2015 Ozone Standards and Current and Potential Shortage of Emission Reduction Credits

The 2015 NAAQS Ozone Standard is creating new non-attainment areas across the country which includes 2 in Texas (San Antonio and El Paso areas). These areas start with no Emission Reduction Credit (ERC) Registry and new major source facilities over certain thresholds of NOx and VOC emissions may face a difficult challenge to permit new facilities. What is the current status of the historical ERC trading programs in the long standing non-attainment areas (Houston, Baton Rouge, Dallas, California and Northeast). What lessons can be learned. Any interstate trading allowed? Any inter-pollutant trading allowed? How can companies mitigate these risks? As industry becomes more efficient and cleaner there are less opportunities to generate ERCs which are desperately needed for future growth. 

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