How do we get areas into attainment

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• Homework 2 due Feb. 27 (Janine is in charge
  of this one.)
• This weeks discussion section now online.
• The Way We Live Now Why Bother?
• No hard copy (OK?)
• Grants to attend Powershift09
• For 2 students
• Send me your name if youre interested. I will
  draw names on Friday.

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Memo 1 due March 6

• Choose a current environmental policy issue.
• How to get ideas (if you dont have one).
• Write with a co-author (if you want).
• Focus on a policy, not a problem.
• Every big policy has lots of little policies.
• I am not expecting you to read the law itself or
  the Federal Register. (OK if you do, of course.)

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• Format
• Short, block paragraphs (required.)
• Use sub-headings (required.)
• Be careful of plagiarizing
• Try to avoid policies that dont do anything
  substantive.
• What about policies that only spend money?

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SO2 auction

• Yearly auction of 125,000 allowances in March.
• Why Congress included an auction in the law.
• Here are the results from the 2008 auction

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Todays class

• Acid Rain Trading, wrap-up
• Student comments
• Clean Air Interstate Rule
• Hazardous air pollutants (if time)
• Mobile sources
• Performance of the Clean Air Act

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Cap-and-trade student comments

• Under cap-and-trade, a plant can actually
  increase its pollution.
• If the price of allowances is low, then plants
  wont invest very much in pollution control.
• Under cap-and-trade, a plant can sometimes
  exceed its limit by buying allowances from
  someone else.
• (Note to myself for 2010 Go over a shorter list
  of comments. Two or so are sufficient for
  students to get the point.)

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• If a plant has allowances to sell, that means it
  could have reduced its pollution. Therefore, we
  should have set a lower cap.
• Cap-and-trade is OK, but we should still require
  tough pollution control by new sources.
• Should you try to raise money to buy allowances
  (and retire them)?

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• ARTP has been considered a success
• (One obvious reason two less obvious)
• Allowance prices
• Small bureaucracy
• Transparent Both pollution levels and control
  costs can be easily tracked.

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• Potential and actual drawbacks
• Local problems (Not a problem for SO2)
• The market must work. (Not a problem for SO2)
• Did not entirely remove NSPS or NSR.
• Transport This is a problem.

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The transport problem

• Definition
• Clean Air Interstate Rule (CAIR) (March 2005)
• Each state given an SO2 NOx budget
• Each state can
• Participate in a CAIR cap-and-trade or
• (ii) Choose other methods to reduce emissions.
  (SIP)
• Eastern states only
• Struck down by the courts (Dec. 2008)

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• Section 112 Hazardous Air Pollutants (HAPs)
• List of pollutants
• Relies heavily on command-and-control.
• Maximum Achievable Control Technology
• Before 1990, regulations had been issued for only
  seven HAPs. (Why?)

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• Section 112
• (2) Standards and methods Emissions standards
  promulgated under this subsection and applicable
  to new or existing sources of hazardous air
  pollutants shall require the maximum degree of
  reduction in emissions of the hazardous air
  pollutants subject to this section (including a
  prohibition on such emissions, where achievable)
  that the Administrator, taking into consideration
  the cost of achieving such emission reduction,
  and any non-air quality health and environmental
  impacts and energy requirements, determines is
  achievable for new or existing sources

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• This is as far as we got in class.

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Clean Air Act, cont.

• Mobile sources
• Vehicles
• Fuel
• Vehicles
• Emissions standards for new vehicles
• Nationwide (why?)
• NOx Require a 90 percent reduction by 1976
• DO NOT CONFUSE WITH MILEAGE STANDARDS (CAFE)

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• Sec. 202. (a) Except as otherwise provided in
  subsection (b)- (1) The Administrator shall by
  regulation prescribe (and from time to time
  revise) in accordance with the provisions of this
  section, standards applicable to the emission of
  any air pollutant from any class or classes of
  new motor vehicles or new motor vehicle engines,
  which in his judgment cause, or contribute to,
  air pollution which may reasonably be anticipated
  to endanger public health or welfare.

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Mobile sources, cont.

• New vehicles
• Technology-forcing
• Existing vehicles
• State Inspection and Maintenance Programs
• Fuels
• Standards may differ regionally
• Recall, this is about air pollution, not fuel
  economy.

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Massachusetts vs. EPA (decided April 2, 2007)

• One of the most important environmental
  decisions by the Supreme Court in years. (Adler)

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• Massachusetts v. EPA
• Several states, cities, and environmental groups
  sue EPA.
• They argue EPA is required to regulate CO2 from
  mobile sources.
• Because of Section 202

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• Counter-arguments/questions
• Is CO2 an air pollutant (as defined by CAA)?
• Does EPA have to issue regulations for air
  pollutants?
• If Congress had wanted EPA to regulate CO2, it
  should have said so.
• Other agencies are responsible for mileage
  standards.
• Does this ruling affect other sources, by
  requiring EPA to set up NAAQS for CO2?
• Eventually, probably yes

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EPA May Reverse Bush, Limit Carbon Emissions From
Coal-Fired Plants

• By Steven Mufson and Juliet Eilperin
• Washington Post Staff Writers
• Wednesday, February 18, 2009 Page A02
• The Environmental Protection Agency will reopen
  the possibility of regulating carbon dioxide
  emissions from coal-fired power plants, tossing
  aside a December Bush administration memorandum
  that declared that the agency would not limit the
  emissions.

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Clean Air Act reconsidered

• Successfully amended in 1990
• Air quality has improved!

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Remaining issues

• Transport problem
• Area sources
• Formerly small, now a major source of emissions.
• Consumer product manufacturing guidelines
• PM and Ozone still a problem.

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• Friday Clean Water Act
• I am moving this forward in the syllabus