Memo from the Director
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF AIR AND RADIATION
TO: Members of the Updating Output Emission Limitation Workgroup and the Clean Air, Energy, and Climate Change Subcommittee
FROM: Brian McLean, Director, US EPA/Clean Air Markets Division (formerly the Acid Rain Division)
DATE: May 9, 2000
SUBJECT: Final Guidance Document on Output-Based NOx Allowance Allocations
In February, EPA gave an update on the workgroup's accomplishments to the Clean Air, Energy, and Climate Change subcommittee of the Clean Air Act Advisory Committee. In that presentation and in a memorandum to the workgroup, we stated that EPA would produce a final guidance document for distribution on the workgroup's website. We have now posted the final document (PDF) (222 pp., 2.4 MB) on the Workgroup's Web site and include it as an attachment to this e-mail.
Thank you for your comments on the previous draft of the guidance document. The final document includes many enhancements, as suggested by various members of the workgroup. Among the changes to the document are:
- Changing the emphasis of the discussion on net and gross output to focus on net output as the basis for allocations, but to also provide reasons for cases where gross output may be an appropriate basis.
- Recommending separate allocations for electric generating units and for non-electric generating units.
- Changing the allocation factor for thermal output based on 70% boiler efficiency.
- Providing two approaches to monitoring thermal output, depending on whether an industrial boiler or cogenerator measures condensate return to its boiler or heat recovery steam generator.
- Including additional diagrams and monitoring examples for cogeneration facilities, including cases with auxiliary firing.
- Tightening the standard for accuracy in measuring output and adding greater flexibility in the consensus standards that might be used.
- Providing three options for the degree of detail in monitoring output that a State might require.
Because of these many enhancements, we were unable to complete the guidance document until now. At our last meeting, workgroup members suggested that EPA should prepare a discussion of issues related to monitoring and reporting of output data. We have put this discussion in Section VII of the guidance document. For those of you with sources affected under the Acid Rain Program or the OTC NOx Budget Program, we hope you will discuss these issues with associates involved in monitoring and reporting and comment on this section of the guidance document.
We hope to receive any comments you may have on the issues discussed in this guidance document as we prepare a proposed rule providing for output-based allocations in a federal NOx Budget Trading Program. Your comments would be most helpful if we receive them by Friday, May 26, 2000. Please send your comments to Margaret Sheppard of my staff:
Via express mail:
U.S. EPA, Clean Air Markets Division
633 3rd St. NW
Washington DC 20001
Via U.S. Postal Service (note new address):
U.S. EPA, Clean Air Markets Division
Mail Code 6204N
1200 Pennsylvania Avenue NW
Washington, DC 20460
Several of you suggested that we should clarify the relationship of this document to EPA's section 126 rulemaking (including part 97, the federal NOx Budget Trading Program). We believe that the appropriate focus of this document is to fulfill the commitment we made in the final NOx SIP Call notice to give States information that they may use as they prepare their State Implementation Plan submittals in response to the NOx SIP Call. We expect to take comment on various issues related to the guidance in our upcoming rulemaking for part 97. In order to establish EPA's policy only after considering public comments on that rulemaking, we decided not to provide recommendations on these issues in the guidance.
You have been extremely helpful to the Agency as we have considered the technical issues involved in measuring output. We are looking forward to hearing from you further. If you have any questions or comments, you may contact Margaret Sheppard by telephone (202-564-9163) or by e-mail (firstname.lastname@example.org).