Comments
on
Section
IV
of
IAQR
SNPR
 
Page
10:
This
seems
to
allow
states
to
opt
out
of
cap­
and­
trade
program
relatively
easily.
My
understanding
was
that
opting
out
would
not
be
easy.
Perhaps
you
should
clarify?
 
Page
14,
18:
If
a
state
caps
non­
EGUs,
does
that
mean
that
they
cannot
include
their
EGUs
in
the
trading
program?
 
Page
18,
paragraph
2:
This
paragraph
states
that
if
states
choose
to
include
non­
EGU
sources
in
this
program,
the
states
must
impose
a
cap
on
these
sources,
or
if
this
is
not
"
practicable,"
adopt
another
system
to
measure
if
the
reductions
have
been
obtained.
In
general,
trying
to
measure
reductions
from
a
baseline
and
not
requiring
a
cap
seems
like
a
bad
idea.
It
opens
the
system
up
to
the
same
gaming
opportunities.
It
is
also
unclear
to
me
why
this
would
ever
be
necessary
­­
if
firms
can
calculate
an
appropriate
baseline
etc.,
why
can't
a
cap
be
calculated?
 
Page
19,
paragraph
2:
This
paragraph
suggests
that
states
choose
a
baseline
year
between
2002
and
2005
for
NOx
and
Sox
emissions
from
non­
EGU
sources.
Requiring
the
baseline
to
be
an
average
would
lessen
the
ability
of
sources
to
cherry­
pick
the
most
favorable
baseline
year.
 
Page
59:
"
Based
on
that
modeling,
EPA
has
proposed
that
if
States
achieve
all
of
the
mandated
NOx
reductions
by
including
their
EGUs
in
the
regionwide,
annual
NOx
capand
trade
program
managed
by
EPA,
EPA
will
consider
the
reductions
from
that
program
to
also
meet
the
ozone
season
reduction
requirements
that
States
were
previously
achieving
from
EGUs
participating
in
a
regionwide
ozone
season
NOx
cap
and
trade
program."
Does
this
mean
that
if
a
state's
EGUs
are
part
of
the
new
program,
then
they
are
absolved
of
responsibility
in
the
NOx
SIP
Call?
Or
does
it
mean
that
they
count
only
their
reductions
from
the
first
program
against
the
second
program,
thus
perhaps
still
being
part
of
both
programs?
If
the
latter,
then
might
this
invite
restrictions
on
trading
to
other
states?
 
Page
60:
Non­
EGUs
will
have
many
fewer
trading
partners.
Page
60­
61:
"
EPA
considered
whether
it
would
be
appropriate
to
allow
States
to
include
non­
EGUs
in
the
annual
IAQR
trading
program
and
relieve
them
from
the
requirements
of
the
ozone
season
NOx
trading
program."
This
seems
like
a
more
sensible
approach.
I
can't
remember:
has
this
been
discussed
and
dismissed
already?
