" APPLES FOR ORANGES" ( AFO)

Version 2: THE FOUNDATION of CAP & EARN OPEN MARKET, INTERPOLLUTANT EMISSIONS CREDITS TRADING Proposed by Robert C. Dalton. Environmental Marketplace Consultant And Vice President of Business Development and Government Affairs ESTEC Enterprises, Inc.

November 10, 2002 In South Carolina In New Jersey P. O. Box 1212 455 Ocean Blvd. # 27 Clemson, SC 29633 Long Branch, NJ 07740 Contact by e mail: rcd2001@ earthlink. net Contact by Cell Phone:

1 732 222 4149  i

i Forward Between 45,000 and 75,000 local smokestacks of manufacturers in local communities nationwide can have their ozone precursor and hazardous air pollutant emissions reduced by over 90% with a Cap &

Earn emissions credits trading program that is based upon this " Apples for Oranges" ( AFO) proposal.

An open market, interpollutant emissions credits trading program with an emissions cap such as Apples for Oranges or Cap & Earn would use the market value of the multipollutant emissions from coal fired power plants to reduce emissions of ozone precursors and hazardous air pollutants from local manufacturing plants prior to or in conjunction with reducing multipollutant emissions from the older coal fired power plants. The amount of manufacturing facilities that can have their ozone precursor emissions reduced by 90% under an open market, interpollutant emissions credits trading program is staggering. In South Carolina alone, the market value for the nitrogen oxide ( NOx) emissions from these older coal fired power plants can reduce 90% of the ozone precursor and hazardous air pollutant emissions from over 3000 smokestacks of manufacturers in local communities.

The best incentive for incresing air quality is to allow for power companies to competitively increase market share with an environmental agenda.

The incentive is the electricity marketplace. The current market for electric power generation is between $ 200 billion and $ 300 billion per year. One percent ( 1%) of market share has a value of $ 2 billion to $ 3 billion dollars. The value of 1% market share of the electric power marketplace is almost greater than the entire annual pollution control marketplace for air emissions from non power plants sources. This large dollar value should provide electrical utilities enough incentive to aggressively reduce their customers' emissions of ozone precursors and hazardous air pollutants, creating a greater reduction in ozone forming emissions nationwide and, most importantly, in local communities. The entire dollar value to deliver electricity in the electric utility marketplace is greater. The entire marketplace  ii

ii not only includes power costs, but transmission and distribution costs also. The entire electric utility marketplace is much greater than $ 500 billion dollars.

The Apples for Oranges proposal is the foundation for a Cap & Earn open market, interpollutant emissions credits trading program with an emissions cap. Essentially, Apples for Oranges ( AFO) is an emissions credits trading program that calls for State and Federal governments to allow trade between ozone precursors emissions, volatile organic compounds ( VOC's) and nitrogen oxides ( NOx). AFO is an interpollutant emission trading program. Also, the proposal includes trading of hazardous air pollutants ( HAP's) and sulfur dioxide emisions. In the proposal, emissions trading focuses on local air quality and the reduction of ozone precursors that are consider " hot spots" due to emission of HAP's.

Cap & Earn's and AFO's interpollutant trading program is unique. Interpollutant trading is a profound change to the Nation's current emission credits trading programs. Cap & Earn and AFO would allow for a true free market of emission credits trading that is based upon greed. The greed of power companies that desires more profits from increased market share.

This proposal is written for a wide audience. The proposal is intented to educate the new comer to emission credits trading and provide details on key issues that would effect the success of emissions credits trading programs for experts and regulators.

The concept behind " Apples for Oranges" and Cap & Earn has been said to have merit by one the leading experts in emissions credits trading, and currently, the USEPA is studying their own version of " Apples for Oranges" emission credits trading for trading diesel particulate emissions reduction ( emission credits) for NOx emissions. It appears that the " Apples for Orange" concept is ready to unleash free enterprise to improve our nation air quality.

The author of this " Apples for Oranges" proposal has spent over 10 relentless years studying and observing deregulation of electricity, emission credits trading and environmental laws and regulations.  iii

iii Table of Contents Chapter Page 1 Definitions ..................................................................................... ........................................ 1 2. Background............................................................................... ............................................. 2 3. In Step with the Concerns of the the Local Community............................... ....................   5 4 AFO Helps to Stop the Spread of Ozone Precursors   ..               .. 9 A. Smokestack Height........                ..............................  11 B. Dilution Methods with Fans and Blowers....................................... ...........     . 12 C. " Skipping to the Next County"........................................................ ............... .......  13 D. Expansion by Duplicating Facilities                     . 15 5. The Best Incentive to Reduce Emisisons and Increase Air Qualilty.............................  .. ... 17 6. An Estimated 45,000 to 75,000 Smokestacks Can be Cleaned ( based upon USPIRG Data)....  21 1. Real Life Scenarios: Interpollutant vs. Intrapollutant Emission Credits Trading  .......  .... 26 A THE CITY AND DIESEL PARTICULATE An Urban Approach to Better Air Quality                   ...... 28 B THE POWER OF A LARGE CONSUMER  A CUSTOMER APPROACH         . 29 A Tire Manufacturer in South Carolina C. CREATING JOBS IN AN ECONOMICALLY DEPRESSED REGION ........................     30 Camden, NJ Needs Industry. D. PREVENTING A LOSS OF JOBS  A COMMUNITY EFFORT ...................................     32 Boat Manufacturers and Other Manufacturing Facilities, Atlantic County, NJ E. THE POWER OF A LARGE CUSTOMER  AN ELECTRICITY PROVIDER APPROACH ... . 34 An Automobile Manufacturer in South Carolina F. COMPANY EXPANSION  EXERCISING OPTIONS ..............................................   35 Commercial Bakery in Bergen County, NJ G. POWER OF THE LARGE CUSTOMER AND ITS SUPPLIERS ...................................  37 A COOPERATIVE APPROACH TO CLEAN AIR An Automobile Manufacturer and Regional Parts Suppliers in South Carolina 8. Establishing Reasonable Guidelines for Interpollutant Emissions Credits Trading ........  ..  39 A. Guidelines for Trading Between Pollutant Species: Air Toxins ( HAP), NOx, VOC, and ( SOx)  40 B. Guidelines for Emissions Reductions from Utilities and Industry ........................................   43 C. Addressing the " Hot Spots" Issue. ..............................................................................................  44 D. Geographic Scale for Trading      .................................................................................. 45 E. Federal and State Oversight of Air Quality Management ................................................................ 46 F. Ensuring Credible Record Keeping and Monitoring ........    .................................................. 46 G. Fractional Energy Trading ...........................................................      ............................. 46 9. Summary of Key Points............................................................................................  ......... 48 10. Appendices                                   53 . Appendix A: USPIRG Data and Calculations ................................................................ ... 53 Appendix B: Proposal to Rep. Lindsay Graham, R SC ........................................................... 56 Appendix C: E mail from Dr. Bruce Yandel ........................................................................ 57 1 1 Chapter 1 Definitions Ozone Precursors   Ozone Precursor are chemicals that react with the sun's ultraviolet energy at a certain temperature and atmospheric conditions to cause pollution related to the formation of ozone. Common ozone precursors are volatile organic compounds ( VOC's) and nitrogen oxides ( NOx). These chemicals are emitted from automobiles, stands of pine trees, sewage treatment facilities, industry and coal fired and gas fired power plants. When ozone reaches a certain levels in the local atmosphere, ozone can trigger breathing difficulties in people who are sensitive to ozone.

Interpollutant Trading  Interpollutant trading occurs when one type of pollutant credit is traded for a different type of pollutant emission. Nitrogen oxide ( NOx) emissions credits are traded for volatile organic compound ( VOC) emissions. Sulfur dioxides ( SOx) emissions credits are traded for carbon dioxide ( CO2) emissions.

Intrapollutant Trading  Intrapollutant trading occurs when a specific type of pollutant credit is traded for the same pollutant emission. Nitrogen oxides ( NOx) emissions credits are traded for nitrogen oxide emissions ( NOx) only. VOC emissions credits are traded for VOC emissions, only.

Open Market with Interpollutant Trading ( Apples for Oranges)  Pollution reduction is accomplished by interpollutant trading. Emission credits for one type of pollutant can be traded for another type of pollutant emission. The trading can occur between different industries. A VOC credit from a manufacturer can be traded for a NOx emission from an electrical utility. This is an example of interpollutant emission credits trading.

Open Market  Emission credits for a specific pollutant can be traded between different industries. Example: NOx credits are traded for NOx emissions, between an electrical utility and a manufacturer. A NOx emission credit cannot be traded for any other emission type such as a VOC, SOx or etc. This is an example of intrapollutant emissions credits trading.

Multipollutant Approach  ( For Electrical Utilities Only). The main emissions types from electrical utilities, ( mercury, nitrogen oxides, sulfur dioxides and carbon dioxide) would have one reduction target and program for a specified pollutant. NOx emissions credits are traded for NOx emissions. SOx emissions credits are traded for SOx emissions. The Multipollutant Approach is limited to coal fired power plants at this time. This is an example of intrapollutant emissions credits trading program.

VOC  Volatile Organic Compound. A regulated group of organic species that are emitted from industrial and commercial processes. Volatile organic compounds can contain chlorine atoms. A VOC is more strictly regulated if the compound is considered a hazardous air pollutants ( HAP). 2 2 Chapter 2 : Background 3 3 Chapter 2 BACKGROUND Apples for Oranges ( AFO), an open market, interpollutant emissions credits trading program with an emissions cap, is an incentive method for cleaning the environment without substantially effecting economic growth of our nation, focusing on the local environment and economic growth of a community. The program was originally introduced last year in Washington, DC. Apples for Oranges' open market, interpollutant emissions trading provides healthy, clean air for a community whether the community is an urban area in the Northeast or West or a manufacturing area located in the Southeast, Midwest or Northwest. Open market,

interpollutant emissions credits trading provides an enormous amount of flexibility for communities and businesses to produce a healthy environment. Aggressive incentives for power companies are used to increase air quality by decreasing the emissions of other companies. The biggest incentive for the power company having business from a customer. Other incentives can contain obligations such as decreasing carbon dioxide emissions through increased efficiency and renewable energy requirements as well as target reductions for mercury, sulfur dioxide and nitrogen oxide emissions. These additional incentives would be generally used to try to create a concensus between the environmental community, individuals, industry and power companies.

Open market, interpollutant emissions trading with an emissions cap produces a shift in the present way power companies, industrial and commercial sectors, environmentalists and the community are grouped in the eyes of society. This shift is illustrated below:

Current View Emission Producers Community ELECTRIC UTILITIES RESIDENTIAL CUSTOMERS MANUFACTURERS ENVIRONMENTALISTS COMMERCIAL BUSINESSES 4 4 Interpollutant Emissions Trading Electricity Producers Electricity Consumers ELECTRIC UTILITIES RESIDENTIAL CUSTOMERS ENVIRONMENTALISTS MANUFACTURERS COMMERCIAL BUSINESSES The change in grouping from emissions producers and community to electricity producers and electricity consumers allows for the environmental marketplace to be polarized with an economic weight never before seen in any other environmental regulatory program. This change is beneficial for both the local community, manufacturers and the power industry The proposed target reductions by open market, interpollutant emissions credits trading with an emissions cap, are greater than any other proposed emissions trading program or regulatory method in our Nation. The long term national goal of Apples for Oranges interpollutant emissions credits trading is to reduce two thirds ( 2/ 3) of all present day air pollution by almost ninety percent ( 90%) in the next ten years and almost ninety percent ( 90%) of air pollution for new sources. This two thirds ( 2/ 3) of all air pollution emissions are from power generators, industrial manufacturers and commercial businesses. The Apples for Oranges open market, emissions credits trading program with an emissions cap, which is called Cap & Earn,

provides the best incentive ever for the power industry to reduce pollution nationwide, while focusing on air quality in local communities by reducing emissions from local manufacturers and transportation sources. 5 5 Chapter 3 IN STEP WITH CONCERNS OF THE LOCAL COMMUNITY 6 6 ENVIRONMENTAL QUESTIONS FOR LOCAL COMMUNITIES There are two fundamental questions that communites have to the right to ask themselves with regard to their leaders choosing a Federal or State environmental protection program either through administrative regulation or Federal or State laws made by their legislative branch. The first question to ask families is:

1. " If they have a choice between having the ozone precursors or hazardous air pollutants from a manufacturing facility next to their homes reduced or emissions from the a power plant over 100 miles away reduced, which would they want?"

The other fundamental question answered is:

2. " Should Federal and State regulations and laws provide opportunity for communities to choose between reducing in air pollution from local sources and reducing air pollution from source hundreds of miles away?" 7 7 The answers to these two questions are obvious, and would be:

1. Families would want the local industry cleaned. 2. Laws and regulations should allow for a choice between local and distant reductions in emissions to be made by local communities.

An open market , interpollutant emission credits trading program with a cap, such as Cap &

Earn and Apples for Oranges, provides opportunity for local action. On the Federal level, there is a strong difference. Federal environmental action tends to focus on distanst action for emissions reductions in local communities.

On the National level, the US Senate and USEPA have a multipollutant approach for power plants and ozone precursor emissions reduction. Both the Bush Administration and the US Senate proposed a multipollutant reduction strategy with intrapollutant species trading, not interpollutant species trading. In 2001, the U. S. Senate introduced the Clean Power Act which addresses reductions in sulfur dioxide ( SO2), nitrogen oxides ( NOx), mercury and carbon dioxide ( CO2)

emissions by 2007, whereas the Bush Administration's Clear Skies Initiative proposed a timetable for its multipollutant emissions reduction limits to be met by 2010 or later. Neither of these Federal initiatives for emissions reduction regulations focuses on strategies specifically designed to improve local air quality. Both the US Senate's and USEPA's approach rely on intrapollutant emissions trading which are designed primarily for emissions reductions from coal fired power plants far away from local communities. A balanced approach is needed. This balanced approach should address transient emissions from distanst coal fired power plants and the emisssions in the local community.

Cap & Earn and Apples for Oranges ( AFO) seeks either a balance between local and distant emissions reductions or an initial amount of emissions reductions that focus on local 8 8 action. Using an interpollutant emissions trading system, hazardous air pollutants ( HAP) can be removed from communities more readily than with current and proposed trading systems. Theses hazardous air pollutants commonly can be volatile organic compounds that are ozone precursors.

The Cap & Earn and " Apples for Oranges" emissions credits trading program uses the market value of the large amount of ozone precursor emissions from coal fired and gas fired power plants such as NOx as a driving force for reducing ozone precursor emissions from sources in local communities which emit hazardous air pollutants and volatile organic compounds.

Neither the Bush Administration's Clear Skies Initiative nor the U. S. Senate's Clean Power Act addresses the issue of local air quality in terms of hazardous air pollutants and ozone precursors. This is wrong. The Federal programs do little to promote improved local air quality,

but instead promotes measures by industry that are designed to shift precursor ozone emissions about the local communities. These methods will be discussed in the next Section.

Air quality is local, so local control of precursor ozone air emissions should take precident over distant air emissions. Local control should be integrated with national air quality initiatives for local economic growth. A Cap & Earn emissions credits trading program provides local control of air quality and allows for economic growth.  9

9 Chapter 4 CAP & EARN HELPS TO STOP THE SPREADING OF OZONE PRECURSORS  10

10 Chapter 4 The Cap and Earn emissions credits trading program is designed to help stop the spread ozone precursors by legal methods that are commonly employed by environmental engineers and environmental lawyers to improve of local air quality, but these methods spread ozone precursors about a State. These common spreading methods are known as 1) smokestack height, 2) dilution with fans/ blowers, c) skipping to the next county and d) expansion by duplicating facilities. While these methods that spread ozone precursors about the community can be effective in reducing ozone precursors locally, nothing stops these ozone precursor that are emitted into the local atmosphere from being carry by wind currents to adjacent communities with poor air quality.

Federal regulations and programs that are designed to reduce air emissions of ozone precursors and hazardous air pollutants do very little stop these spreading method. In fact, the Federal regulations and programs promote the spread of air emissions of ozone precursors.

Programs such as Cap & Earn or other " Apples for Oranges" emissions trading programs are designed to reduce emission regardless of the location of a manufacturing facility and produce real reductions of ozone precursor and hazardous air pollutant emissions in local communities.

The following examples of " spreading methods" are provided to give insight and understanding to the reader, so the advantages of Cap & Earn and " Apples for Oranges" will become evident.  11

11 METHOD 1. SMOKESTACK HEIGHT Environmental engineering methods can reduce the local impact on air quality by a manufacturing facilities, without reducing emissions of ozone precursors. One method, which is know as adjusting smokestack height, reduces the very local impact on a manufacturing facility's community. Environmental Engineers calculate air models which determine the amount of local ozone precursors or harzardous air pollutants a facility produces locally by a smokestack's height. Typically, the smokestack's height is increased so the ozone precursors and hazardous air pollutants are carried away by the air currents ( wind) to other locations such as a nearby county or another State. As shown above, short smokestacks produces very local amounts of ozone precursors and hazardous air pollutants, whereas the tall smokestack allows for the ozone precursors and hazardous air pollutants to be carried away to another community. This is a common, but ineffective practice to reduce air emissions of ozone precursors and hazardous air pollutants.  12

12 Open market, interpollutant emissions credits trading programs with a emission s cap would remove the ozone precursors and hazardous air pollutants from the environment permanently. For example, emissions credits could be generated by a power company from installing pollution control equipment at a manufacturing facility that has emissions of ozone precursors. The control equipment would reduce the emissions of volatile organic compounds ( VOC) from the manufacturing facility, producing emission credits. These emissions credits would be purchased by the power company, and the VOC emissions credits would be used to offset power company's nitrogen oxide ( NOx) emissions from a power plant over 100 miles away. The emission credits would be used for a limited amount of time, only METHOD 2. DILUTION WITH FANS/ BLOWERS Other environmental engineering methods also reduce local impact of a facilities emissions of ozone precursors and hazardous air pollutants on air quality by a manufacturing facility, without reducing any of these emissions. Fans and Blowers are attached to smokestacks. These fans and blowers mix a large amount of clean air with ozone precursors and hazardous air pollutants then project the mixture high above the manufacturing facility. Above the manufacturing facility, these diluted emissions are carried away by the air currents ( wind) to different locations such as a nearby  13

13 town or another State. This is a common, but ineffective practice for removing ozone precursors and hazardous air pollutant emissions from the local environment also.

The Cap & Earn and AFO interpollutant emissions credits trading programs could remove the ozone precursors and hazardous air pollutants from the environment permanently. The ozone precursors or hazardous air pollutant emissions from a manufacturing facility would be destroyed by pollution control equipment, and emissions credits would be created. Subsequently these emission credits would be purchased by a power company. Then for a limited period of time,

these emissions credits could be used to offset a power company's sulfur dioxide ( SOx) emissions from a power plant over a hundred miles away. This is the principle behind Apples for Oranges and Cap & Earn, open market, interpollutant emissions credits trading programs.

METHOD 3. SKIPPING TO THE NEXT COUNTY Commonly, industry will build a new manufacturing facility or move an existing facility across county lines to save money by not being required to reduce their ozone precursors or hazardous air pollutant emissions, and in fact the new manufacturing facility can increase their emissions of ozone precursors or hazardous air pollutants by this method. This is known as  14

14 " skipping to the next county". Companies can cross the county line either by 100 feet or a mile where a facility releases more ozone precursors into the environment more because the chosen county would have less strigent air quality regulations. And, the ozone precursors and hazardous air pollutants from this facility can drift into other counties with worse air quality adversely effecting local air quality miles away.

Manufacturing facilities need to expand to accommodate growth. If the costs of compliance to one county's air quality regualtions are less than another county's regulatory cost,

then a manufacturing facility tends to build a facility in the county which is not a nonattainment area with lower cost to meet environmental regualations. ( See above.) Regardless of the argument about an increased tax base of County B, a reduction in ozone precursors and hazardous air pollutants does not occur when companies decides to " skip to the next county" due to Federal air quality regulations.

Cap & Earn, an open market, interpollutant emissions credits trading with an emissions cap would reduce ozone precursors and hazardous air pollutants regardless of a county's air quality status, attainment or nonattainment region. Simply put, the power company which is bidding on the new facility's electricity would bid on the emissions credits from the facility. These emission credits would be created by the power company installing pollution control equipment on the facility. VOC credits generated would subsequently be used by the power company to offset some of their emissions, NOx or SOx., in other areas of the region.  15

15 METHOD 4. EXPANSION BY DUPLICATING FACILITIES Another common method to save money by not reducing emissions of ozone precursors and hazardous air pollutants is duplicating facilities. For an extended period of time, this method avoids future economic growth problems associated with Federal and State environmental regulations and is legal. This strategy, " Expansion by Duplicating Facilities", is quite effective for growing industries to be able to meet their market demands without having to limit production of their products.

By Federal Laws and Regulations, a facility that is located in an ozone non attainment area is limited to 100 tons of emissions of volatile organic compounds ( VOCs). The owner of a manufacturing company has options either to increase the production of a current facility to a level that produces over 100 tons of emissions of ozone precursors and install pollution control equipment or the owner can open a new facility, increase production and can legally produce up  16

16 to 200 tons of emissions. Each facility would produce 100 tons of emissions ozone precursors each.

The reader of this section should not view these identified legal methods that allow for economic growth and increase air polluiton as an attack on industry. The purpose of this section is to provide an objective review of current practices by industry for growth &

profit and their effect on air quality in our society. One should keep in mind that these current methods can help to decrease local pollution which leads to ozone formation.

However, these same practices probably are not the answer to solve today's and tomorrow's poor air quality that produces unhealthy levels of ozone in many regions of our Country. Today, more cost effective strategies are needed to increase air quality. These strategies have to take in to account that air pollution is effected not only from local sources but from sources miles away from ones community.

A Cap & Earn emission credits trading with an open market interpollutant emission credits trading program such as " Apples for Oranges" could prevent an increase in emissions, allow for industry to grow and improve air quality regardless of wherever industry moves.  17

17 Chapter 5 THE BEST INCENTIVE TO REDUCE EMISSIONS AND INCREASE AIR QUALITY  18

18 THE BEST INCENTIVE FOR CLEANING THE ENVIRONMENT The best incentive for incresing air quality is to allow for power companies to competitively increase market share with an environmental agenda. The environmental agenda would rely on an open marketplace with free enterprise. Power companies would make their own choices which they believe would do the most to increase their market share and to meet the given emissions reductions targets for a desired timetable. For example, two timetables could be allowed for reducing emissions of ozone precursors and hazardous air pollutants by the Federal Government. One timetable allows for Cap & Earn or an other types of open market,

intrapollutant trading ( or current regulations and the proposed multipollutant strategy) and would have certain obligations. These obligations could be the target emissions reductions and the timetable of the Senate's Clean Power Act. The second timetable could be the Bush  19

19 Administration's emission reduction and time table under the Clear Skies Initiative. The second timetable would allow for Cap & Earn or " Apples for Oranges" open market, interpollutant emissions credits trading with an emissions cap, and would have certain obligations to reduce the level of the emissions cap of the course of time, also. The second timetable would require power companies to reduce more air emissions by the timetable proposed by the Administration than compared to the emissions reductions by the Senate's timetable. The second timetable would allow for power companies to aggressively reduce emissions of ozone precursors and hazardous air pollutants from industrial and commercial customers, while having to exceed the emissions reduction for coal fired power plants under the Senate plan. Each power company would have to make its choice by 2004.

The incentive is the electricity marketplace. The current market for electric power is between $ 200 billion and $ 300 billion per year. One percent ( 1%) of market share has a value of $ 2 billion to $ 3 billion dollars. The value of 1% market share of the electric power marketplace is almost greater than the entire annual pollution control marketplace for air emissions from nonpower plants source. This large dollar value should provide electrical utilities enough incentive to aggressively reduce their customers' emissions of ozone precursors and hazardous air pollutants,

creating a greater reduction in ozone forming emissions nationwide and, most importantly, in local communities. The entire dollar value to deliver electricity in the electric utility marketplace is greater. The entire marketplace includes not only power cost, but transmission and distribution costs also. The entire electric utility marketplace is much greater than $ 300 billion dollars.  20

20 An aggressive reduction of emissions follows several premises:

the electricity seller wants to retain present customers,

the electricity seller wants to grow the business, therefore the seller needs new customers, and

a deregulated electricity market allows for manufacturers, commercial businesses and the average customer to demand more from the electricity provider.

Cap & Earn gives power companies greater ability to improve the local and national air quality by reducing their customers' air ozone precursors and hazardous air pollutants whereas intrapollutant emissions credits trading does not. The greater ability to improve the local and national air quality by AFO programs would be driven by the natural desire of power companies to expand business and greater reduction targets for the multiple pollutants which would be achieved under a longer time table.

An estimated amount of industrial and commercial smokestacks which could be cleaned by market forces is rather larger under an open market, interpollutant emissions trading program with an emission cap. The estimate is discussed later in this document. The estimated amount is based upon USPIRG's data.  21

21 CHAPTER 6 AN ESTIMATED 45,000 TO 75, 000 SMOKESTACKS CAN BE CLEANED  22

22 Based on calculations using USPIRG data, the Nox emissions from the average older coalfired power plants creates a market value for emissions credits that can purchase over 300 units of pollution control equipment for manufacturers to offset NOX emissions from the power plant for a limited time.

Three years ago US Public Interest Research Group ( USPIRG) published a list of the " Dirtiest 100 Power Plants" in the United States ( see Appendix A). The purpose of the USPIRG data was to release to the public a comparison between the amount of nitrogen oxide ( NOx)

emissions that older coal fired power plants emit and the amount of nitrogen oxide ( NOx)

emissions these same plants would emit under current regulations. Today, these older coal fired power plants have been subject to much legal attention by the courts, former and current USEPA Administrations and the US Congress.

An open market, interpollutant emissions credits trading program such as Apples for Oranges or Cap & Earn would use the market value of the multipollutant emissions from power plants to reduce emissions of ozone precursors and hazardous air pollutants from local manufacturing plants prior to or in conjunction with reducing multipollutant emissions from the  23

23 older coal fired power plants. The amount of manufacturing facilities that can have their ozone pre cursor emissions reduced by 90% under an open market, interpollutant emissions credits trading program is staggering. The market value for the nitrogen oxide ( NOx) emissions from these older coal fired power plants can reduce 90% of the ozone precursor and hazardous air pollutant emissions from between 45,000 and 75,000 local smokestacks of manufacturers in local communities.

USPIRG data showed that the number tons of nitrogen oxides ( NOx) emitted from older coal fired power plants which have not complied with current regulations for nitrogen oxide emissions ( NOx) to be in excess of 2,705,092. That immense tonnage creates a significant market value for emission credits. Current range for values of nitrogen oxide ( NOx) emissions credits put the value of a ton of nitrogen oxides ( NOx) at between $ 3750.00 and $ 6,200.00 during the years 2003 2007. The value of the power plants' excess tons of NOx emissions which is based upon USPIRG data is calculated from multiplying the 2,705,092 excess tons of NOx emissions by the minimum and maximum dollar values per ton. The market value of these excess tons of NOx is between $ 10,762,735,000 and $ 16,771,570,400. That range of values can be translated into an amount of units of pollution control equipment for manufacturing facilities than can be purchased to produce emissions credits which could offset these ( NOx) emissions for a limited amount of time.

The number of units of pollution control equipment for manufacturing facilities that can be purchased by this market value of emission credits can be calculated. The emissions reductions of ozone precursors and hazardous air pollutants by the pollution control equipment which would be installed on the manufacturing facilities would be used to offset the NOx emissions from these older coal fired power plants. For this discussion, the standard size of pollution control  24

24 equipment is 2500 SCFM ( standard cubic feet per minute) and the standard cost for this size of pollution control equipment is $ 225,000. The number of units of pollution control equipment for manufacturing facilities is calculated by dividing the minimum and maximum market values of the excess NOx emissions ($ 10,762,735,000 to $ 16,771,570,400) by the cost of a unit of pollution control equipment ($ 225,000). The number of units from this calculation ranges between fortyfive thousand ( 45,000) and seventy five ( 75,000) units.

This number of units is consistent when one considers the USEPA's estimated costs for reducing nitrogen oxide emissions from these older coal fired power plants under the Clinton Administration. The Clinton Administration estimated that the cost would be fourteen billion dollars ($ 14 Billion) over tens years. This cost estimation would be the equivalent of allowing for the purchase of over sixty thousand ( 60,000) pollution control units.

These calculations demonstrate the great capability of interpollutant emissions credits trading to act locally in communities to improve the air quality by reducing emissions at local manufacturing facilities.

A timetable for reducing emissions from both coal fired power plants and manufacturing facilities needs to be established, and through compromise the likelihood of reducing more pollution may be achieved. Both the Bush Administration and the U. S. Senate have timetables to reduce multiple species of pollution from coal fired power plants by 70%, whereas the reduction targets for all species of emissions by this proposed interpollutant emissions credits trading ( Apples for Oranges) is 90%. Many legal battles have been fought and many fights continue over the amount of reductions and a specific timetable. A compromise will be needed.

Many older plants have also been subject to law suits by Northeastern States that argue for tighter emission controls. The NOx emissions from these older coal fired plants contribute to  25

25 the poor local air quality in the Northeast through transportation of NOx in the Ozone Transportation Region. In the Spring of 2001, the U. S. Supreme Court upheld the decision in favor of the Northeastern States. Subsequently, the Bush Administration and the U. S. Senate have proposed new regulations and laws with different target emissions reductions and timetables.

Both the Bush Administration and the US Senate propose a multipollutant reduction strategy with intrapollutant species trading, not interpollutant species trading. In 2001, the U. S. Senate introduced the Clean Power Act which addresses reductions in sulfur dioxide ( SO2), nitrogen oxides ( NOx), mercury and carbon dioxide ( CO2) emissions by 2007, whereas the Bush Administration proposed a timetable for its multipollutant emissions reduction limits to be met by 2010 or later under the Clear Skies Initiative.

Regardless of the legal battles, open market, interpollutant emissions credits trading with an emission cap has the ability to reduce pollution in local communities by reducing the emissions of ozone precursors and hazardous air pollutants from local manufacturers while at the same time creating a more competitive marketplace for electric utilities and local economic growth.

Emissions reductions of ozone precursors and hazardous air pollutants can occur in between 45,000 and 75,000 smokestacks of local manufacturers with an open market, interpollutant emission credits trading with an emissions cap, providing great improvements in the local air quality. 26 26 Chapter 7 REAL LIFE SCENARIOS:

INTERPOLLUTANT VS. INTRAPOLLUTANT EMISSIONS CREDITS TRADING 27 27 REAL LIFE SCENARIOS APPLICABLE TO INTRAPOLLUTANT EMISSION CREDITS TRADING The good intentions and current strategies of environmental regulations in this country continue to produce adverse affects on the health and economies of local communities. These adverse effects are often overlooked or not understood by most law makers, regulatory agencies,

communities and environmental groups. There is no question that emissions in this country from industrial, commercial and transportation sources need dramatic reductions during the course of next decade. The effect of current and proposed emission credits trading programs and their true effect on the local air quality and local economic growth need to be addressed.

The following real life scenarios in this section are related to two similar geographic regions within the United States. These regions are South Carolina and New Jersey:

South Carolina is between large cities, Charlotte and Atlanta, while New Jersey is between large cities, New York City and Philadelphia.

Both South Carolina and New Jersey thrive as manufacturing centers for two larger cities and their surrounding metropolitan regions, producing products for the nation and the global marketplace.

The boundary metropolitan regions of these large, cities have some of this country's worst air quality.

Air pollution from the boundary regions of these cities affect the air quality of South Carolina and New Jersey, respectively.

In conjunction with the transient air quality effects of these large metropolitan regions, the economic growth of these States is increasingly affected by the Federal air quality regulations and will be subject to new, more stringent air quality regulations soon.

The following scenarios are base on real life situations that occur in communities throughout the U. S., whether one is located in South Carolina, New Jersey, North Carolina,

Virginia, Massachusetts, Wisconsin, Texas, California, Oregon, Ohio, Tennessee, Illinois or 28 28 elsewhere. Members of communities, families, industry, commercial businesses and institutions are greatly affect by air quality regulations, and have to consider the effect of Federal air quality regulations on the local air quality and economic growth Scenario 1: THE CITY AND THE DIESEL PARTICULATE ( Only with Interpollutant Emissions Credits Trading)

Urban areas and inner city regions rely on public transportation, bus lines. Many bus lines use older diesel engines to power their buses. Particulate and volatile organic compounds ( VOC's) emissions from diesel engines worsen the local air quality in urban areas and innercity regions. Cleaner alternatives to diesel engines are available which reduce the particulate and VOC emissions. These alternatives include engines that use either electric, propane, fuel cell or natural gas. With an open market, interpollutant emissions credits trading approach with an emission cap, the local air quality in the urban and inner city regions can be improved readily. Local, County and State governments, private businesses and individuals can pool their influence as a large group of customers to choose an energy supplier which will assist in the retiring of older diesel buses in exchange for their business. The energy supplier uses the emission credits from the reduction of particulate and VOC emissions to offset NOx or SOx emissions for a limited period of time.

The same type of trading can be used for the trucking industry. Trucking companies can exchange emission credits with power companies after the trucking company installs diesel 29 29 particulate emission reduction equipment on their trucking fleet. The USEPA has public disclosed that they are considering trading emission credits from diesel particulate reductions for NOx emissions from power plants. Robert Brenner, the USEPA deputy assistant administrator, Office of Policy Analysis and Review, Office of Air and Radiation, USEPA disclosed on January 18, 2002 that the USEPA has been considering allowing the trade of a diesel particulate emission credit for NOx emissions.

Scenario 2: THE POWER OF A THE LARGE CONSUMER  A CUSTOMER APPROACH A Tire Manufacture in South Carolina ( Only with Interpollutant Emissions Credits Trading)

A large tire manufacturer in South Carolina calls up Duke Energy, the Southern Company ( Mirant), Carolina Power and Lighting or Santee Cooper and says, " If you want my business,

then you'll have to reduce my emissions of ozone precursors and hazardous air pollutants,

then purchase my emissions credits with your electricity... And... at a low cost." Then, the power company which earns the business can use these emissions credits to offset NOx emissions at one of the power company's coal fired power plant for a given period of time.

This type of free enterprise cannot occur under current Federal regulation. 30 30 Scenario 3: CREATING JOBS IN AN ECONOMICALLY DEPRESSED REGION Camden, NJ needs Industry Under Current USEPA Regulations for Open Emission Trading Program:

A large manufacturing company wants to locate a pharmaceutical plant with 500 jobs in Camden, NJ. The tax incentives are attractive. The air quality laws of NJ and the air quality in Camden may require the potential job provider to install pollution control equipment. For example, the air quality regulations for Camden County may require the manufacturing plant of this example to emit less than 50 tons of emissions of ozone precursor. However, the proposed manufacturing plant's process will emit 75 tons of emissions. The company decides to move Salem County, NJ where the company does not need any pollution control and emits 75 tons into the environment. This is how present laws and regulations work; the incentives under the recently approved USEPA Open Market Emissions Trading program for New Jersey forbids companies by USEPA regulation from interpollutant emissions credits trading,

allowing only intrapollutant emissions credits trading. By law and design of New Jersey's 31 31 Open Market Emissions Credits Trading Program, air quality can decrease from an increase in ozone precursors and hazardous air pollutants.. One can say, " there were not enough VOC credits available under New Jersey's program."  Good bye jobs in Camden, hello more air pollution.

Under the Proposed INTERPOLLUTANT EMISSION CREDITS TRADING PROGRAM:

The same large manufacturing company wants to locate a pharmaceutical plant with 500 jobs in Camden, NJ. The tax incentives are attractive. The air quality laws of NJ and the air quality in Camden may require the potential job provider to install pollution control equipment because Camden requires the company to emit less than 50 tons of emissions of ozone precursors. The Company's new plant would emit 75 tons of emissions ozone precursors or hazardous air pollutants. The large manufacturing company goes to the electric companies bidding on the facilities energy ( GPU/ First Energy, PSE& G, Exelon, Enron, etc.) and says, "

I want to build this facility in Camden. If you want my business, then you'll have to reduce my emissions of ozone precursors & hazardous air pollutants, purchase my emission credits from the pollution control equipment which you will install and pay for the operating costs with your electricity... And... at a low cost." Then, the power company which earns the business can use these emissions credits to offset NOx emissions for a given period of time at a coal fired power plant.

Or, a power company can come into the offices of this potential job providing manufacturer and says, " I'd like your business, how about some low cost electricity. I'll clean up your ozone precursor and hazardous air pollutant emissions, then purchase them with electricity... Not only will I cover the generation cost, but I'll cover the transmission and 32 32 distribution fees, too." If the power company can trade electricity fractionally, environmental emission credits could be paid by generation costs, transmission costs and distribution costs.

Fractional energy trading would provide for a greater open market for emission credits trading. Hence, GPU/ First Energy could trade generation costs for some emission credits,

Excelon could trade transmission fees for some emission credits and the PSE& G could trade distribution costs for some emission credits. Fractional energy trading is similar to emission credits trading under New Jersey's Open Market Emission Trading program. New Jersey's trading program trades emission credits in increments of 100 lbs instead of increments of one ton.

Similarly, fractional energy trading pays for emissions credits with parts of the total cost of a delivered kilowatt.

Scenario 4: PREVENTING A LOSS OF JOBS  A COMMUNITY EFFORT Boat Manufacturers and Other Manufacturing Facilities, Atlantic County, NJ Under Current USEPA Regulations for Open Emission Trading Program:

In the next two years Atlantic County, NJ may become a nonattainment area, and new regulations from the USEPA will require drastic changes to the operations of manufacture of boats, pools and other products using styrene. Instead of installing pollution control 33 33 equipment to reduce their styrene emissions, a hazardous air pollution ( HAP), the yacht manufacturers decide that they will move operations to an attainment region of Florida,

thereby avoiding the high costs for pollution control equipment  $ 1.0 million dollars. The effect is that Atlantic County losses jobs and the tax revenues generated from the sale of $ 2 million luxury yachts which may also result in increased property taxes. To avoid the same environmental costs, the pool manufacturers and the other fiberglass manufacturers consider moving to Virgina. The overall result is that Atlantic City and the Pine Barrens region of New Jersey is out of more jobs and tax revenue.

Under the Proposed INTERPOLLUTANT EMISSIONS CREDITS TRADING PROGRAM:

Assume AFO is in place. Now when the yacht manufacturers decide that they will move operations to Florida, instead of installing pollution control equipment, the business and local communities step in! In Atlantic County, NJ, Stockton State University, casinos in Atlantic City and local communities announce that they are sticking by industry, because the county needs jobs and tax revenue. Since New Jersey has a deregulated retail electricity market, this consortium of local and business groups decide to exercise the power of the marketplace.

They form a large electricity buying group with lots of purchasing power. The new electricity buying group decides to purchase their $ 20 million dollar market value of electricity each year for the next five years from a electricity provider that will install pollution control equipment at the manufacturing sites of select companies, and the selected power company will purchase the generated emissions credits to offset emissions from power plants, for example in Ohio,

which contribute to the pollution on the East Coast. Not only does the community retains job,

but there is a greater improvements on the local air quality compared to the current USEPA regulations for the current open market emission credits trading program for New Jersey. 34 34 Scenario 5:

THE POWER OF A LARGE CONSUMER  AN ELECTRICITY PROVIDER APPROACH An Automobile Manufacturer in South Carolina ( Only with Interpollutant Emissions Credits Trading)

If open market, interpollutant emissions credits trading with an emissions cap would be allowed, a power company could come into the offices of a large automobile manufacturing facility in South Carolina and say," I'd like your business, how about some low cost electricity, and I'll clean up your emissions of ozone precursor and purchase them with electricity. Not only will I cover the generation cost, but I'll cover the transmission and distribution fees, too." Then, if the power company can trade electricity fractionally, several power companies obtain emissions credits by paying for environmental emission credits with generation costs, transmission costs and distribution costs. For example, Mirant could trade generation costs for some emissions credits, Duke Power could trade transmission fees for some emissions credits and the City of Seneca could trade distribution costs for some emissions credits to assist Seneca's local industry. 35 35 Scenario 6:

COMPANY EXPANSION  EXERCISING OPTIONS Commercial Bakery in Bergen County, NJ Under Current USEPA Regulations for Open Emission Trading Program:

The Commercial Bakery Industry is coming under new USEPA regulations in a couple of years for nonattainment areas, such as Bergen County. A commercial bakery wants to expand, but the bakery has to install pollution control equipment to meet the new regulations.

The commercial bakery needs VOC emissions credits to offset the commercial bakery's emissions from the expansion. This commercial bakery in Bergen County realizes that there are not enough VOC credits under New Jersey's Open Market Emission Credits Trading Program to meet its needs. The recently USEPA approved Open Market Emissions Credits Trading Program for New Jersey forbids The bakery from interpollutant emissions credits trading, allowing only intrapollutant emission credits trading, thus reducing the actual market for emissions credits. The company makes plans to move to New York State where the transportation cost may be greater. This commercial bakery decides to move to New York,

and as a result Bergen County losses jobs and tax revenue, and the amount of pollution increases in the New York/ New Jersey metropolitan region. 36 36 Under the Proposed INTERPOLLUTANT EMISSIONS CREDITS TRADING PROGRAM In New Jersey's deregulated marketplace with open market, INTERPOLLUTANT emissions credits trading with an emission cap ( Cap & Earn), when the same commercial bakery wants to expand and has to install pollution control equipment to meet the new regulations, it has the electricity providers in the State bid on a new electricity contract which includes 1) low cost electricity and 2) a package which will install pollution control equipment and a purchase agreement for the VOC emissions credits which will be used to offset the NOx emissions traveling to the New York/ New Jersey region from a coal fired power plant in Pennsylvania for a limited amount of time.

Cap & Earn, an open market, interpollutant emission credits trading program allows for an equal or greater amount of ozone precursors and hazardous air pollutants to be reduced in a local community as opposed to reducing NOx emissions at great distances from a community.

In addition, interpollutant emission credit trading allows for the local improvements in the local air quality and the local economy to be sustained or to grow, whereas intrapollutant trading does not perform to this level of local impact, environmentally or economically. 37 37 Scenario 7: THE POWER OF THE LARGE CONSUMER AND IT'S SUPPLIER  A COOPERATIVE APPROACH TO CLEAN AIR An Automobile Manufacturer and Regional Parts Suppliers in South Carolina ( Only with Interpollutant Emissions Credits Trading)

A power company would come into the offices of a large automobile manufacturing facility in South Carolina and would say," I'd like your business, how about some low cost electricity, and I'll clean up your emissions and purchase them with electricity. Not only will I cover the generation cost, but I'll cover the transmission and distribution fees, too." The large power company might tell the power supplier that more emissions of ozone precursors can be removed from the environment and at less costs if the power company reduces ozone precursor and hazardous air pollutant emissions from the automobile manufacturer's suppliers. The auto manufacturer might tell the power company that under Federal law its suppliers are exempt from reducing their emissions of ozone precursors, because of the suppliers' locations and permitted emissions levels. The automobile manufacturer would further state that if all the suppliers' emissions were reduced,

then more air pollution will be cleaned from the environment through free enterprise compared to under Federal laws and regulations. If the power company could trade electricity 38 38 fractionally, the environmental emissions credits could be brought by several power companies. Each power company would pay for a fraction of emission credits in exchange for generation costs, transmission costs and distribution costs. Fraction energy trading would create a greater open market for emission credits trading. For example, Mirant could trade generation costs for some emission credits, Duke power could trade transmission fees for some emission credits and the City of Seneca could trade distribution costs for some emission credits to assist Seneca's local industry. This cannot happen under the current and proposed Federal Laws and current and proposed USEPA regulations. This could only happen using an interpollutant emissions credits trading program in an open market, such as Apples for Oranges.

Free Enterprise and the Power of the Consumer of electricity can radically change the way our Nation increase its air quality and provide for economic growth. 39 39 Chapter 8 KEY ISSUES:

ESTABLISHING REASONABLE GUIDELINES FOR INTERPOLLUTANT TRADING PROGRAMS 40 40 KEY ISSUES: REASONABLE GUIDELINES All trading programs need reasonable guidelines. These guidelines sometimes tend to be arbitrary in nature as opposed to being pointed with certainty and exactness. Nevertheless,

reasonable guidelines are needed to ensure public health. Apples for Oranges' open market,

interpollutant trading programs with Cap & Earn implementation would need reasonable guidelines, also. Case law has assisted in minimum guidelines for trading programs as well as upheld reasonable arbitrary regulations which were put in place by the USEPA to protect the public health and safety. Therefore, guidelines for an open market, interpollutant emissions trading program with an emission cap could be developed with the same focus of public health and safety, and built upon current intrapollutant emissions trading programs to establish rules specifically for interpollutant emissions credits trading.

The section discusses some guidelines for emissions credits trading. It hopes to touch on all pertinent issues, but by no means is complete. This section is meant to begin the discussion on guidelines for AFO programs, interpollutant trading. The section discusses A) guidelines for trading between pollutant species, B) guidelines for emissions reductions from utilities and industry, C) the ` hot spot' issue, D) geographic scale of trading, E) Federal and State oversight of air quality management, F) ensuring credible record keeping and monitoring and G) fractional energy trading ( FRACTRAD).

A. GUIDELINES FOR TRADING BETWEEN POLLUTANT SPECIES The guidelines for trading between pollutant species should:

1. exclude trading of mercury emissions 2. work within established hazardous air pollutant ( HAP) frameworks 3. establish trading ratios between species 4. establish local and regions trading ratios 41 41 5. provide credible incentives for early emissions reduction 6. provide credible incentives for emissions reduction beyond the amount which is required under Federal and State regulations 7. must be cost effective.

Open Market, interpollutant emissions credits trading would exclude trading of mercury emissions form coal fired power plants for other pollutant species. The support for reducing mercury emissions is extremely strong. USPIRG, the Southern Alliance for Clean Energy, Izaak Walton League of America, the National Environment Trust, National Wildlife Federation,

Natural Resources Defense Council and others strongly support great reductions in mercury emissions. Mercury emissions from coal fired power plantssshould be addressed separately,

however interpollutant trading could be effected by installing equipment which reduces mercury emissions. Therefore, certain mercury emissions reduction strategies could produce emissions credits for nitrogen oxides and sulfur dioxide. These NOx and SOx credits should be allowed to be traded in an AFO (" Apples for Oranges"/ open market, interpollutant emission credits trading)

program.

Open market, interpollutant emissions credits trading programs with an emission cap ( AFO/ Cap & Earn) should provide strong incentives to reduce air toxins ( HAP) and follow the di minimis standards of trading emissions credits under current HAP frameworks such as those found in the Michigan's and New Jersey ` s open market emissions trading programs. Cap & Earn programs would concentrate their initial thrust on reducing and provide strong incentives to reduce air toxins during the first stage of trading. A trading ratio favoring HAP emissions should be developed when trading occurs between two pollutant species.

Reasonable trading ratios would be established for the species. As chemical species, HAP emissions have the most adverse effects on public health and the environment as compared to 42 42 NOx, SOx and other VOC emissions. HAP emissions should carry the most weight in any trade in an interpollutant trading program. VOC emissions from industry represent a carrot incentive for electrical utilities to increase market share and to retain customers, therefore VOC emissions should carry more weight in any trade between NOx and SOx emissions.

Local impacts of emissions reductions which effect public health should carry more weight than distant reductions. For example local emissions reductions of NOx and VOC's should weigh more in a trade than distant reductions in NOx.

Ratios between species and local factors would be used for trading in AFO programs. For example, one ton of local VOC reduction credits could be traded to offset two tons of NOx emissions. Or, one ton of local HAP reduction credits could be traded to offset ten distant tons of NOx emissions. Or, one ton of local NOx emissions could be traded to offset 1.3 tons of distant NOx emissions. Ratios and a different categories of emissions reduction already exist in trading programs. Currently, several States have different rules for emissions credits during ozone seasons. Input from discussions with stakeholders would serve to establish agreement on trading ratios.

Guidelines for trading between pollutant species should provide credible incentives for early emissions reductions, provide credible incentives for emissions reductions beyond an amount which is required under Federal and State regulation, and be cost effective. AFO trading systems should allow for the value of emission credits to cover the cost of the emissions reduction. For example, if pollution control equipment is required to reduce VOC emissions from an industrial smokestack which produces 25 tons of emissions annually and has a flow rate of 2500 CFM, then the cost of the pollution equipment in relation to the value of emissions credits must be determined and be an incentive to install the equipment. Otherwise, there is no incentive to 43 43 reduce pollution. If the cost of this pollution control equipment is $ 225,00.00, then an reasonable incentive has to be established.

From previous discussion, the value of a ton of NOx for 2003 2007 is between $ 3750.00 and $ 6200.00. The annual value of emissions credits for twenty five ( 25) tons of VOC emission given this range is between $ 93,000.00 and $ 150,000.00. The higher value of the range still does not cover the cost of the pollution control equipment under current discrete emissions reductions ( DER) credits guidelines. Hence, new guidelines must be established to create reasonable incentives to make AFO programs effective.

Using ratios between pollutant species during interpollutant trading or extending the duration of credits may be necessary. A trading ratio of 2 to 1 for NOx to VOC would provide a reasonable incentive producing between $ 186,000.00 and $ 300,000.00 towards the purchase of pollution control equipment. Similarly, extending the duration of the emissions credits from one year to two years and maintaining a 1 to 1 trading ratio between NOx and VOC would produce the same dollar value.

Dollar values of emissions could vary from smokestack to smokestack. Not every smokestack produces the same tonnage of emission. Interpollutant trading guidelines would have to address these issues so incentive can be real and effective.

B. GUIDELINES FOR EMISSIONS REDUCTIONS FROM UTILITIES AND INDUSTRY Guidelines for emissions reductions from utilities and industry would have to be established. These guidelines should be flexible and cover a certain percentage of emissions reductions in coal fired power plants through the AFO program. AFO programs should initially focus the majority of emissions reductions on industrial smokestacks and part of the reductions 44 44 would come from coal fired power plants. Since one of the main driving forces is the customer,

the majority of emissions reductions should come from industrial smokestacks initially. This focus should concentrated on air toxins. Emissions reductions from coal fired power plants would be done on a partial basis. Generally, coal fired power plants have more than one boiler and more than one smokestack. Emissions from a fraction of the total number of smokestacks of coal fired power plants could be reduced.

The emissions reduction targets in the AFO program are provided in this document and initially propose smaller target reductions for NOx and SOx by 2007 in comparison to other proposed Federal legislation and regulations, but AFO program has additional requirements on coal fired power plants by 2007. The coal fired power plants must also reduce carbon monoxide emissions, produce electricity from renewable sources, and reduce emission from industrial and commercial sources. In additional by 2007, participating industry would have to increase their energy efficiency by fifteen percent ( 15%). By 2012, ninety percent ( 90%) of all industrial smokestack emissions would be reduced, eighty five percent of ( 85%) of NOx and SOx emissions from coal fired power plants would be reduced and ninety percent ( 90%) of all mercury emissions would be reduced. AFO programs would reduce more pollution than the US Senate's Clean Power Act and the Bush Administration's multipollutant reduction targets for 2012 under the Clear Skies Initiative.

C. THE " HOT SPOTS" ISSUE The " hot spot" issue is of concern by many stakeholders. The Southern Alliance for Clean Energy, National Environmental Trust, the Clean Air Task Force, the American Lung Association and USPIRG stand strong on the position that any emissions trading program must take into 45 45 account the potential for " hot spots". A Cap & Earn emission credits trading programs could effectively minimize the potential for " hot spot" by reducing the air toxins from local industries near and adjacent to power plants. Emissions reductions under an AFO program could be designed for specific regions to decrease the likelihood of developing " hot spots".

D. THE GEOGRAPHIC SCALE OF INTERPOLLUTANT TRADING The geographic scale for interpollutant trading would primarily be designed to effectively reduce emissions in non attainment areas. Obviously, emissions in Georgia should not be traded for emissions credits in California. An AFO trading program would build upon current regional and State programs as well as evidence provided in recent court decisions regarding ozone transportation. VOC ozone precursor emissions may be more localized due to the heavier weight of the molecular species, therefore AFO programs would be more effective in reducing " hot spots" which are associated with industry.

Geographic scales of different interpollutant trading regions could require different trading rules. The Southeast has much industrial growth, so the Southeast could have a regional Cap &

Earn program that addresses a relationship between industry and utilities. The Northeast has much ozone transportation from the Midwest, so the Northeast could have a regional Cap & Earn program that addresses this large amount of ozone transportation with a relationship that address its needs.

Regional trading zones would have to be established, and one would suspect that there would be overlapping regions. The rules may be different for each region, but could be cooperative between regions. 46 46 E. FEDERAL AND STATE OVERSIGHT OF AIR QUALITY MANAGEMENT Federal and State oversight of air quality management would continue. Geographic regions, non attainment area and trading programs would be under the management of Federal and State agencies. These agencies would ensure that trading is producing air quality improvements and that these improvement are meeting the requirements under the Clean Air Act ( CAA) or amendments to the CAA.

G. ENSURING CREDIBLE RECORD KEEPING AND MONITORING AFO program would build upon guidelines already established for intrapollutant trading.

Additionally, participants would be required report emissions inventory with production records online to monitoring agency. These reports would be available for public review. Continuous emissions monitoring ( CEM) devices would be installed on participating smokestacks when possible.

F. FRACTIONAL ENERGY TRADING ( FRACTRAD)

Fractional energy trading ( FRACTRAD) is a new concept which could be used in regulated and deregulated energy markets. FRACTRAD allows for emissions credits to be purchased with electricity. Fractional energy trading is introduced for the first time under this Apples for Oranges' interpollutant trading program. Emission credits could be purchased under FRACTRADing, and the fractional dollar amounts could pay for pollution control equipment and the equipment's operating costs.

FRACTRAD increases the market reach of power companies, and would allow for more than one power company to be part of an emissions credits trade. The power cost, transmissions 47 47 cost and distribution cost for a delivered kilowatt could be separated out of emissions credits purchases, and distributed to more than one power company. 48 48 Chapter 9 SUMMARY OF KEY POINTS 49 49 SUMMARY OF KEY POINTS Apples for Oranges Version 2: Cap & Earn An Open Market, Interpollutant Species Emission Credits Trading Program.

1. Apples for Oranges and Cap & Earn are open market, an interpollutant emissions credits trading programs with an emission cap. The progams are incentive methods for cleaning the environment that provide vehicles for economic growth of the Nation and focuses on the local environment and economic growth of a community.

2. Interpollutant Trading  Interpollutant trading occurs when one type of emissions credit is traded for a different type of emission. Nitrogen oxide ( NOx) emissions credits are traded for volatile organic compound ( VOC) emissions. Sulfur dioxides ( SOx) emissions credits are traded for carbon dioxide ( CO2) emissions.

3. Intrapollutant Trading  Intrapollutant trading occurs when a specific type of emissions credit is traded for the same type emission. Nitrogen oxides ( NOx) emissions credits are traded for nitrogen oxide emissions ( NOx) only. VOC emissions credits are traded for VOC emissions, only.

4. The emissions credits trading programs can contain incentives contain obligations such as decreasing carbon dioxide emissions through increased efficiency and renewable energy requirements, as well as target reductions for emissions of air toxins, mercury, sulfur dioxide and nitrogen oxides.

5. The best incentive for cleaning the environment is to allow for power companies to competitively increase market share with an environmental agenda with aggressive emissions reduction targets and focusing on increasing the air quality in local communities .

6. The nationwide goal of Apples for Oranges/ Cap & Earn's open market, interpollutant emissions credits trading program is to reduce two thirds ( 2/ 3) of all present day air pollution ( mercury, air toxins, nitrogen oxides and sulfur dioxide) by eighty percent ( 80%) in the next ten years and ninety percent ( 90%) of air pollution from new sources.

7. The Apples for Oranges program aims to reduce the potential for " hot spots" to occur in local communities by creating reasonable guidelines for emissions reductions of ozone precursors and hazardous air pollutants in local communities.

8. Interpollutant emission credits trading reduces the methods in current regulations and laws that decrease air quality. 50 50 9. These methods are a) adjusting smokestack height, b) dilution methods with fans, c) " skipping to the next county" and d) duplicating facilities.

10. There are two fundamental questions that we, as Americans, have to ask ourselves when our leaders choose a Federal environmental protection program either through Administrative regulation or Federal laws made by the Legislative Branch.

11. One question to ask families is, " If they have a choice between having the pollution from a manufacturing facility next to their homes cleaned or emissions from the a power plant over 100 miles away cleaned, which would they want?"

12. The other fundamental question that needs to be answered is, " Should Federal Regulations and Laws provide opportunity for communities to choose between reducing air pollution from local sources and reducing air pollution from source hundreds of miles away?"

13. INTERPOLLUTANT emissions credits trading allows for power companies to have greater ability to improve the local and national air quality by reducing their customers' air pollution whereas intrapollutant emissions credits trading does not.

14. Interpollutant emissions credits trading programs such as Apples for Oranges uses the market value of the multipollutant emissions from power plants to reduce emissions from local manufacturing plants prior to or in conjunction with reducing multipollutant emissions from the older coal fired power plants.

15. The Apples for Oranges program creates a shift in the way individual segments of society which desire reduced emissions would be grouped. The shift would occur from the current aggregation of emissions producers and community to electricity producers and electricity consumers.

16. This shift allows for the environmental marketplace to be polarized with an economic weight never before seen in any environmental regulatory program.

17. The value of 1% market share of the electric power marketplace is almost greater than the entire annual pollution control marketplace for air emissions, while the current value of " excess" nitrogen oxide emissions based on USPIRG data demonstrates the strength of market forces for cleaning the environment.

18. The current 2003 2007 market value for the excess nitrogen oxide ( NOx) emissions from USPIRG's Dirtiest 100 Utility Plants, older coal fired power plants, is between $ 10.1B and $ 16.7B dollars ($ 10,144,095,000 to $ 16,771,570400).

19. This market value can be translated into an amount of units of pollution control equipment for manufacturing facilities than can be purchased to produce emission credits which could offset these nitrogen oxide ( NOx) emissions for a limited amount of time. 51 51 20. The current 2003  2007 market value for the excess nitrogen oxide ( NOx) emissions from USPIRG's Dirtiest 100 Utility Plants ( older coal fired power plants) can reduce 90% of the emissions from between 45,000 and 75,000 local smokestacks of manufacturers in local communities.

21. With interpollutant emission credits trading, emissions reductions can occur in between 45,000 and 75,000 smokestacks of local manufacturers providing great improvements in the local air quality by greatly reducing air toxins.

22. The good intentions and current strategies of environmental regulations in this country continue to produce adverse affects on the health and economies of local communities. These adverse effects are often overlooked or not understood by most law makers, regulatory agencies, communities and environmental groups.

23. By law and design of New Jersey's Open Market Emissions Credits Trading Program , pollution can increase.

24. Both the Bush Administration and the US Senate propose a multipollutant reduction strategy with intrapollutant species trading, not an interpollutant species trading program. The current USEPA regulations only allow for intrapollutant emissions credits trading under 40 CFR Part 51 Subpart U. Neither the Administration through new regulatory proposals nor the US Senate's Clean Power Act, S. 556 address changes to the current USEPA regulations which would create an interpollutant emissions credits trading program.

25. Key Issues which would need reasonable guidelines would be A) rules for trading between pollutant species, B) rules for emissions reductions from utilities and industry, C) the ` hot spot' issue, D) geographic scale of trading, E) Federal and State oversight of air quality management, F) ensuring credible record keeping and monitoring and G) fractional energy trading ( FRACTRAD).

26. The guidelines for trading between pollutant species should: 1. exclude trading of mercury emissions, 2. work within established hazardous air pollutant ( HAP) frameworks, 3. establish trading ratios between species, 4. establish local and regions trading ratios, 5. provide credible incentives for early emissions reduction, 6. provide credible incentives for emissions reduction beyond the amount which is required under Federal and State regulations 7. must be cost effective.

27. Interpollutant emissions trading would exclude trading of mercury emission for other pollutant species.

28. AFO programs should provide strong incentives to reduce air toxins ( HAP) and follow the di minimis standards of trading emissions credits under current HAP frameworks. 52 52 29. Ratios between species and local factors would be used for trading in AFO/ Cap & Earn programs.

30. AFO trading systems should allow for the value of emission credits to cover the cost of the emissions reduction.

31. New guidelines must be established to create reasonable incentives to make AFO programs effective such as using a ratios between pollutant species during interpollutant trading or extending the duration of credits may be necessary.

32. Guidelines for emissions reductions from utilities and industry would have to be established.

33. Cap & Earn/ AFO programs should initially focus the majority of emissions reductions on industrial smokestacks and part of the reductions would come from coal fired power plants.

34. Cap & Earn/ AFO programs would reduce more pollution than the US Senate's Clean Power Act and the Bush Administration's multipollutant reduction targets for 2012 under the Clear Skies Initiative.

35. Emissions reductions under an AFO program could be designed for specific regions to decrease the likelihood of developing " hot spots".

36. The geographic scale for interpollutant trading would primarily be designed to effectively reduce emissions in non attainment areas.

37. VOC emissions may be more localized due to the heavier weight of the molecular species, therefore AFO programs would be more effective in reducing " hot spots" which are associated with industry.

38. Geographic scales of different interpollutant trading regions could require different trading rules.

39. Fractional energy trading ( FRACTRAD) is a new concept which could be used in regulated and deregulated energy markets. FRACTRAD allows for emissions credits to be purchased with electricity.

40. The power cost, transmissions cost and distribution cost for a delivered kilowatt could be separated out of emission credits purchase, and distributed to more than one power company. 53 53 Chapter 10 APPENDIX A USPIRG Data and Calculations FROM USPIRG: The Dirtiest 100 Utility Plants  ExcessNOx Emissions based on the differenc between current and 1970 standards Page 1 of 3 Facility Owner state total emissions excess emissions 1 Cumberland Tennessee Valley Authority TN 159,893 142,448 2 Paradise Tennessee Valley Authority TN 149,828 137,303 3 Belews Creek Duke Energy Corporation NC 103,736 91,687 4 Gen J. M. Gavin American Electric Power Service OH 96,798 84,683 5 Johne E. Amos American Electric Power Service WV 68,060 56,165 6 Baldwin Illinois Power IL 63,447 55,431 7 J. M. Stuart Dayton Power & Light Co. OH 63,815 52,884 8 Clitty Creek Ohio Valley Electric Corporation IN 59,470 52,737 9 New Madrid Associated Electric Cooperative MO 53,473 47,033 10 Roxboro Carolina Power & Light Company NC 56,428 45,824 11 Kyger Creek Ohio Valley Electric Corporation OH 48008 42,426 12 W. H. Sammis Ohio Edison OH 51,470 40,798 13 Gibson Cinergy Corp. IN 58740 40,687 14 Cardinal American Electric Power Service OH 45901 38,117 15 Muskingum River American Electric Power Service OH 44839 37,462 16 Powerton Commonwealth Edison Company IL 43897 36,661 17 Tanners Creek American Electric Power Service IN 39343 34,852 18 Monroe The Detroit Edison Company MI 50163 34,487 19 Mt. Storm Virginia Power WV 43039 34,269 20 Four Corners Arizona Public Service Company NM 44,244 32,516 21 Crystal River Florida Power Company FL 45982 32,347 22 Big Bend Tampa Electric Company FL 40417 31,765 23 Clinch River American Electric Power Service VA 34949 24 James G. Miller Jr. Alabama Power Company AL 45947 30,467 25 Bowen Georgia Power Company GA 44506 28,960 26 Big Sandy American Electric Power Service KY 38086 28,455 27 Scherer Georgia Power Company GA 44647 28,296 28 Barry Alabama Power Company AL 36647 27,686 29 F. J. Gannon Tampa Electric Company FL 32738 27,649 30 Shawnee Tennessee Valley Authority KY 34322 27,363 31 Kammer American Electric Power Service WV 30713 27,249 32 Harilee Branch Georgia Power Company GA 33064 27,137 54 54 APPENDIX A USPIRG Data and Calculations facility owner state actual emissions excess emissions 33 Ghent KentuckyUtilities Company KY 37949 26,065 34 Coffeen Central Illinois Public Service Co. IL 28473 25,137 35Miami Fort Cinergy Corp. OH 30921 24,859 36 Allen TennesseeValley Authority TN 28486 24,812 37 LaCygne Kansas City Power andLight Co. KS 29538 24,029 38Gorgas AlabamaPower Company AL 30444 23,721 39 Fort Martin Allegheny Power System WV 29197 23,706 40Mountaineer ( 1301) American Electric Power Service WV 27565 23,518 41W. A. Parish Houston Lighting & Power Company TX 38595 23,295 42 Harrison Allegheny Power System WV 33615 22,889 43 Sioux Union Electric Company MO 26414 22,637 44Widows Creek TennesseeValley Authority AL 28779 22,188 45 Kincaid Commonwealth Edison Company IL 24747 21,705 46 Coal Creek CooperativePower Association ND 28832 21,176 47 Rockport American Electric Power IN 36509 20,862 48 Kingson TennesseeValley Authority TN 28010 20,274 49 Lewis & Clark Montana DakotaUtilities Co. MT 32189 20,126 50 Jim Bridger PacifiCorp WY 33507 20,124 51 San Juan Public ServiceCo. of New Mexico NM 33515 19,908 52 AllenS. King Northern States Power Co. MN 22590 19,789 53 Navajo Salt River Project Ag. Imp. & Power AZ 32184 13,642 54 J. H. Campbell Consumers Energy Company MI 25980 19,627 55Marshall Duke Energy Corporation NC 29723 19,545 56 Big Stone Otter Tail Power Company SD 22389 19,518 57 Bailly Northern IndianaPublic ServiceCo. IN 21873 19,494 58Warrick Southern IndianaGas andElectric Co. IN 23885 19,474 59Milton R. Young MinnkotaPower Cooperative ND 23907 19,400 60 Homer City GPUGeneration Corporation ( GENCO) PA 29379 19,332 61 Thomas Hill AssociatedElectric Cooperative MO 25546 19,102 APPENDIX A 55 55 USPIRG Data and Calculations 65 Limestone Houston Lighting and Power Company TX 27589 17,613 66 Hatfield's Ferry Allegheny Power System PA 24288 17,599 67 Winyah Santee Cooper SC 22279 17,287 68 St. John's River Power Plant Jacksonville Electric Authority FL 25112 17,284 69 Morgantown Potomac Electric Power Company MD 22189 16,944 70 Martin Lake TU Electric TX 30286 16,565 71 Chesterfield Virginia Power VA 22475 16,437 72 Mitchell American Electric Power Service WV 23105 16,309 73 Sibley Missouri Public Service MO 18538 16,277 74 Pleasant Prairie WI 24055 16,211 75 Brandon Shores Baltimore Gas and Electric Company MD 22898 15,756 76 Intermountain Los Angles Dept. fo Water & Power 26269 15,720 77 C. P. Crane PNG Corporation 17423 15,691 78 St. Clair The Detroit Edison Company 21454 15,650 79 Walter C. Beckjord Cinergy Corp OH 20775 15,473 80 Keystone GPU Generation Corporation ( GENCO) PA 25090 15,440 81 Wateree South Carolina Electric & Gas Co. SC 18039 15,234 82 Joliet 29 Commonwealth Edison Company IL 21102 15,197 83 E. O. Gaston Alabama Power Company AL 23515 15,172 84 Reid Gardner Nevada Power Company NV 18904 15,109 85 Bruce Mansfield Ohio Edison Company PA 25503 15,066 86 Conemaugh BPU Generation Corporation ( GENCO) PA 24525 14,975 87 Kanawha River American Electric Power Service WV 16893 14,928 88 Dave Johnston PacifiCorp WY 21173 14,840 89 Williams South Carolina Electric & Gas Co. SC 17905 14,371 90 Jeffrey Energy Center Western Resources, Inc. KS 25360 14,099 91 Michigan City Northern Indiana Public Service Co. IN 15544 13,664 92 Mountainer ( 1301) American Electric Power Company WV 19142 13,376 93 Craig Tri State G& T Association, Inc. CO 21124 13,376 94 Hunter ( Emery) PacifiCorp UT 21176 13,687 95 W. H. Zimmer Cinergy Corp. OH 19906 13,270 96 Seminole Seminole Electric Cooperative, Inc. FL 20895 13,256 97 Merrimack Northeast Utilities Service Co. NH 15777 13,192 98 J. T. Deely City Public Service TX 22580 13,172 99 Avon Lake Centerior Energy OH 15979 13,128 100 Bull Run Tennessee Valley Authority TN 17434 13,076 TOTAL EXCESS TONS 2,705,094 OF EMISSIONS ANNUALLY The average 8 year cost for add on pollution control equipment for a flow rate of 2500 SCFM flow ( equipment and installation cost only) is $ 225,000. Therefore, one can calculate the number of MARKET VALUE OF THESE EXCESS $ 10,144,102,500 machines that can be purchase with the market value of the AT $ 3750 PER TON excess tonnage of NOx emissions This calculation uses a 2500 SCFM unit as the standard, The number of local control te  =($ 10114102500)/($ 225,000) because the price of pollution control equipment with the can be purchase by the excess emission in the pollution control industry is estimated senario above: 45085 by $ 225,000 per 2500 SCFM. This estimate is valid up to 25,000 SCFM and assumes that the 25,000 SCFM is derived from multiple process lines no greater than 5,000 SCFM. The number of local control te =($ 14,000,000,000)/$ 225,000) can be purchase by the USEPA market value of $ 14 billion for reducing NOx 62222 Based upon the market value of excess emissions the number of from the Clinton Administration, Carol Browner USEPA 2500 SCFM units that can be installed is: 45,085 Sources:

1) USPIRG: The Dirtiest 100 Utility Plants  Excess NOx Emissions based on the difference between current and 1970 standards 2) Conversations with professionals within the pollution control industry concerning the cost of state of the art: regenerative thermal oxidizers ( RTO's) and catalytic oxidizers. 56 56 APPENDIX B TERSE OVERVIEW OF PROPOSED CHANGES TO SECTION 113 OF HR 655 ELECTRIC CONSUMERS' POWER TO CHOOSE ACT OF 1997 Proposed changes which will be sent to U. S. Rep. L. Graham, R SC within three weeks of 8/ 7/ 98 current tittle of section 113: Renewable Energy proposed title after conversation with U. S. Rep. L. Graham, R SC: Renewable Energy and Environmental Restoration Overview of Proposed changes by R. C. Dalton; Apples for Oranges Trading. Proposed changes to the USEPA's emissions credits trading programs would allow for VOC's, ozone, NOx, CO, CO2 and SOx emissions credits to be traded to offset emission of another pollutant species. Currently NOx emission credits are traded for NOx emissions, and SOx emission credits are traded for SOx emissions. Apples for Oranges trading would provide a greater incentive for companies to reduce their emissions by providing a market for all types of air emissions. For emissions trading to work well in all industries, each type of emission needs to be able to be traded. With apples for oranges trading, a coal burning utility can purchase a VOC emissions credit from a industrial client for the utility's NOx emissions. The same utility could trade their emissions for NOx emissions credits. Or, the same utility can trade VOC credits for NOx emissions. Or, a utility could sell VOC credits to another utility for its NOx emission. Again, the principle is to produce a larger and freer market to reduce the overall pollution within the U. S. Apples for oranges trading would help assist competitiveness in the deregulated energy markets by providing more items for bargaining in contractual agreements between utilities and their prospective clients and would allow for industrial and commercial business to fund pollution reduction measures by emissions credits.

Propose an Expansion of Emission Credits Trading to be Borderless within the U. S. For example, South Carolinian companies can trade emissions credits with Maryland companies, instead of the current program which restricts trade to be within local regions or EPA regions. Expanded and freer trade will add greater value to the emissions credits by creating a larger market. Industrial and commercial business will have a greater market to sell their emissions credits to provide for pollution reduction measures. The expansion of trade will allow communities greater opportunity to work with surrounding business to restore their local environment to healthy and clean levels. Additionally, a community's real estate value can be effected by cleaner air and water within local communities; Cleaner water and air should increase property values. The land next to industry that does not pollute should be more valuable than land next to industry that does pollute.

* * * * * 57 57 APPENDIX C E mail from Dr. Bruce Yandle [ Original Message] ° From: < byandle@ att. net> ° To: < rcd2001@ earthlink. net> ° Date: 9/ 6/ 01 10: 52: 32 AM ° Subject: Re: Help Please, Emission Credit Trading from a Clemson grad.> ° Bob   Your idea has merit, and is well expressed. Let me ° suggest that you contact Wendy Gramm at the Mercatus ° Center, George Mason University. Also, Susan Dudley, ° same organization. Go to their web page and you will ° see what they do. ° Please keep me posted. ° yandle@ clemson. edu ° Room 201 Sirrine Hall ° Clemson University ° Clemson, SC 29634 ° 864.656.3970 > > Dear Dr. Yandle,

° > I'm trying to attend and participate in a meeting which is closed to the ° > public. The meeting is sponsored by the US Senate Environment and Public ° > works committee with Sen. Jeffords. The meeting contains electric utility ° > executives, environmental groups, state regulators and observers which are ° > negotiating revisions to the Clean Air Act. I cannot even obtain a list of ° > negotiators from Jefford's committee. ° > I want one simple change to the USEPA Open Market Emission Trading Program ° > and the Environmental Incentive Program ( EIP). The simple change is to be able ° > to have interpollutant trading  VOC for a NOx credit. Current regulation ° > has intrapollutant trading, NOx for NOx and VOC for VOC. ° > With the arguments that Mike Maloney, Bobby McCormick and Chad ° > McGowan provided for deregulation of electricity, one can image the ° > profound effect that trading a VOC for a NOx will have on cleaning the ° > environment in a deregulated marketplace, especially locally. ° > Imagine if Michelin could call up Duke Energy, the Southern Company ( Mirant), ° > Carolina Power and Lighting or Santee Cooper and say, " If you want my business, ° > then you'll have to reduce my emission and purchase my emission credits with ° > your electricity... And... at a low cost." Then, the power company ° > which earns the business can use the VOC credits to offset NOx emissions for a ° > given period of time. ° > Or, even better... the power company can come into ° > BMW and say," I'd like your business, how about some low cost electricity, ° > and I'll clean up your emissions and purchase them with electricity... Not ° > only will I cover the generation cost, but I'll cover the transmission 58 58 ° > and distribution fees, too" Then if the power company can trade ° > electricity fractionally  generation costs, transmission costs and distribution ° > costs for environmental emission credits, the open market will be ° > greater. For example, Mirant can trade generation costs ° > for some emission credits, Duke power can trade transmission fees for some ° > emission credits and the City of Seneca can trade distribution costs for some ° > emission credits."  I believe that the environment and economic growth ° > can coexist. ° > I proposed this interpollutant trading and ° > fractional energy trading idea for legislative changes to Rep. Lindsay Graham. ° > Is there anything that can be done to get into that meeting and is there a ° > interpollutant trading representative that exist besides myself? Thank you for your time.

> Most Sincere,

> > Robert C. Dalton, Ceramic Engineering ` 83 ° > 609 294 0975 ° >  Robert Dalton >  rcd2001@ earthlink. net ° >  EarthLink: It's your Internet. 10 59 10 59


[Federal Register Volume 82, Number 94 (Wednesday, May 17, 2017)]
[Notices]
[Page 22662]
[FR Doc No: 2017-09942]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. EL17-73-000]

New Jersey Boroughs of Milltown, Park Ridge, and South River v.
Public Service Electric and Gas Company; Notice of Complaint

    Take notice that on May 9, 2017, pursuant to section 206 of the
Federal Power Act, 16 U.S.C. 824e (2017) and Rules 206 and 212 of the
Rules of Practice and Procedure of the Federal Energy Regulatory
Commission's (Commission), 18 CFR 385.206 and 385.212 (2017) the New
Jersey Boroughs of Milltown, Park Ridge, and South River (Complainants)
filed a complaint against Public Service Electric and Gas Company
(Respondent) asserting that the base return on equity used in
calculating transmission Formula Rates under the PJM Interconnection,
L.L.C. Open Access Transmission Tariff is unjust and unreasonable, as
more fully explained in the complaint.
    Complainants certifies that copies of the complaint were served on
Respondent via electronic mail through its counsel.
    Any person desiring to intervene or to protest this filing must
file in accordance with Rules 211 and 214 of the Commission's Rules of
Practice and Procedure (18 CFR 385.211 and 385.214). Protests will be
considered by the Commission in determining the appropriate action to
be taken, but will not serve to make protestants parties to the
proceeding. Any person wishing to become a party must file a notice of
intervention or motion to intervene, as appropriate. The Respondent's
answer and all interventions or protests must be filed on or before the
comment date. The Respondent's answer, motions to intervene, and
protests must be served on the Complainants.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper using the eFiling link at http://www.ferc.gov. Persons unable to file electronically should submit an
original and 14 copies of the protest or intervention to the Federal
Energy Regulatory Commission, 888 First Street NE., Washington, DC
20426.
    This filing is accessible on-line at http://www.ferc.gov, using the
``eLibrary'' link and is available for review in the Commission's
Public Reference Room in Washington, DC There is an ``eSubscription''
link on the Web site that enables subscribers to receive email
notification when a document is added to a subscribed docket(s). For
assistance with any FERC Online service, please email
<EMAIL_ADDRESS>or call<PHONE_NUMBER> (toll free). For
TTY, call<PHONE_NUMBER>.
    Comment Date: 5:00 p.m. Eastern Time on May 30, 2017.

    Dated: May 10, 2017.
Kimberly D. Bose,
Secretary.
[FR Doc. 2017-09942 Filed 5-16-17; 8:45 am]
 BILLING CODE 6717-01-P


[Federal Register Volume 87, Number 212 (Thursday, November 3, 2022)]
[Notices]
[Pages 66283-66284]
[FR Doc No: 2022-23940]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. ER23-223-000]

EnerSmart Imperial Beach BESS LLC; Supplemental Notice That
Initial Market-Based Rate Filing Includes Request for Blanket Section
204 Authorization

    This is a supplemental notice in the above-referenced proceeding of
EnerSmart Imperial Beach BESS LLC's application for market-based rate
authority, with an accompanying rate tariff, noting that such
application includes a request for blanket authorization, under 18 CFR
part 34, of future issuances of securities and assumptions of
liability.
    Any person desiring to intervene or to protest should file with the
Federal Energy Regulatory Commission, 888 First Street NE, Washington,
DC 20426, in accordance with Rules 211 and 214 of the Commission's
Rules of Practice and Procedure (18 CFR 385.211 and 385.214). Anyone
filing a motion to

intervene or protest must serve a copy of that document on the
Applicant.
    Notice is hereby given that the deadline for filing protests with
regard to the applicant's request for blanket authorization, under 18
CFR part 34, of future issuances of securities and assumptions of
liability, is November 17, 2022.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper, using the FERC Online links at http://www.ferc.gov. To facilitate electronic service, persons with internet
access who will eFile a document and/or be listed as a contact for an
intervenor must create and validate an eRegistration account using the
eRegistration link. Select the eFiling link to log on and submit the
intervention or protests.
    Persons unable to file electronically may mail similar pleadings to
the Federal Energy Regulatory Commission, 888 First Street NE,
Washington, DC 20426. Hand delivered submissions in docketed
proceedings should be delivered to Health and Human Services, 12225
Wilkins Avenue, Rockville, Maryland 20852.
    In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
internet through the Commission's Home Page (http://www.ferc.gov) using
the ``eLibrary'' link. Enter the docket number excluding the last three
digits in the docket number field to access the document. At this time,
the Commission has suspended access to the Commission's Public
Reference Room, due to the proclamation declaring a National Emergency
concerning the Novel Coronavirus Disease (COVID-19), issued by the
President on March 13, 2020. For assistance, contact the Federal Energy
Regulatory Commission at [email protected] or call toll-free,
(886) 208-3676 or TYY,<PHONE_NUMBER>.

    Dated: October 28, 2022.
Debbie-Anne A. Reese,
Deputy Secretary.
[FR Doc. 2022-23940 Filed 11-2-22; 8:45 am]
BILLING CODE 6717-01-P