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CAIR Frequent Questions — Meeting State Budgets

Q: Where can states find the list of modeled units included in the final CAIR?

A: You may find the list of EGUs modeled in CAIR on the NEEDS section of the Intergrated Planning Modeling page. NEEDS stands for the (National Electric Energy System) Database for IPM 2004.

Q: Can states withhold allowances (NOx) to effectively create a tighter program? Will EPA continue to administer the trading program?

A: EPA believes that the state caps set in CAIR already represent the appropriate amount of cost-effective reductions in NOx emissions required to prevent significant contribution to non-attainment through transport of emissions to downwind ozone and PM 2.5 non-attainment areas. EPA is not encouraging States to withhold or retire allowances to create a tighter program. Where necessary, the Agency believes that the States should be looking at lowering emissions of other sources of NOx given the large amount of reductions the power industry is already making. However, CAIR does not prohibit States from creating a tighter program, and the Clean Air Act generally authorizes States to adopt requirements more stringent than federal requirements. EPA suggests that States interested in adopting tighter requirements for EGUs consider the need for this based on the modeling and analysis done by States for general attainment planning. In every case, the State SIPs must include control measures and demonstrate that the measures will allow the State to meet its State budget. (See preamble discussion at 70 FR 25162, 25256-63 (2005) and §§ 51.123(e) and (q) and 51.124(e).) While EPA has committed to administer the CAIR trading programs in order to efficiently and effectively eliminate significant contribution through transport of these emissions, EPA has not made a commitment to administer more aggressive NOx trading programs.

Q: Would EPA allow states with very low CAIR allocations (NOx) within that group to trade even if the overall emission rate for the group is higher than the effective CAIR rate for those low allocated states?

A: States may include non-EGUs that were part of their SIP Call trading program in the CAIR ozone season NOx Trading Program regardless of the overall emission rate for that group of sources.

 


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