# Presentation: 167767

## The Designated Representative and Allowance Accounts Under CAIR,CAMR, and the ARP

- EPA Region 7 Workshop
- Kansas City, Kansas
- August 16, 2007
- Robert Miller

## What is a Designated Representative?

- A _person_ authorized by the owners and operators of a facility to:
- Sign, date, & attest to the _truth_, _accuracy_, and _completeness_ of submissions made under CAIR, CAMR, or the ARP.
- The DR must be _the same person_ for CAIR, CAMR, and the ARP.

## What Kinds of SubmissionsDoes the DR Make?

- The DR submits, and attests to the truth, accuracy, and completeness of (among other things):
- Certificate of Representation
- Emissions data reports
- Monitoring plans and certification applications
- Permit applications
- Allowance transfers
- Monitoring petitions

## Who Must Have a DR?

- Any facility that has a unit subject to CAIR, CAMR, or the ARP
- Even if you already have a DR for the ARP, you still need to submit an updated DR form for CAIR and CAMR
- Sources in States that aren’t in the national Hg trading program still must have a DR (for 40 CFR part 75 submissions)

## Who Can Be a DR?

- EPA is not hung up on titles, _but_ . . .
- The DR must be a _person_ (no companies, associations, LLCs, etc.), _and_;
- Must have the necessary authority to carry out his or her responsibilities as the DR, _and_;
- Must be the same person for CAIR, CAMR, and the ARP

## Other Persons Can Act on Behalf of the Designated Representative

- Alternate Designated Representatives
- Agents
- Source management agents
- Allowance trading agents
- Compliance agents
- General accounts management agents
- The DR is _still_ ultimately responsible for all submissions made on behalf of the owners and operators of the facility

## How Does a PersonBecome a DR?

- Submission of a complete Certificate of Representation (DR form) to EPA HQ (CAMD) establishes the DR (and ADR, if applicable) for the facility.
- There is no deadline for submission of the DR form, but it _must_ be submitted _before_ any _other_ submission can be legally made under CAIR, CAMR, or the ARP.

## Certificate of Representation

- Facility name, State, and plant code (same as ORIS or facility code)
- County name where the _facility_ is located
- Latitude and longitude of the facility
- Name, title, company name of DR
- Fax, Phone, and email address (_not_ an option)

## DR Form (cont’d)

- For each _unit_ subject to CAIR, CAMR, or the ARP, fill out _one_ “Page 2”
- Check the box(es) indicating the Program(s) the unit is subject to
- Duct burners and steam turbines are _not_ listed
- Indicate the unit type

## DR Form, Cont’d

- Page 2, cont’d.
- Enter the source category
- NAICS code (Census Bureau)
- Commence commercial operation date:
-  The date the unit first served a generator that produced electricity for sale

## DR Form, Cont’d.

- Page 2, cont’d.
- Enter the generator ID #
- Enter the nameplate capacity of _each generator served by the unit_ in MWe
- For ARP-affected units in NADB: use “NAMEPCAP” in NADB for ARP nameplate capacity

## DR Form, Cont’d.

- Page 2, cont’d.
- For CAIR-CAMR affected units, & ARP affected units _not_ in NADB, use the higher of 2 numbers for both ARP & CAIR-CAMR nameplate capacity:
- Manufacturer’s rating for maximum electrical generating output capacity, or;
- If physical change increases maximum electrical generating output, the increased maximum electrical generating output

## DR Form, Cont’d.

- For each owner or operator of the unit, list the company name and check the owner and/or operator boxes.
- Read the appropriate certification statements, and have the DR (and ADR, if applicable) sign and date the form.

## Submitting the DR Form

- Hardcopy submissions:
- EPA must receive _originals_ (no faxes)
- Form _must_ be complete, even if only minor changes are being made
- In a hurry? Overnight mail is best if CBS not an option, **OR . . . . .**

## CAMD Business System

- CAMD Business System offers alternative to paper form for Cert. of Rep.
- Saves on work of filling out multiple forms
- Allows the designation of “Agents” to perform on-line functions
- All allowance account management can be done here
- _[https://camd.epa.gov/cbs/](https://camd.epa.gov/cbs/)_

## Allowance Management System

- EPA’s system for tracking all allowance activity
- Maintains information on:
- accounts and their representatives
- the issuance of all allowances
- the holdings of allowances in accounts
- the transfer of allowances between accounts
- the deduction of allowances for compliance purposes

## Allowance Accounts 

- Compliance Accounts
- accounts for affected sources
- General Accounts
- For any person or organization
- State Accounts
- Basic allocation authority
- Set asides for new units, energy efficiency, etc

## Compliance Accounts

- Established for each affected source via Certificate of Representation
- One account for Acid Rain/CAIR/CAMR programs
- Account Numbers
- 12 digits
- first six digits are ORIS/facility code and second six digits are “FACLTY”

## General Accounts

- Available for any individual or organization
- Established by submitting form
- name and contact information for account representative [and alternate]
- signature
- list of all persons with ownership interest in the allowances held in the account
- 12 digit account number, always begins “9999”

## State Accounts

- Each State has basic authority account equal to State budget
- States have CSP authority in CAIR NOx Annual Program
- From within the State trading budget, States may choose to set aside a portion of the budget
- New unit set-asides
- Energy efficiency or clean air
- State accounts always begin with the two-letter State abbreviation

## DRAFT Allowance Transfer & General Account Forms

- Should be finalized by the end of Summer or Fall 2007
- Transfer form allows the transfer of one type of allowance only (CAIR NOx Annual, CAIR NOx Ozone, CAMR, or Acid Rain)
- General Account form can be used to open an account for multiple programs
- Most allowance transactions can be performed online via CBS!! https://camd.epa.gov/cbs

## Data on the Web

- Data and Maps web site
- http://cfpub.epa.gov/gdm/
- Available from CAMD home page
- All allowance information is publicly available
- Accounts
- Allocations
- Representatives
- Transfers
- Deductions for emissions