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Clean Air Action Corporation Implements Breakthrough Technologies and Approaches
If you need outside-the-box thinking and action, contact Charlie Williams at +1 (918) 747-8770 today. We don't just talk about it: we make the air cleaner in ways others can't even imagine... The First Ozone Alert ProgramOzone Alert programs are now a common way for cities and towns to alert the public and industry about steps they can take to reduce emissions when weather conditions that contribute to high ozone (smog) levels are forecast. CAAC helped establish the first ozone alert program in 1991 in Tulsa, Oklahoma. Tulsa twice exceeded the National Ambient Air Quality Standard for ozone. In response, CAAC brought together a group of concerned public officials, citizens, and industry leaders to find a way to combat the ozone problem. We educated the public on steps they could take to reduce their contributions to ozone on days when the weather was likely to produce dangerous smog levels. For example, individuals could: limit driving, especially during peak traffic periods; minimize "cold starts"; avoid excessive idling; refrain from mowing the lawn or barbecuing; and more. Not only do Ozone Alert programs reduce the incidence of ozone, they also enable citizens to take responsibility for their personal impact on the environment and do something positive about it. Ozone Alert programs now exist in over seventy U.S. cities. The First Multi-stakeholder Trading InitiativeAfter the city of Tulsa, Oklahoma exceeded the National Ambient Air Quality Standard for ozone, CAAC brought together a group of concerned public officials, citizens, and industry leaders to create an environmental incentive system whereby Tulsa businesses would be able to take actions to reduce their air pollution emissions. These actions would have a value that could then be traded with other businesses. This program, called MERIT, for Maximizing Emission Reductions through Inter-source Trading, was the first multi-stakeholder trading initiative in the country. As it turned out, thanks to MERIT and the Ozone Alert! Program, Tulsa was able to stay in attainment for ozone and has been in attainment ever since. The First Interstate Multi-stakeholder Trading InitiativeClean Air Action Corporation was one of the key members in the development of the first interstate multi-stakeholder trading initiative, the NESCAUM/MARAMA Demonstration Project, which was implemented from 1993 to 1996. The purpose of the project was to develop and test principles for emission reduction trading as an effective tool for achieving the goals of the Clean Air Act Amendments of 1990 faster and more efficiently than could otherwise be achieved under traditional command-and-control. These days we have ample evidence of the effectiveness of emission trading, in the success of the SO2 allowance trading component of the Acid Rain program, and by the seven states that currently have trading systems in place for NOx. Back in 1993, however, emission trading was a good idea in theory, but lacking empirical validation. Clean Air Action Corporation worked with state regulators and the project's industry volunteer participants to develop the rules and procedures for what eventually became an open market trading system for NOx and VOCs. Private sector participants invested millions of dollars implementing emission reduction strategies, and generating technical data to document the reductions. Several participants risked future enforcement action to demonstrate that use of discrete emission reductions is a viable compliance alternative to installation of control equipment. The project was a huge success: It demonstrated that a market for discrete emission reductions (DERs) existed, and that use of DERs for compliance with federal or state emission requirements may save firms anywhere from 50 – 500% of the cost of employing on-site emission control technology. It achieved consensus that 'real, quantifiable, and surplus' are the three critical criteria for creation of usable emission reductions. Participants reviewed and endorsed technical drafts of protocols for creation of discrete emission reductions from both mobile and stationary source strategies. It established procedures for the allocation of interstate discrete emission reductions generated by mobile or stationary source strategies with a regional impact. Participants reviewed a model private registry for tracking the creation, transfer, and use of DERs, and model reporting forms for use in conjunction with the creation, transfer, and use of DERs. It facilitated the development of model single-source state implementation plan (SIP) revisions to facilitate the use of DERs as a compliance alternative. The NESCAUM/MARAMA Demonstration project influenced the NOx trading programs that were eventually implemented in Massachusetts, New Hampshire, Connecticut, New Jersey, Texas, and Michigan. A partial listing of firms who participated in the NESCAUM/MARAMA Demonstration project:
The First Open Market VOC TradeIn 1993 Clean Air Action Corporation worked with Getty Oil to develop a protocol to demonstrate the feasibility of using emission reduction credits to facilitate the use of ethanol as an oxygenate in reformulated gasoline. The protocol sought to show how lower RVP fuel could be used to offset higher RVP ethanol blended gasoline. This would be a significant benefit to makers and users of gasoline in ozone non-attainment areas, which require the use of reformulated gasoline. The First Interstate TransactionIn 1995, Food Specialty Ingredients, Inc., located in Connecticut, bought two tons of NOx created in New Jersey by PSE&G. CAAC facilitated this trade, which was the first interstate emission reduction credit transaction to take place. The First International TransactionIn 1996, CAAC facilitated the first-ever international emission reduction transaction, which took place between Ontario Power Generation and Detroit Edison Company. During the first half of 1996, DECO produced 13,298 tons ozone season NOx and 7,647 tons non-ozone season NOx by installing low-NOx cell burners on their fossil-fuel fired steam generating boilers. OPG bought 400 tons of those reduction credits to meet part of its voluntary commitment to the Ontario Ministry of Environment. First Use for Alternative ComplianceIn 1995 Pfizer Corporation had determined it would be impossible for it to meet Connecticut's Reasonably Available Control Technology (RACT) requirements for ozone on all its boilers by modification of the units by the State Implementation Plan (SIP) deadline of May 31, 1995. Equipment delivery and installation timelines and constraints prevented timely completion on all units. But halting use of certain boilers would have caused production cutbacks that could have adversely affected more than 700 manufacturing jobs. Equally important, Pfizer's research operation could have been disrupted. Clean Air Action helped Pfizer avoid this unpleasant scenario by acquiring emission reduction credits for the amount of NOx emissions that would have exceeded the new standards between May, 1995 and May, 1996. They bought 3,178 tons of NOx emission reduction credits from Public Service Electric & Gas of New Jersey, created by switching fuel from coal to natural gas. The First Flexible Attainment RegionPrior to the passage of the Clean Air Act Amendments of 1990, the Tulsa Metropolitan Area was designated as attainment for ozone. In 1991, however, Tulsa experienced two exceedances of the ozone standard, and faced the possibility, with one more exceedance during the next two ozone seasons, of being redesignated as non-attainment. While the immediate response was to institute an Ozone Alert! Program, to attempt to prevent further exceedances on a voluntary basis, municipal authorities sought a more permanent solution to the problem of being on "the edge." The result was a proposal for a Flexible Attainment Region (FAR) that recognized the need for more certainty in planning, both for the business community and the public sector. The local support structure was largely in place, thanks to the Ozone Alert! Program, and the FAR proposal enjoyed the approval of the business community. Spearheaded by the Mayor, with the assistance of both the city government and the regional council of governments, as well as the state air quality agency, Tulsa made its case for the need for a more flexible response to the possibility of one more exceedance, which would have caused redesignation. What the community proposed was based on the following. Tulsa’s air quality, for the most part, met the requirements of the ozone standard, and it was clear that there was no persistent or regular ozone problem. There were occasionally, however, incidents of elevated levels of ozone that could prove unhealthful. The community was operating a voluntary reduction program which had thus far been successful in educating the public about air quality issues, and in changing behavior patterns on days with the potential for elevated ozone levels. In part, these efforts had prevented any further exceedances of the standard. Thus a third exceedance, it was argued, should not automatically trigger a full-scale non-attainment program. The community recognized and acknowledged, however, that some additional actions would be necessary should a third exceedance occur. With the full support of local industry, the city proposed that the most appropriate response to a third exceedance was a flexible one, with additional emission reductions being made from appropriate sources until the ozone standard was once again attained. A list of potential reductions and sources was prepared, again with the support of local industry. Under the proposal, Tulsa would have three years to implement these additional reductions and to bring the region into attainment. With the support of local and state government, as well as affected industries and the public, Tulsa made this proposal to the USEPA. After some negotiations, the proposal was approved by USEPA’s regional office in 1994, and the Tulsa Metropolitan Area became the nation’s first FAR. |
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Are you faced with a situation for which there is no precedent? Have you ever wanted to change the status quo? Ever wondered if there is a better way? If so, you'll be happy to know that Clean Air Action Corporation is the leading catalyst for change in air emissions compliance today, having been involved or responsible for the following breakthroughs: