Interstate Air Pollution Flashcards
Interstate Air Pollution
- one of the og justifications for the CAA but not really until last couple of decades that it kicks in
- very challenging - tough to figure out what state is doing what and how much
Tall Stack Phenomenon
- designed to meet in-state NAAQSs cheaply (by sending to other states)
- super tall stacks, + figured out intermittent controls so would only run the power plant when wind blows in a certain direction
- Congress responds w/ 1977 amendments - you can have the stacks, but you don’t get credit for them in efforts to reduce air pollution (no credit for intermittent controls or stacks over a certain height)
Section 110(a)(2)(D)
- Clean Air Act Amendments 1990
- says that SIPs need to “contain adequate provisions prohibiting “any source” “from emitting any air pollutant in amounts” which will “contribute significantly” to nonattainment in another state
Section 126(b)
- deals with Interstate Pollution Abatement
- allows states to petition if they think another state is messing with their attainment or maintenance of NAAQSs
Tradeable Emissions - Cap/Trade
- multiple states with downwind effects may mean fungibility -> cap and trade system might be effective
Opportunities:
- bring existing sources into regulatory fold
- create market to take advantage of lowest cost reductions
- address bottom line amount
- promote economic efficiency
Cap and Trade - General Concept/Advantages
- FUNGIBILITY KEY
- cost-effective - may cost more for some facilities to reduce their emissions, and cap and trade can allow you to achieve the same level of reduction at a lower cost (those for whom it’s more expensive will buy reductions from others)
- better to let the market figure it out than try to set out definitively which is most cost-effective
Challenges of Cap and Trade
- determine overall amount emitted
- determine overall reduction required
- address nonfungibility issues
- allocation: auction vs give away
- monitor
- possibility of weird incentives (companies may pollute max amount possible)
Section 176A
- Interstate Transport Commissions
- EPA can establish a “transport region” if it determines interstate transport of air pollutants from one or more states in the region contributes significantly to violation of NAAQS in one or more other states
- can establish Transport Commissions for those regions -> the commissions can recommend measures and request a SIP call (request that EPA issue a finding that a state’s SIP is substantially inadequate)
Major EPA Interstate Pollution Initiatives
- Acid Deposition CAA Title IV (Bush I)
- NOx SIP Call (1998, Clinton)
- Clean Air Interstate Rule (2005, Bush II)
- Cross State Air Pollution Rule (2011) (Obama) (“Transport Rule”)
Acid Deposition
- Midwest to Northeast -> the 111 “Big Dirties” causing major harm to forests + paint on buildings in NE (lots of ecosystem + property damage)
- Bush defeated logjam in 1990 CAA amendments -> creates Acid Deposition program (found a way to reduce acid in a way midwestern industries found pallatable)
- TITLE IV DEALS WITH ACID DEPOSITION CONTROL
Acid Deposition - Nationwide Cap
- plan to reduce SO2 by 10M tons per yr below 1980
- reduce NOx by 2M tons per yr below 1980
Acid Deposition - Phase 1
1990-2000
- designed to achieve half of all emissions reductions sought
- applies to largest coal-fired power plants (>100MWe)
- allocation of pollution allowance to plants based on SO2 emission rates of 2.5 lbs SO2 per million BTU produced
- plants can buy and sell allowances (although allowances explicitly not a property right)
- bonus allowances for certain technologies and locations
Acid Deposition - Phase II
Begins in 2000
- adds additional industrial sources (>75 MWe)
- allowance formula reduces from 2.5 lbs SO2 per million BTU to 1.2 lbs SO2 per million BTU
- bonus allowance provisions for “clean coal technology,” to ease transition in 10 Midwestern States and reward cleaner states
Successes of Acid Rain Program
- cost of compliance dropped dramatically (cost of scrubbers down, encouraged energy conservation as well as fuel shift to low sulfur coal)
- smaller plants opted into Phase 1 (trying to take advantage of market)
- 2005 - Cost benefit ratio found to be favorable - estimated 40:1 bens to costs (bens $122B annual)
- achieved 40% plus reduction since 1990 by 2006
Ozone Pollution
- secondary pollutant
- created by other emissions in the atmosphere that combine
- no company actually emits ozone, they just emit volatile organic compounds and NOx that react when there’s heat to produce ozone