planning should not be done by transportation managers. The Federal highway bill has provisions that may be used to assist in achieving air quality goals, and should be utilized. Marketable Permits The EPA's BACT/LAER Clearinghouse is a useful source of information. Social, behavioral, political, and operational differences between command- and-control and market-based approaches need to be considered. A government's role in establishing market-based programs should be to define the market, help start the market, define market success, and intervene when early indications of problems appear. An analysis of all social costs of a market-based approach, including who is bearing the costs, should be conducted to ascertain that no group is unfairly impacted. 4 A strategy to include mobile and area sources, as well as stationary sources, in marketable permits programs needs to be developed. Research into long-term, market-based approaches is not viable at present. It should not be assumed that command-and-control approaches have a higher probability of success than market-based approaches. 56 ------- 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 ------- APPENDIX PARTICIPANT LIST ------- ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- DUF ------- |