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Clean Air Mercury Rule. Clean Air Mercury Rule. EPA Rule to Control Mercury Emissions from Coal-Fired Electric Utilities New Source Performance Standard (CAA 111) Allows for Mercury Emissions Trading National Cap Distributed by EPA to States
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Clean Air Mercury Rule • EPA Rule to Control Mercury Emissions from Coal-Fired Electric Utilities • New Source Performance Standard (CAA 111) • Allows for Mercury Emissions Trading • National Cap Distributed by EPA to States • States Distribute Mercury Allowances to Facilities
Clean Air Mercury Rule (CAMR) Published May 18, 2005 [70 FR 28605] • Amended NSPS Subpart Da Hg emission limits for utility units constructed after January 30, 2004 • NEW Subpart HHHH – Trading Program • State Hg budgets • Model Trading Rule • Performance Specification 12A – Hg CEMS • 40 CFR Part 75, Appendix K – Sorbent Traps
State Responsibilities Rulemaking: • Submit NSPS plan to EPA by November 17, 2006 • Notify EPA of Hg allowance allocations by October 31, 2006 (if adopt interstate trading program) for 2010, 2011, 2012 Administration: • Issue Hg Budget permits – modify Title V permit • Review monitoring system certifications • Enforcement for exceeding allowances held
Mercury Allowances: CA, CO, HI, ND, NV, SD, UT, WY CAMR Is this Really “Excess?” Q: What to Do with “Excess?” A: Need to Validate Reported Figures TRI
Mercury Allowances: AK, AZ, MT, NM, OR, WA Is this Really “Shortage?” TRI Q: What if There’s No “Excess?” A: Need to Validate Reported Figures All States Will Be Challenged to Determine Their Role, Fate CAMR
Clean Air Mercury Rule • Red Flag • EPA developed rule with the idea that technology for mercury control will not be adequately demonstrated until after 2010 • Used $39,000 per pound in 2020 in analysis/calculations • 2005 Congressional Hearing (Institute for Clean Air Companies) estimated current control $2000) • EPA’s own analysis projects actual emissions to be 24.3 tons as 2020s (estimates outside EPA for full compliance is 2030) • Rule’s underpinnings are influenced by this • State Budgets (Allowances) • CAP & Trade • KEY PRINCIPLE cost of emission control is varied from high to low • Company’s adopt known current technologies to avoid future risk
Clean Air Mercury Rule Banking