6.1.12.1. Early Reduction Program

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In December 1992, EPA issued final rules for the early reduction of hazardous air pollutants. 57 FR 61970 (December 29, 1992). If a facility qualifies by reducing hazardous air pollutants by 90 percent (95 percent in the case of hazardous particulate emissions) prior to EPA proposing MACT regulations on the source category, the facility may defer compliance with the new maximum available control technology standards (MACT) for up to six years. Because participation in the program is voluntary, a source must anticipate cost savings or it would not have an incentive to participate. Once a source is accepted into the program it becomes legally obligated to meet the 90 (or 95) percent emission limitation. Trading exists intertemporally in that sources exchange their early reductions for their later reductions.

EPA has shown how such a program can benefit the environment. Assume a source emits 100 tons per year. Under the early reduction program it would emit 10 tons per year. Further assume that MACT would have the source reduce emissions to 2 tons per year in year 5 and thereafter. Table 6-4 illustrates the time profile of emissions. The source has reduced emissions by 360 tons in years 1-4 in exchange for 48 tons of emissions in years 5-10. Total emissions are reduced by 312 tons.

By mid-1993 over 60 chemical plants had asked to participate so as to avoid for 6 years the synthetic organic chemical MACT standard. Other types of facilities also had applied to join the program. Novello and Martineau (1993).

6.1.12.1. Early Reduction Program

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