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OAR Box 1802 

Prepped by Charmelle Mathews 

Document Number: 

47) IV-E-42 

Docket Number: 

A-90-37 

Printed 11/4/200811:57:59 AM Sheet 47 of 117 
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MEETING SUMMARY 

STAKEHOLDER MEETING 

SECTOR-BASED APPROACH 

January 13, 2000 

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ccn 2 5 200Q 

EPA AIR DOCKET 

The meeting was held in the Polaris Room at the Ronald ReagaiTBuilding and 

International Trade Center, 1300 Pennsylvania Avenue, Washington DC 20004. The meeting 

began at approximately 10:00 am and closed at approximately 3:30 pm. Attached is a list of 

attendees. 

INTRODUCTION 

Bob Perciasepe (EPA Assistant Administrator for Air and Radiation) opened the meeting 

with some introductory remarks. He noted that EPA has been working on New Source Review 

(NSR) reform for a long time, and that there were three pieces of reform under consideration. 

First, there is the review of NSR proper - looking to clarify, simplify, and improve the base 

program. Second, there is the plantwide applicability limit (PAL) concept, with which EPA has 

had some success under Project XL experimentation. Third, there is the sector-based approach 

that will be discussed today. Mr. Perciasepe noted that EPA is intrigued by this approach that 

has been derived from stakeholder ideas, and wanted to learn more about how it would work. 

Mr. Perciasepe then gave his view of NSR. The intent of NSR is that, over time, as 

capital infrastructure is improved (through new capacity, efficiency improvements, rebuilds), 

cleaner units will result. A fundamental concept is that as capital stock improves, there should be 

an improvement in emission profiles. He wondered if this concept might be more easily 

achieved by looking at this more holistically on a sector basis. 

Mr. Perciasepe cautioned that EPA was not unveiling a new proposal today. He was 

aware that the meeting was receiving media attention, and wanted to be clear that the purpose of 

this meeting was to share thinking on what the issues are. EPA structured the meeting to 

promote cross-fertilization of ideas. The process is at a juvenile stage, and wrought with hurdles. 

The sector-based approach is a concept EPA is interested in. EPA has done some thinking of the 

approach, and noted that there are emerging themes and some consensus on what the approach 

might include. During today's meeting, EPA will present some of its preliminary thinking. 

Mr. Perciasepe also wanted to ensure that there was no mis-communication with 

members of Congress. He assured that EPA will not do anything not in keeping with the law. If 

this approach moves forward, EPA will use the normal process, beginning with a Notice of 

Proposed Rule Making, etc. which was still down the road. 

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Mr. Perciasepe joked that people looking for news should attend the Administrator's 

news conference at noon rather than attend this stakeholder meeting. 

OPENING REMARKS 

Bill Harnett (Acting Director, EPA Information Transfer and Program Integration 

Division) then discussed the ground rules for the meeting and asked for cooperation in sticking to 

the timetable for the meeting. He briefly went over the Agenda for the meeting that was 

distributed to all attendees. See Attachment I for the distributed Agenda. 

Mr. Harnett asked each person at the main table to state their name and affiliation. The 

following people were seated at the table: 

Bob Perciasepe (Assistant Administrator, EPA/OAR) 

John Seitz (Director, EPA/OAQPS) 

Bill Harnett (Division Director, EPA/OAQPS/ITPID) 

Karen Blanchard (EPA/OAQPS/ITPID) 

Kathy Kaufman (EPA/OAQPS/ITPID) 

Alan Eckert (EPA/OPAR) 

Anna Wood (EPA/OPAR) 

Greg Foote (EPA/OGC) 

Bruce Buckheit (EPA/OECA) 

Rich Fisher (Federal Land Manager) 

John Bunyak (Federal Land Manager) 

Christine Shaver (Federal Land Manager) 

Christopher James (State of Connecticut) 

Praveen Amar (Northeast States for Coordinated Air Use Management - NESCAUM) 

William O'Sullivan (State of New Jersey) 

Bill Becker (STAPPA/ALAPCO) 

John Paul (Dayton Regional Air Pollution Control Agency) 

Joe Goffman (Environmental Defense Fund) 

Charles McPhedran (Penn Futures) 

David Wooley (Clean Air Task Force) 

David Hawkins (Natural Resources Defense Council) 

Becky Stanfield (US Public Interest Research Group) 

Michael Florentino (Clean Air Council) 

Sue Hedman (Environmental Law Center) 

Conrad Sneider (Clean Air Task Force) 

Bill Grant (Izaak Walton League) 

Larry Shapiro (NY Public Interest Research Group) 

Mark Brownstein (Clean Energy Group) 

Michael Bradley (Clean Energy Group) 

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Joel Bluestein (EEA/Trigen) 

Bill Bumpers (Class of 85) 

Rob Brubaker (Ohio Utilities) 

Mark Hall (Trigen) 

Quinlan Shea (Edison Electric Institute) 

Henry Nickel (Utility Air Regulatory Group) 

Greg Signer (Tennessee Valley Authority) 

Rae Cromiller (NRECA) 

Bob Sussman (Cinergy/WEPCO) 

OVERVIEW OF NSR ALTERNATIVE SECTOR-BASED APPROACH 

Kathy Kaufinan (EPA/OAQPS/ITPID) then made a presentation of EPA's ideas and 

questions regarding the sector-based approach. See Attachment II for Ms. Kaufman's slides. 

Slide 1 - Goal 

Slide 2 - General Framework 

Slide 3 - Basic Requirements 

Slide 4 - Overall Issues 

Slide 5 - Basic Requirements Issues 

Slide 6 - Should There Be Trading? 

Slide 7 - Trading/Averaging Issues 

Slide 8 - State and Federal Roles 

Slide 9 - Timeframes and Target Levels 

BASIC REQUIREMENTS DISCUSSION 

Mr. Harnett then asked the group to begin considering the issues raised in Ms. Kaufinan's 

presentation. He first asked whether the sector-based approach should be limited to coal-fired 

units, or whether it should include other fuel types. 

Henry Nickel (Hunton & Williams, representing Utility Air Regulatory Group - UARG) 

thought that the integrated approach proposed by UARG for the utility industry was a good idea, 

and that the industry also supported a backstop program. He said that possibly the so-called 

"off-ramp" could be focused on coal-fired plants. He stressed, however, that changes to the basic 

program, such as the potential-to-potential or maximum hourly test, are still desired by all of . 

industry, and should cover all units including oil- and gas-fired units. 

Mr. Harnett indicated that EPA was evaluating how to give sources flexibility and asked 

what the basic principles of the sector-based approach should be. 

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Bob Sussman (representing Cinergy, WEPCO) questioned whether NSR was the proper 

mechanism for this type of program. He noted that an integrated strategy for the utility industry 

is important, but was not convinced that it was practical to use NSR as the vehicle for the 

integrated strategy. He suggested an alternative strategy that "achieves broader, multi-pollutant 

environmental goals" and presented the following six principals that should govern such an 

integrated strategy: 

1. Long-term regulatory certainty and stability 

2. Comprehensive (current vs future, all pollutants in a sector) 

3. Control levels/dates should be tied to public health and environmental goals, and not simply 

based on available technology 

4. Broad participation from industry (otherwise emissions reduction may not be significant and 

may result in competitive disadvantages for those who participate) 

5. Market-based tools needed (pointed to Title IV and NOx SIP call as models) 

6. Still need to streamline basic NSR and make it flexible to allow efficiency improvements. 

Mr. Sussman stated that NSR was not the vehicle to achieve these elements. Rather, he indicated 

that Cinergy, WEPCO, and TVA had drafted a Memorandum of Understanding (MOU), called 

the "Partnership for an Integrated Strategy....", calling for an integrated strategy for SOx, NOx, 

C02, and mercury that would be air quality based, not control technology based. The MOU 

would set goals and legally binding emission limits, and that EPA would not interfere over the 

time period. He indicated that the MOU would not be exclusively based on NSR, but would 

include NSR as a part. Other programs included in the MOU would be PALs, cap-and-trade etc. 

Once agreement was reached on the MOU, rules would be put in place to make limits legally 

enforceable. He did not know whether there was sufficient authority in the Clean Air Act for this 

approach, and therefore may need legislation to implement it. He said that the MOU could serve 

as a framework for pursuing legislation. He indicated that the fleshed-out MOU would be 

available in the near future. 

Mr. Perciasepe acknowledged the question of whether NSR was the proper vehicle for an 

integrated utility strategy, and indicated that it could be discussed separately. Mr. Harnett 

indicated that the MOU should include CO and particulate matter (PM). 

Joel Bluestein (EEA/Trigen) stated that with respect to the goal of providing certainty and 

flexibility mentioned in Ms. Kaufman's presentation, the sector-based approach could not be 

limited to a small segment of the industry and that the entire broad sector should be looked at, 

e.g., it should cover all power generation, not just utilities. He also said that it was hard to 

discuss the approach without knowing the details, but at least the goal needs to be broader. 

David Hawkins (Natural Resources Defense Council) said he supported a number of the 

principles stated by Mr. Sussman. He had to disagree, though, on Mr. Sussman's third principle 

that targets should be based on environmental need, not available control technology. 

Mr. Hawkins reminded the group that the Clean Air Act includes both ambient (health-based) 

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and "best practices" approaches. Each have strengths/weaknesses. He noted that the battle over 

the recent ozone/PM NAAQS revision is a reminder of the difficulty of getting agreement using 

only a health-based approach. He stated that both approaches need to be retained. 

Mr. Hawkins also said that EPA still needs to focus on basic NSR reform. He contrasted 

the lack of success of the NSR program with the motor vehicle program. High polluting cars 

manufactured in the 60's and 70's have gradually been replaced and now represent only a small 

fraction of the entire fleet and the corresponding emissions. In contrast, older power plants still 

emit a large proportion of emissions, e.g., 84% of NOx emissions. He indicated that the 

grandfathered sources are not going away unless NSR is improved. 

Praveen Amar (NESCAUM) stated that, with respect to whether the approach should 

include only coal-fired units or other units as well, it was proper to start with coal-fired plants, 

since that is where most of the emissions are coming from, e.g., almost all of S02 and a 

significant percentage of NOx. 

Mark Brownstein (Clean Energy Group) stated the Mr. Sussman's proposal is basically 

consistent with the Clean Energy Group's proposal. If the solution lies in the legislative arena, 

there are a number of bills currently in the Congress that include these ideas and that he could 

recommend to Mr. Sussman to investigate. 

Mr. Brownstein then stated what he believes is needed to be included in the sector-based 

approach. It needs to look at all fuel types. Pure economics drive business decisions, and all 

costs must be included. Environmental costs must be included up-front, otherwise business 

decisions are affected. His group does not care about fuel type, but rather is looking to generate 

electricity at the lowest possible price. So it is important to have environmental costs identified 

prior to business decisions. Also, the approach should be consistent with NSPS for NOx for 

utility boilers, which he thought was a good program. 

Christopher James (State of Connecticut DEP) stated, half jokingly, that some people 

believe NSR is quite good. He appreciates industry's need for flexibility and certainty, but not 

on a compartmentalized basis, i.e., not on a sector basis. He would like EPA to go forward with 

a comprehensive program that includes multiple pollutants and a broad coverage of sources, not 

just the interests represented at the table today. He applauded EPA's efforts in taking on an 

integrated approach. 

Bill Bumpers (Class of '85) agreed with Mr. Hawkins that a technology driver has" to be 

included in the program. He said there are opportunities for markets to drive technologies, and 

that superior heat rates and efficiency improvements drive emission reductions. However, he 

noted that there is a fundamental difference in viewpoints between an existing versus a new 

sources, i.e., making changes to a unit to make it more efficient versus building a new source. 

He said that new units and new technology are more efficient and cleaner and drive emission 

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targets lower. But that does not mean that older, e.g., 40-year old, plants should be shut down. 

Instead, their efficiency needs to be improved. 

Mr. Bumpers noted that the off-ramp was proposed at first because of the stalemate in 

NSR reform. He thought the sector-based approach should focus on all units and all pollutants 

except C02 and mercury. He stated that C02 and mercury were not covered under the NSR 

program. He also said that the approach should be unit-specific, i.e., individual units should be 

allowed to opt in as opposed to company-wide, because many facilities operated independently 

and terms like "companies" and "system-wide" were hard to define. 

Greg Signer (Tennessee Valley Authority) asked whether the standards should be based 

on fuel input or power output. With respect to type of fuel, he suggested that the approach 

should be expanded beyond fossil fuels and should include, for example, nuclear and 

hydroelectric power generation. He stated that he agreed with Mr. Hawkins that EPA still 

needed to pursue basic NSR reforms, and is working with Cinergy on the MOU. He also said 

that whether the approach is unit-specific or system-wide will depend on the elements of the 

approach, but the trading should be system-wide. 

For clarification, John Seitz (Director, EPA Office of Air Quality Planning and 

Standards) asked if the recommendation was for opting in to be unit-specific and trading to be 

system-wide. He also said that he wanted everyone to understand that the issues were broader 

than unit-specific. Mr. Bumpers said that each plant has different issues and that he wanted to 

convey that each unit could not be expected to emit at the same target rate. Mr. Perciasepe said 

that trading would work best if more units and facilities participated in the program. 

Christine Shaver (Federal Land Manager) stated that NSR is virtually the only tool that 

Federal Land Managers have to protect Federal lands. She recognizes that existing units are the 

problem, and welcomes a program that would ensure the certainty of emission reductions. She 

also recognizes industry's needs and welcomes ideas. She noted that the visibility rules include a 

top-down best practices approach, and that there is a need to keep technology requirements. 

With respect to the concept of this approach, she indicated that FLM would support this program 

but wanted a technology-based program. Although SOx and NOx were a major concern to the 

FLM, but she would support a multi-pollutant program if that was a more efficient way to do it. 

Mr. Hawkins said that the issue of unit-specific versus company-wide was a subset of a 

larger issue of what the program provides. If the alternate program was a voluntary program and 

it provides more flexibility then it also needs to provide better environmental protection. He also 

stressed that the base NSR program needs to be strong. He was concerned that if the base NSR 

program were not changed, a voluntary program would amount to "pushing on a bag of 

molasses." He suggested that EPA cannot allow a company to obtain a cap at today's levels. 

The NSR reform must change this fundamental aspect of the base program or units will not come 

into a voluntary program. 

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Mr. Bluestein disagreed with Mr. Bumpers that the problem was with existing units. 

New units also had to be considered and could help drive technology improvements. 

Ned Helme (Center for Clean Air Policy) stated that the voluntary off-ramp should 

include a C02 component, and that a C02-target is needed. Business decisions need to consider 

C02 and mercury. Alternative fuels make mercury problem go away. He also said that a 

company should come into the program with all of their plants. 

Mike Bradley (Clean Energy Group) had concerns about shoehorning an integrated 

approach into NSR. He said that a lot of issues have been raised including that of a declining 

cap. He stated that if the off-ramp was not attractive then "you may loose a critical mass." He 

suggested that cost savings from a trading approach depends on lots of participation. He also 

said that limiting it to SOx and NOx would not work, and that the approach needs to capture the 

C02 and mercury piece. The MOU may be an option. He noted that C02 is the big uncertainty 

factor in the future. He needs a crystal ball to see what the future mercury and C02 programs 

will be, but these need to be folded into the off-ramp approach. 

Mr. Harnett pointed that no one had talked about CO and PM, and asked whether the 

assumption was that these pollutants would be automatically covered in the off-ramp program. 

Bill O'Sullivan (State of New Jersey) stated CO and PM must be considered because they 

are criteria pollutants and this program is a criteria pollutant-based program. 

Mark Buzel (AES, New York) said that opting in the program should be unit-specific 

because companies change. Even if we know what the facilities are today, the business model 

may change in the future. 

David Wooley (Clean Air Task Force) supported Mr. Hawkins in stressing the urgency to 

complete NSR reform. While he supported an integrated strategy for the utility industry and the 

grandfathered sources, and recognized that a broad program was needed to ensure that emissions 

will be reduced, he emphasized that the sector-based approach should not be a distraction from 

the main focus, which is reform of the base NSR program. Mr. Wooley then asked Mr. Nickel if 

there was any progress on the UARG proposal for NSR reform. 

Mr. Nickel replied that the UARG proposal had been on the table since April 1999, and 

that UARG was awaiting EPA response. He pointed out that their proposal was backed by a 

large number of sources, which satisfies the broad participation criteria for success. He said that 

their proposal can achieve significant S02 and NOx reductions. He also said that for CO and 

PM the base program has to be good, but questioned how CO and PM will be addressed in the 

sector-based approach. He indicated that CO was only an issue for low level sources such as the 

combustion turbines, but not an issue for large sources. With respect to PM, he said that almost 

all sources have some level of control, and that there is only a need to determine which sources 

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need to do more (than what they are currently doing). He suggested that the program for CO and 

PM be different from S02 and NOx. 

Peter Glaser (representing Western Fuels Association) warned to keep C02 out of the 

discussions. C02 is not a regulated pollutant, and there would be a big fight if C02 was 

considered. 

Mr. Bradley urged EPA to get on with the reform of the core elements of NSR, which 

should be strong, and views the off-ramp as voluntary relief. He also said that there are 

companies that want C02 in the program. 

Mr. Perciasepe attempted to sum up prior to the break for lunch. The concept of a 

comprehensive approach seems agreeable to all, with trading being an important element of the 

approach. There is the issue of the proper vehicle, but NSR has an important role. He sensed 

frustration among the group that there was a need to talk about emission reduction levels or 

targets, i.e., whether the targets should be air quality-based or technology-based. He stated that 

the levels needed to be dynamic and not static because technology improves over time. He 

indicated that there was also a need to talk about that timeframe issue and what sources should be 

doing now versus speculate for the future. He pointed out that this was not a negotiation and that 

we are not going to make up a number. There is a legal framework based on legal principles 

which requires that levels be based on some rationale. He suggested that the afternoon session 

be re-arranged to talk first about timeframe and targets to allow for sufficient discussion, and 

leave further discussion of trading issues to the end of the session. 

Bill Becker (STAPPA/ALAPCO) got in the last word of the morning by stating that the 

discussion on trading and averaging will benefit from a discussion on framework and principles 

of the program - the States want the framework to achieve emission reductions. He expressed his 

opinion that the discussion on framework should precede the discussion on timeframe and 

targets. 

BREAK FOR LUNCH (approximately ll:50am-12:30pm) 

DISCUSSION ON STATE AND FEDERAL ROLES 

Mr. Seitz opened the afternoon session by pointing out that Mr. Perciasepe had to go for a 

meeting with the Administrator, and that he will be back later in the afternoon. 

Mr. Harnett identified a change in the schedule for the afternoon session, to begin with 

the topic of the State/Federal roles for a voluntary off-ramp program, followed by the 

timeframes/targets issue, and ending with further discussion of trading versus averaging. He 

initiated the State/Federal roles discussion by asking what would happen if a State chose not to 

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participate in the voluntary program. He asked that if the program was left for States to adopt via 

SIPs, similar to the NSR program, then should EPA reject those SIPs that do not adopt this 

approach, i.e., should it be voluntary or mandatory for States to adopt it? He also asked that if it 

were voluntary for States to adopt it, then what would happen in the case of a company that has 

plants in several States but only some of those States adopt this program. 

John Paul (Dayton RAPCA) thought that if the prgram is voluntary for the sources then it 

must be voluntary for the States, and the regional groups such as NESCAUM or MARAMA 

could facilitate trading. States could opt-in through the regional organizations. He further stated 

that if the program were designed such that they were easy to implement then the States were 

likely to adopt it. 

Mr. Harnett noted that some States were opposed to opting into the trading program 

under the NOx SIP call, and requested input from the States as to whether some of those issues 

might be a problem here. Mr. Paul indicated that localized impacts were always a concern of 

States when talking about a regional trading program, and that protections against localized 

impacts would be needed. Also, with trading, timeframes and targets were a concern. Longer 

timeframes make trading harder. Technology-based targets and short timeframes are preferable 

to get reductions. He acknowledged that the details need to be worked out. 

Mr. Bradley indicated that in some States there may only be a few sources and those 

States may be reluctant to join the program. He noted that these sources may be addressed 

through limits made enforceable through the Title V program. He also indicated that States are 

supportive of their proposal. 

Mr. Amar stated that if large reductions occur in general, then local impacts would likely 

not be a problem because* of the tall stacks associated with most coal-fired units, and could be 

handled via local implementation of air quality standards. He stressed the importance of having 

baseline determinations and emissions banking, and agreed that it would not be hard to do once 

rules were set up-front. 

Mr. James identified the Ozone Transport Commission Memorandum of Understanding 

was an example of how State/Federal roles could work. He also agreed with Mr. Bradley's 

suggestion that if there were only a few sources then a Title V revision will also work. 

John Bunyak (Federal Land Manager) noted that local impacts are very important to 

managers protecting Federal lands, and that any cap-and-trade program must protect the issue of 

impacts, including AQRV in Class I areas. He indicated support for declining emission caps of 

large geographic regions, and said that status quo, e.g., at current emission levels, was not 

acceptable. 

Becky Stanfield (U.S. PIRG) strongly agreed that local impacts were not a trivial issue, 

especially with respect to mercury, where hot spots would require attention. Similarly, NOx and 

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S02 hot spots were not acceptable. She also expressed her opinion that brad-based trading 

would depend on timeframe and targets. 

Bill Grant (Izaak Walton League) was also concerned about mercury. He suggested that 

if trading occurred over too large of a region, then local mercury impacts may still persist. He 

preferred a small geographic area. 

Mr. O'Sullivan did not expect that any emission increases would be allowed at individual 

sites. He thought the program would allow individual sites to forego decreases, but that actual 

emission increases would not be allowed. However, if there were emission increases then local 

impacts would have to be addressed. 

Mr. Nickel argued that although a trading program would not encourage emission 

increases, the program would have to allow emissions to increase at individual plants. He 

indicated that safeguards against emission increases and local impacts may already exist under 

other programs. 

Mr. Amar pointed out that if emission reductions were not substantial then trading could 

cause problems. Trading across State boundaries must work under the umbrella that overall 

reductions will occur. Similar to ozone and NOx, this was a regional issue. 

Mr. Seitz suggested that within other trading programs, such as the NOx MOU or the 

Title IV program, NOx reductions were being realized, but that a trading program should not 

trump the issue of local impacts. 

Mr. Becker said that trading would not allow increases in emissions. He asked 

Mr. Nickel if UARG would allow increases at individual facilities. 

Mr. Nickel replied yes. He said that some facilities may increase utilization and offset it 

with reductions elsewhere. 

Bruce Buckheit (EPA/OECA) noted that an air quality control mechanism under the SIP 

program could be used if a localized problem existed, but that such a facility could still 

participate in the trading program as a seller instead of a buyer. 

Mr. Harnett asked whether an individual facility could increase emissions as long as the 

NAAQS were protected. Mr. Nickel said that a trading program should preserve that flexibility. 

He also pointed out that he was talking about annual, and not short-term, emissions. 

Mr. O'Sullivan noted that modifications other than emission increases, such as reduced 

stack heights, would also have to be considered in the air quality analysis. In such a case, 

modeling would be necessary. 

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In response to Mr. Nickel's comment, Mr. Grant stated that most mercury deposition 

occurs within 25-50 miles of a plant, and that significant increases in utilization that result in 

emission increases could exacerbate such local problems. 

Mr. Hawkins stated that local environmental groups would keep pressure on to make 

certain that plants in their constituency would be cleaned up. However, he noted that the 

integrity of the program depends upon regional trading. 

Mr. Bunyak noted that Class I areas do not have SIP safeguards or other programs to fall 

back on. 

Mr. Bumpers said that industry wants trading and supports integrity in the trading 

program. Industry can live with State/local concerns about environmental safeguards. He also 

said that industry has gone through a number of programs and can do this, but only without 

bureaucratic problems. 

For clarification, Mr. Seitz asked if STAPPA/ALAPCO's comment was that in a 

voluntary program the States should be allowed to enter the program if there were a number of 

sources in the State, and if the State only had 1 or 2 sources, then a Title V revision would be 

preferred. 

Mr. Brownstein commented that if this approach is a mandatory program that replaces 

NSR, then there would be a problem. However, if it is an off-ramp and a voluntary program, 

then it can work. Most companies are multi-State companies, and so coordination among States 

is needed. States have done this before. 

Mr. James suggested that for States that do not opt in, FIP could be used instead of a SIP 

to implement this program. Mr. Harnett replied that one of the problems with that was that EPA 

resources were limited. 

Mr. Harnett pointed out that during the NOx SIP discussion many States were not 

interested in trading. If that is the case then only those sources that are in States that opt in could 

participate in the trading program. He said he is trying to understand where the differences are 

among the States. 

Mr. Becker said that one of the concerns was that if a utility is allowed to increase 

emissions, the beneficiary would be an upwind facility that was trading with it. He asked why 

would a downwind State want to participate under such circumstances. 

Mr. Nickel thought that mechanisms currently exist to take care of increasers and to 

address upwind-downwind issues. His view of the program was that emissions from some plants 

go up, others go down, and there is a net decrease in emissions over time. However, industry 

cannot do anything it wants under the trading program - there are protections such as the ambient 

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standards and visibility. Trading has to be flexible, but that does not mean that it would hinder 

air quality maintenance plans. 

Mr. Hawkins was concerned that industry has made efforts to prevent the existing system 

from working, and mentioned several cases currently in the DC Circuit. He then said that 

downwind problems do exist and that the current state of affairs has not delivered cleaner air. 

Mr. Becker echoed Mr. Hawkins' comment. While the ambient air quality impact 

analysis is protection on paper, once emissions occur the burden falls on States to protect the 

NAAQS. States have had tough battle trying to do this and should opt in only if they were 

comfortable with this issue. 

Mr. Bumpers argued that there will always be problems and that even under NSR there 

could be significant increases in utilization. He asked, "How do you design a perfect trading 

program? Can we do it under NSR?" 

Mr. Buckheit said that according to some people a broad-based program will make it 

easier. (???) In a cap-and-trade program, there will always be a question of who, what, when etc. 

Mr. O'Sullivan suggested that it would be left up to the sources to propose how they do 

retrofits and get early reductions. The order of things was not that important. He also noted that 

lots of old sources have never been rigorously modeled. He felt a rigorous modeling effort for 

older sources was needed in this program to ensure protection of ambient standards. He was less 

concerned about the impacts of annual emission increases than he was about increases in hourly 

emissions. He suggested that lb/hr emission limits may be necessary. 

Mr. Paul said that the bottomline is dollars. In the end, all industry and States think about 

is how much it will cost them. "We are just dancing around" what the program should look like, 

but not talking about details. He said that cost issue will be a problem when talking about 

details. 

DISCUSSION ON TIMEFRAMES AND TARGET LEVELS 

Mr. Harnett then moved the discussion to the timeframes and targets issue. He asked for 

ideas on the rationale that EPA should use in selecting emission reduction targets/levels and the 

time frame for implementation. He indicated that a number of proposals have come in with 

recommendations for levels and timeframe. The group should consider questions like - Should 

all sources be subject to BACT/LAER? When should the program begin? When should targets 

be met? But mainly, EPA was interested in the rationale for deciding targets and timeframes. 

Mr. Seitz explained that Mr. Perciasepe wants a timeframe if this program is going to be 

offered as an off-ramp to regular NSR. He emphasized that EPA was most interested in the 

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rationale to be used in setting targets and timeframes, and less so in the exact numbers/schedules 

that people were advocating. 

Mr. Sussman's view was that the program could contain three categories. One, the 

primary driver should be ambient air quality, noting that the primary purpose of control programs 

was to meet attainment responsibilities and that this cold be achieved via national/regional 

programs such as the NOx SIP call. Two, State/local controls within SIP - the focus of these 

program would be on sources within the non-attainment areas. Three, NSR controls - he viewed 

NSR as a backstop program, and not the center piece of the air quality program. NSR is 

source-specific and is there to prevent leakage. He also stated that the technology-based driver 

of the NSR program should not be the driver of the national program. As to levels, he suggested 

that it should not rely on NSR levels. There is a point where the technology path and ambient air 

quality path diverge. National/regional models could be used to determine levels. He suggested 

to put NSR "to one side" and design a national program. He agreed that State/local agencies will 

play a significant role in whatever is done on national level. There were two ways to determine 

levels; one, technology-based (NSR), and two, air quality-based. When asked by Mr. Harnett 

whether he was talking about PM-2.5 and ozone 1-hr standards, and if this was the rational he 

would use, Mr. Sussman replied that a comprehensive air quality regime is needed and that we 

need to talk about specific issues. When asked by Mr. Buckheit how health-based levels would 

be set without going through five years of analysis, e.g., how to set levels for a future year, say 

2012, Mr. Sussman replied that technology-based levels cannot supersede health-based levels. 

Mr. Buckheit noted the time-consuming nature of modeling and the inability to reach consensus 

on setting health-based levels. He felt that a program based only on ambient air quality would 

take a long time to reach consensus on levels. 

Mr. Seitz acknowledged that NSR was technology-based program that has created a level 

of anxiety. He agreed that certainty was desired. The question is what type of rationale could be 

used to set timeframes and levels. UARG had suggested to use life expectancy for timeframe, 

although EPA did not agree with it. Are there any other suggestions for rationale? 

Mr. Signer suggested not to de-link off-ramp from main NSR. NOx and S02 are 

different from TVA's perspective. They (TVA) were putting SCR on some of their large sources 

right now, and also trying to get 80% reductions on S02. 

Mr. Wooley urged EPA to assure that the voluntary program would achieve the same 

emission reductions as those he anticipates would occur from proper implementation of the base 

program. He indicated that 15 or 20 years was too long for a timeframe, and that current 

litigation would likely result in requiring certain reductions in the 3-5 year time frame. He 

suggested that the voluntary off-ramp program must be at least as stringent as the levels he 

expects that will result from the litigation. 

Charles McPhedran (Penn Futures) agreed with Mr. Hawkins that the current NSR/PSD 

has failed to get the emission reductions it was supposed to. Enforcement can help NSR work as 

Page 13 
P.15 

can improvements in the base program. Any alternative program should be based upon what can 

be achieved in practice. He asked that EPA look at what industry has done and is capable of 

doing, e.g., controls that achieve 0.1 lb/MMBtu for NOx are in place in Pennsylvania. He 

advocated that EPA adopt short-term goals of 0.15 lb/MMBtu for NOx and 0.3 lb/MMBtu for 

S02. When asked by Mr. Seitz for clarification whether levels should be based on those that can 

be achieved in practice, Mr. McPhedran replied yes only in terms of enforcement. When asked 

by Mr. Seitz whether he had a long-term goal aside from enforcement, Mr. McPhedran replied 

that he could not say yet. 

Mr. Bradley said that his proposal is a hybrid between technology and ambient air quality 

considerations. There should be a declining cap over time, with an intermediate goal to obtain 

reductions by 2008. He thought a national program with a 0.15 lb/MMBtu for NOx was needed, 

and a 50% reduction in S02 above the current Acid Rain program. He proposed a mercury goal 

of a 50% reduction by 2008, with a possible second phase after that. For C02, he thought 

stabilization to 1990 levels were possible. For PM-10, he suggested to use an NSPS-type 

approach, and for CO, an engineering and practice-type approach. He was not sure what to 

recommend after the 2008 targets were met. He selected 2008 as the time frame because it was 

consistent with EPA's time frame associated with the 8-hour ozone and PM-2.5 attainment 

timeframes. 

Mr. Hawkins said that any alternatives to NSR/PSD must include technology-based 

standards. He felt there was some hope on getting stakeholders to agree on technology-based 

targets, but that agreement on health-based targets would be many years away. 

Mr. Bumpers said that the Class of 85's original proposal was not a trading program, but 

with the apparent general acceptance of trading voiced in the morning sessions, he wanted to 

withdraw their non-trading proposal. He urged EPA to not ignore the base program, and that the 

alternative program should ask "can we get lower, sooner?" However, he cautioned that every 

plant cannot be expected to meet a certain level. He also cautioned that the time frame not be too 

short, since plants are constrained by thin margins and cannot afford to take lots of units off-line 

in a short period. 

Mr. Paul said the States, based on a conference call last week, are looking at a technology 

solution with current BACT as the starting point. He advocated a provision for early sign-up, 

with controls in place by 2007-2010. Early sign-up source would get current BACT. However, 

EPA would reassess BACT in 2005, and that level would apply to sources that sign up for 

installing controls after 2007. He advocated a requirement for mandatory upgrades, i.e., controls 

in place, when a plant reaches 30 years of age. He assumes that all units are eventually 

controlled or shut down. When asked by Mr. Harnett about sources that are already 30 years old, 

Mr. Paul said that the idea was that when the unit reaches age 30, the unit will have 24 months to 

meet the target. Also, the longer the unit holds off controlling, the tighter the standard. 

Page 14 
P.16 

Mr. Nickel joked that the NSR off-ramp was being turned into a "Thelma and Louise" 

off-ramp. He summarized the rationale for the UARG proposal. There would continue to be a 

basic program for everybody. S02 reductions could be piggy-backed on the Title IV program, 

NOx reductions on the regional trading programs. He supported an aggregate BACT concept, 

with the timing depending on the levels. He asserted that there should be a start date and an end 

date. The start date should depend on what you do in the first decade of this century, i.e., NOx 

SIP call, acid rain for S02 control, etc. Although the mechanism for the alternate program can 

be established now, it cannot begin immediately. The sources should be given time to achieve 

reductions under other programs first. For end date they had suggested 5 5-year life, noting that 

in some of the acid rain analyses a 55-65 year life was used. He also said that controls on 

existing sources had not been achieved because NSR is technology-based and the existing 

sources have limitations. He suggested levels of 0.15 for NOx and 0.25 for S02 (based on 

subpart Da of NSPS). When asked by Mr. Seitz what their suggested start date was, Mr. Nickel 

replied 2010, but with lots of work, the industry could live with a 2005 start date. When asked 

by Mr. Harnett whether he would change levels if the timeframe was 10-15 years, Mr. Nickel 

replied it would be very aggressive to achieve in 10-15 years. 

Ms. Shaver pointed out that the visibility program (regional haze rule) had a 13-15 year 

outlook, and that any timeframe here must be less than that. She recommended current BACT 

levels for the next 3-5 years, with a revisit in 5 years. Therefore, there would be an incentive to 

sign up early on. The targets must not allow less than what is in on-going activities. She also 

stated that coal-fired sources in the West can meet much lower targets than the East. When 

asked by Mr. Harnett if she was suggesting a regional level, Ms. Shaver replied that a percent 

reduction target be considered instead of a lbs/MMBtu target. 

Quinlan Shea (Edison Electric Institute) said his group endorses NSR reform. He 

cautioned against including mercury or C02 since there was no legal or political basis. He urged 

EPA not to link enforcement with NSR reform, criticizing what he called EPA's "revisionist 

history." He thought NSR as always being a backstop program, and disagreed with EPA's 

enforcement policy of the last two years. 

Mr. Seitz urged all not to fold the enforcement issue into today's discussion. 

Rae Cromiller (NRECA) indicated that it was difficult to comment in detail, since he did 

not know what the new, reformed NSR program would look like, and it was hard for a utility to 

decide whether to participate in an off-ramp. In general, he thought there must be an off-ramp, 

which must be linked to NSR criteria. He thought it was a mistake to throw mercury and C02 

into the debate. He views NSR as a backstop program, and adding mercury and C02 would 

create controversy. He thought EPA needed to concentrate on fixing the existing program before 

beginning down the mercury/C02 path. 

Mr. Bluestein said the sector-based approach needed a technology forcing function in the 

form of a declining cap. He urged that the program not be prescriptive in terms of control 

Page 15 
P.17 

technology on a unit-by-unit basis, but emission targets should be based in terms of output -

lbs/unit electricity generated and not lbs/MMBtu. 

David Israel (Clean Energy Group) advocated a comprehensive program. He stated that 

business decisions are made on a number of parameters, and business needs to consider C02 and 

mercury in business decisions. 

Ms. Stanfield said that the off-ramp must achieve the same reductions as NSR. She noted 

that emission reductions called for under the existing NSR program have already been 

substantially delayed, and need to catch up. She thought that a 2005 time frame is not only 

achievable, it meets the objective. She felt that mercury and C02 must be included to achieve 

certainty. 

Mr. McPhedran clarified his position by urging EPA to periodically revise BACT as also 

suggested by Mr. Paul. He mentioned 0.15 lbs/MMBtu of NOx as a short-term goal, not a long 

term target. 

Mr. Brownstein provided a history as to why C02 is on the table. He said that many 

utility industry CEOs met with Vice-President Gore, where the issue of coupling C02 reductions 

with S02 and NOx reductions was raised. If industry needs certainty for capital budgeting, then 

C02 must be included in an integrated strategy. He also said that an age-based program leaves 

reductions on the table whether it is 55- or 30- or 10-15 year program. An age-based program 

will not get the same reductions as a cap by 2008. 

Mr. Becker indicated that most States agreed that mercury should be controlled, and that 

C02 has nothing to do with Kyoto (???). There are over 100 technical and policy initiatives 

that sources can follow to reduce C02 at the same time as NOx and S02 reductions. He noted 

that utilities should assume that the agencies will eventually regulate mercury and C02, and 

should include this certainty in their planning. The program needs to be good at onset. 

Mr. James agreed with the need for certainty, but thought that EPA was asking States to 

be at a disadvantage by not talking about all issues at the same time. Incremental discussions 

cost more. He thought that all issues must be on the table. He mentioned that the northeast 

States and eastern Canadian provinces are moving ahead on a 50% mercury reduction strategy. 

He was hopeful for an integrated strategy. C02 reductions could be included by referring to 

them as efficiency improvements. 

Larry Shapiro (NY Public Interest Research Group) noted that if industry takes the 

off-ramp, the cloud of possible future enforcement disappears, which is a huge benefit. Industry 

should be willing to give something in return, such as commitments on mercury and C02. He 

also mentioned that New York Governor Pataki has already proposed NOx and S02 reductions 

in the same timeframe as being discussed in today's meeting. 

Page 16 
P.18 

Mr. Cromiller responded to Mr. Becker's comment by noting that industry is already 

participating in voluntary S02 and C02 reduction programs right now. Any C02 provision in 

this off-ramp will not provide a safeguard. 

Jene Robinson (Illinois Power) addressed Mr. Brownstein's comment on the White 

House meeting. His impression was that C02 could be reduced faster if the NSR off-ramp 

program went forward and is properly administered. 

Mr. Buckheit wondered why industry objects to mercury reductions as a practical matter. 

He understood the legal basis, but thought that S02 scrubber technology would also remove 

mercury. Mr. Bumpers stated it was not at all clear that scrubbing would get a 50% reduction in 

mercury. Furthermore, scrubbing may not be the way emissions are controlled. Mr. Amar said 

that scrubber does not always work for mercury control. 

Mr. Shea said that the issue of how much we can do in how much time is different from 

target levels. Mr. Harnett explained that there were also other issues to be considered such as 

monthly/quarterly/annual (???), banking and shutdowns. 

Michael Florentino (Clean Air Council) summed up'his group's position by stating that 

the off-ramp must be technology-based because health-based standards were not feasible to 

implement. They were not opposed to trading, but needed safeguards for banking issues and 

environmental justice concerns. He was concerned that some plant choose to trade rather than 

control, and would like like to see some type of cap, maybe seasonal emissions cap, on how 

much a source can trade. 

Mr. Seitz brought the meeting to a close by indicating that the summary of today's 

meeting will be docketed. He also said that additional comments should be sent to the docket 

within about a week. He reiterated Mr. Perciasepe's comments at the beginning of the meeting 

that EPA was still in the early planning stages with respect to the sector-based approach. There 

were still a lot of questions and EPA may contact the stakeholders to talk further. Upon request 

from an industry representative, Mr. Seitz indicated that the questions raised by Ms. Kaufman in 

her presentation will be made available to everyone. With respect to NSR reform, he indicated 

that EPA is continuing dialogue with the stakeholders and hopes to move forward during spring. 

The meeting was then adjourned. 

Page 17 
P.19 

ATTENDEES 

STAKEHOLDER MEETING 

SECTOR-BASED APPROACH 

January 13, 2000 

No. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

Name 

Jesse Adkins 

Praveen Amar 

Janet Anderson 

Nneka Assing 

Bill Banig 

Barbara Bankoff 

Lisa Beal 

Mark Benjamin 

Bob Bessette 

Earl Billingsley 

Karen Blanchard 

Joel Bluestein 

Michael Bradley 

Linda Breggin 

Karen Britto 

Larry Brown 

Mark Brownstein 

Rob Brubaker 

Jack Brunton 

Bruce Buckheit 

Bill Bumpers 

Affiliation 

WVDEP 

NESCAUM 

WHCCTF 

AGA 

UMW 

Siemens 

INGAA 

Inside EPA 

CIBO 

WV-DEP-OAQ 

US. EPA/OAQPS 

EEA/Trigen 

CEG 

Environmental Law Institute 

DTE 

ALDEM 

PSEG 

Porter, Wright, Morris & Arthur 

Sempra Energy 

US EPA/OECA 

Baker Botts 

Phone 

304-558-2479 

617-367-8540 

202-395-2334 

202-824-7332 

202-842-7260 

202-434-3810 

202-216-5935 

703-716-8536 

703-250-9042 

304-558-2275 

919-541-5503 

703-528-1900 

978-369-5533 

202-939-3828 

202-347-8420 

334-271-7886 

973-430-7196 

614-227-2033 

619-696-2509 

202-564-2260 

202-639-7718 

Fax 

304-558-3287 

617-742-9162 

202-395-2311 

202-824-9182 

202-842-7264 

202-347-4015 

202-216-0876 

703-716-8543 

703-239-9042 

304-558-3287 

919-541-5505 

703-528-5106 

978-369-7712 

202-939-3868 

202-347-8423 

334-279-3044 

973-565-0525 

614-227-2100 

619-696-4248 

202-639-7890 

Page 18 
P.20 

No. 

22 

23 

24 

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26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

Name 

John Bunyak 

Mark Burtschi 

Mark Buzel 

James Capp 

Chuck Carlin 

Mark Carney 

Chris Carr 

Tom Carter 

David Cesareo 

Richard Chastain 

Reid Clemmer 

John Cline 

Allan Coeb 

Stan Coerr 

Patrick Connile 

Betty Cox 

David Crabtree 

Caroline Choi 

Rae Cromiller 

Dan Cunningham 

Dave Darner 

Brad Daves 

Jocelyn de Grandpre 

Norbert Dee 

Darnell DeMasters 

Affiliation 

National Park Service 

The NAM 

AESNY 

GAEPD 

Northeast Utilities 

PG&E Generating 

Vincent & Elkins 

APCA 

PECO Energy 

Southern Companies 

PP&L 

Mays and Valentine 

Consulting 

Coerr Environmental Corporation 

Reuters 

API 

DGT 

CP&L 

NRECA 

Con Edison 

Wisvest-Connecticut, LLC 

McGuire Woods 

USEPA 

NPRA 

Wisconsin Electric 

Phone 

303-969-2818 

202-637-3176 

607-729-6950 

x4694 

404-363-7143 

860-665-5344 

301-280-6899 

202-639-6654 

202-408-9494 

215-841-5030 

205-257-6664 

610-774-5475 

804-697-1265 

202-544-7920 

919-932-1770 

202-898-8316 

202-682-8250 

801-619-6500 

919-546-3775 

703-907-5791 

212-460-2066 

203-447-4035 

202-857-1721 

202-564-5574 

202-457-0480 

202-662-4340 

Fax 

303-969-2822 

202-637-3182 

607-729-0540 

404-363-7100 

860-665-3777 

301-913-5850 

202-408-0877 

215-841-4062 

205-257-7294 

610-774-5930 

804-697-1339 

919-932-3340 

202-898-8490 

202-682-8033 

801-619-6599 

919-546-7536 

703-907-5517 

212-387-2142 

203-447-4033 

202-857-1737 

202-564-5603 

202-457-0486 

202-662-4359 

Page 19 
P.21 

No. 

47 

48 

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50 

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52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

Name 

Kimberly Denbow 

Jon Devine 

Ruben Deza 

Larisa Dobriansky 

Tom Driscoll 

Henry Eby 

Alan Eckert 

Tiffany Elliott 

Don Elliott 

William Ellison 

Ray Evans 

Jerry Eyster 

Pam Faggert 

Rich Fisher 

Michael Florentino 

John Flulky 

Joe Fontaine 

Greg Foote 

Katharine Fredriksen 

Andy Gates 

Kris Gaus 

Chris Giblin 

David Gilbert 

Peter Glaser 

Jeff Gleason 

Affiliation 

American Gas Association 

US EPA/OGC 

MDE-ARMA 

Akin, Gump, Strauss, Hauer, Feld 

US EPA/OAQPS 

LCRA 

US EPA/OPAR 

EPSA 

PHJW 

Ellison Consultants 

FirstEnergy 

PHBHaglerBailly 

Virginia Power 

US Forest Service 

Clean Air Council 

Wall Street Journal 

NHDES 

US EPA/OGC 

Koch Industries 

Reynolds Metals Company 

CSW 

Reliant Energy 

Constellation Energy 

Shook, Hardy & Bacon 

Southern Environmental Law Center 

Phone 

202-824-7334 

202-546-1971 

410-631-3240 

202-887-4363 

919-541-5135 

512-473-3200 

202-564-5557 

202-789-7200 

202-508-9558 

301-865-5302 

440-761-4482 

202-828-3971 

804-273-3467 

970-295-5981 

717-230-8806 

202-862-4264 

603-271-6794 

202-260-7620 

202-737-1977 

804-281-3482 

214-777-2896 

202-783-7220 

202-942-9840 

202-783-8400 

804-977-4090 

Fax 

202-824-7082 

202-546-5603 

410-631-3202 

202-887-4288 

919-541-5509 

512-473-3357 

202-789-7201 

202-508-9700 

301-865-5591 

440-384-5433 

202-296-3858 

804-273-3410 

920-295-5959 

717-230-8808 

202-862-9266 

603-271-1381 

202-737-8111 

804-662-4567 

214-777-1380 

202-783-8127 

202-942-9847 

202-783-3131 

804-977-1483 

Page 20 
P.22 

No. 

72 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

.87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

Name 

Joe Goffman 

Prudence Goforth 

Bill Grant 

John Grieve 

Tom Guay 

Steve Guyer 

Mark Hall 

Bill Harnett 

Ray Harry 

David Hawkins 

Simon Healey 

Susan Hedman 

Ned Helme 

Ben Henneke 

Janet Henry 

Ann Heighway 

James Hettinger 

Gene Higa 

J. E. Hofman 

Chris Holly 

John Holt 

Jaqueline Howells 

R. Todd Hyde 

Lee Hughes 

Karen Irons 

Affiliation 

Environmental Defense Fund 

USEPA 

Izaak Walton League of America 

Ontario Power Generation, Inc. 

Clean Air News 

MidAmerican Energy 

Trigen 

US EPA/OAQPS 

Southern Company 

NRDC 

Troutman Sanders 

Environmental Law and Policy Center 

Center for Clean Air Policy 

CAAC 

AEP 

IPL 

Air Daily 

MDE-ARMA 

Trinity Consultants, Inc. 

The Energy Daily 

NRECA 

PNM.SPPC 

Merck & Co., Inc. 

Bayer Corp. 

MD Department of Environment 

Phone 

202-387-3500 

202-564-7433 

651-649-1446 

416-592-6809 

410-975-9911 

515-727-2191 

515-281-2692 

914-286-6621 

919-541-4979 

202-261-5000 

202-289-6868 

202-274-2913 

312-795-3700 

202-408-9260 

410-286-2995 

614-223-1614 

317-261-5073 

202-775-0240 

410-631-3353 

972-661-8100 

202-662-9720 

703-907-5805 

202-547-5400 

908-423-3994 

412-777-2221 

410-631-3256 

Fax 

202-234-6649 

651-649-1494 

416-592-7844 

410-975-9904 

515-281-2970 

914-948-9157 

202-296-7937 

202-289-1060 

202-274-2994 

202-332-1580 

202-408-8896 

410-286-3463 

614-223-1687 

317-630-5796 

410-631-3202 

972-385-9203 

202-662-9740 

703-907-5517 

202-543-5740 

908-423-1322 

412-777-3063 

410-631-3203 

Page 21 
P.23 

No. 

97 

98 

99 

100 

101 

102 

103 

104 

105 

106 

107 

108 

109 

110 

111 

112 

113 

114 

115 

116 

117 

118 

119 

120 

121 

Name 

Craig Jakubowics 

Christopher James 

Debra Jezouit 

Malay Jindal 

David Kathan 

Kathy Kaufinan 

Jeff Keeler 

Mike Kennedy 

Larry Kertcher 

Heidi King 

Bob Kozopas 

Bob Kuchner 

Barnett Lawrence 

Bryan Lee 

Jeffrey Levine 

Mario Lewis 

Dennis Limbach 

Michael Ling 

Robert Long 

Joe Mackeil 

Gene Marshall 

Dawn Martin 

Sharon Masserant 

CV. Mathai 

Christopher McAuliffe 

Affiliation 

Edison Electric Institute 

Connecticut DEP 

Baker Botts 

PES 

NERA 

US EPA/OAQPS 

Enron Corporation 

Florida Power Corporation 

USEPA 

OMB/OIRA 

Ontario Power Generation 

Babcock & Wilcox 

Arnold & Porter 

Dow Jones 

Cauthen and Associates 

GRC/NEG 

Allegheny Energy 

US EPA/OAQPS 

National Mining Association 

MOC 

Pacificorp 

US EPA 

Chemical Manufacturers Assoc. 

Pinacle West (AZ Public Service) 

PSEG Services Company 

Phone 

202-508-5620 

860-424-3027 

202-639-7728 

919-941-0333 

202-466-9239 

919-541-0102 

202-466-9157 

727-826-4334 

202-564-9121 

202-395-3084 

416-592-6438 

330-860-2063 

202-942-5965 

202-862-6647 

202-638-0125 

202-225-1962 

202-824-0404 

919-541-4729 

202-463-2663 

419-421-3442 

801-220-2235 

202-564-7400 

703-741-5240 

602-250-3569 

973-430-6298 

Fax 

202-508-5673 

860-424-4063 

202-639-7890 

919-941-0234 

202-466-3605 

919-541-5509 

202-828-3372 

727-826-4216 

202-395-7285 

416-592-4841 

330-860-1407 

202-942-5999 

202-659-0130 

202-638-0115 

202-225-2441 

202-347-0132 

919-541-5509 

202-833-1965 

419-421-4515 

801-220-4307 

703-741-6240 

602-250-3813 

Page 22 
P.24 

No. 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

134 

135 

136 

137 

138 

139 

140 

141 

142 

143 

144 

145 

146 

Name 

DJ McCarthy 

Yvonne Mclntyre 

John McManus 

Charles McPhedran 

Ken Meade 

Robert Meyers 

Joe Miakisz 

Chris Miller 

Pam Mills 

Dave Mitchell 

Robert Morris 

Catherine Morris 

Norm Morrow 

Ed Much 

Jim Murphy 

Pamela Najor 

Joe Nelson 

Greg Nelson 

Henry Nickel 

Jenny Noonann 

Doug Obey 

Cal Ogburn 

Frank O'Donnell 

Bill O'Sullivan 

Jeff Pardue 

Affiliation 

IPL 

Kansas City P&L 

AEP 

PennFuture 

Hale and Dorr, LLP 

House Commerce Committee 

MJ Bradley & Associates 

Senate EPW 

Allegheny Energy 

Duke Energy 

Coastal 

Center for Clean Air Policy 

Exxon Mobile 

Baltimore Gas & Electric 

Allegheny Energy 

BNA 

Van Ness Feldman 

TEC 

Hunton and Williams 

USEPA 

Clean Air Report 

CP&L 

Clean Air Trust 

NJDEP 

Florida Power Corporation 

Page 23 

Phone 

202-639-8815 

202-508-5275 

614-223-1268 

215-569-9693 

202-942-8431 

202-225-8049 

978-369-5533 

202-224-2969 

202-824-0408 

202-331-8090 

713-877-6194 

202-408-9260 

281-870-6112 

410-787-6558 

724-830-5925 

202-452-6364 

202-298-1894 

813-641-5016 

202-955-1561 

919-541-0193 

703-416-8516 

919-362-3585 

202-785-9625 

609-984-6721 

727-826-4301 

Fax 

202-639-8816 

202-508-5277 

614-223-1268 

215-569-9637 

202-942-8484 

202-225-2899 

202-224-1273 

202-347-0132 

202-331-1181 

713-297-1045 

202-408-8896 

281-588-2522 

410-787-5199 

724-838-6888 

202-452-7891 

202-338-2416 

813-641-5081 

202-778-2201 

919-541-5509 

703-416-8543 

919-362-3266 

202-293-7808 

727-826-4216 
P.25 

No. 

147 

148 

149 

150 

151 

152 

153 

154 

155 

156 

157 

158 

159 

160 

161 

162 

163 

164 

165 

166 

167 

168 

169 

170 

171 

Name 

Gordon Park 

David Parks 

John Paul 

Wayne Penrod 

Bob Perciasepe 

Tracy Peth 

Clara Pofenberger 

Mike Poling 

Frank Prager 

Jack Preston 

Pat Raher 

Todd Rallison 

Rhone Resch 

Tina Richards 

Leslie Ritts 

Barbara Roberts 

Jene Robinson 

Edward Sabo 

Conrad Schneider 

Ted Sears 

John Seitz 

Yvonne Selbig 

Howard E. Shapiro 

Larry Shapiro 

Christine Shaver 

Affiliation 

Tennessee Valley Authority 

BGE 

RAPCA 

Sun Howell Electric 

US EPA/OAR 

Edelman P.R. 

Baker Botts 

Kansas City Power & Light 

NCE 

SCE&G 

Hogan & Hartson 

Pinnacle West 

NGSA 

IPL 

Hogan and Hartson 

US EPA 

Illinois Power 

PES 

CATF 

The Technical Group 

US EPA/OAQPS 

Rochester Gas and Electric 

Van Ness Feldman 

Environmental Enforcement Project 

National Park Service 

Phone 

423-751-2806 

410-787-5234 

937-225-4435 

316-272-5418 

202-564-7400 

202-326-1703 

202-639-7782 

202-508-5276 

303-294-8108 

803-217-9849 

202-637-5682 

602-250-3722 

202-326-9300 

202-639-8815 

202-637-6573 

202-564-7400 

217-423-0119 

703-471-8383 

202-962-8562 

919-541-5618 

716-771-2145 

202-298-1884 

212-812-4256 

303-969-2074 

Fax 

423-751-7011 

410-787-5065 

316-272-5413 

202-371-2858 

202-639-7890 

202-508-5278 

303-294-8255 

803-217-7349 

202-637-5910 

602-250-3393 

202-326-9329 

202-639-8816 

202-637-5910 

240-255-5814 

703-481-8296 

202-962-8542 

202-338-2461 

303-969-2822 

Page 24 
No. 

172 

173 

174 

175 

176 

177 

178 

179 

180 

181 

182 

183 

184 

185 

186 

187 

188 

189 

190 

191 

192 

193 

194 

195 

196 

Name 

Quinlan Shea 

Greg Signer 

Bob Silva 

Patricio Silva 

David Slaughter 

Anne Smith 

David Solomon 

Becky Stanfield 

Robert Stanier 

Joe Stanko 

John Stanton 

Bob Sussman 

Byron Swift 

Jeremy Taylor 

Bob Teetz 

Laura Tranter 

Gene Trisko 

Jean Vernet 

John Walke 

Paul Wallach 

Suzanne Watson 

Flint Webb 

Dick Wilson 

David Wojick 

Anna Wood 

Affiliation 

Edison Electric Institute 

TVA 

DOE (NETL) 

NRDC 

Thompson Publishing Group 

Chas River Association 

US EPA/OAQPS 

US PIRG 

Winston & Strawn 

House Commerce Committee 

National Environmental Trust 

Cinergy/WEPCO 

ELI 

Koch Industries 

Key Span Energy 

Cinergy 

UMWA 

US DOE/Policy 

US EPA 

Hale 8c DonNortheast Midwest Institute 

SAIC 

NES 

Electricity Daily 

US EPA/OPAR 

Phone 

202-508-5027 

423-632-7843 

202-260-2014 

202-289-2398 

202-739-9551 

202-662-3872 

919-541-5375 

202-546-9707 

202-371-5929 

202-887-8821 

202-637-2138 

202-939-3808 

713-544-5572 

631-391-6133 

513-287-4459 

304-258-1977 

202-586-4755 

202-564-5699 

202-942-8429 

202-544-5200 

703-318-4672 

202-333-2524 

540-858-3503 

202-564-1664 

Fax 

202-508-5150 

202-260-6606 

202-289-1060 

202-739-9578 

202-662-3910 

919-541-5505 

202-371-5950 

202-887-8800 

202-939-3868 

631-391-6079 

304-258-3927 

202-586-2062 

202-564-5603 

202-942-8484 

703-709-1042 

202-564-1554 

Page 25 
P.27 

No. 

197 

198 

199 

200 

201 

202 

203 

204 

Name 

David Wooley 

Lillian Woolley 

Bob Wyman 

Tom Yancy 

Alec Zacardi 

Rachael Zaffrann 

Maria Zannes 

Rich Zavoda 

Affiliation 

Clean Air Task Force 

ANR 

Latham & Watkins 

McGraw Hill 

Wallace King 

NY State Attorney General's Office 

IWSA 

LTV Steel 

Phone 

518-472-1771 

313-496-3112 

213-891-8334 

202-383-2248 

202-204-1000 

212-416-8487 

202-467-6240 

216-429-6542 

Fax 

518-472-1774 

313-496-2143 

213-891-8763 

202-383-2125 

202-467-6225 

216-429-6541 

Page 26 
P.28 

ATTACHMENT I 

Meeting Agenda 

X] 
P.29 

AGENDA 

STAKEHOLDER MEETING 

NEW SOURCE REVIEW SECTOR-BASED APPROACH 

RONALD REAGAN INTERNATIONAL TRADE CENTER 

WASHINGTON, D.C. 

JANUARY 13,2000 

10:00-10:15 Introduction and Welcome 

Bob Perciasepe 

Assistant Administrator for Air and Radiation, U.S. EPA 

10:15 - 10:20 Opening Remarks / Ground Rules for the Meeting 

Bill Harnett 

Director, Information Transfer and Program Integration Division, 

Office of Air Quality Planning and Standards, U.S. EPA 

10:20 - 10:50 Overview of NSR Alternative Sector-Based Approach 

Kathy Kaufinan 

Information Transfer arid Program Integration Division, 

Office of Air Quality Planning and Standards, U.S. EPA 

10:50 — 11:30 Discussion: Basic Requirements Issues 

11:30-12:30 Lunch 

12:30-1:00 Discussion: Should There Be Trading? 

1:00 - 2:00 Discussion: Trading/Averaging Issues 

2:00 - 2:15 Break 

2:15-2:45 Discussion: State and Federal Roles 

2:45 - 3:15 Discussion: Timeframes and Target Levels 

3:15-3:30 Closing Remarks 

Bob Perciasepe 

Please Note: If people at the table wish to speak - so signify by standing nameplates on end. 

If people in the audience wish to speak - so signify by coming to the microphone. 

2 
P.30 

ATTACHMENT II 

Presentation Slides 

^ 
NEW SOURCE REVIEW 

ALTERNATIVE SECTOR-BASED 

APPROACH 

• • A- > 

USEPA 

January 13,2000 

to 
Goal 

ta 

To develop an alternative approach for NSR for 

an industrial sector that provides more certainty 

and flexibility in planning for the industry, while 

providing certainty in emission reductions. 

• 
General Framework 

*- Covering Electric Utility Industry (Coal-fired) 

.• Declining rate of emissions over time from the 

industry 

IM 

NJ - Must go beyond Phase II of Acid Rain and 

Regional NOx Strategy 

y-10-15 year program 

<• Voluntary program 

• -A- > 

to 
Basic Requirements 

• Companies agree to a specific 

comprehensive pollution reduction 

program 

fe? • New units comply with NSR/PSD 

• Modifications at existing units would be 

subject to NSR/PSD and use a potential 

to potential emission test 

Qr'Jk 
Overall Issues 

• Have had discussions and received input on this 

approach from various stakeholders. 

•• Various issues have been raised of how such a 

£ sector-based approach could be structured and 

T

 implemented. 

•• Looking for a multi-stakeholder discussion on these 

issues to help us understand how the pieces could fit 

together to make a workable program that companies 

would participate in, with real environmental progress. 

• ••• > 
oo 

Basic Requirements Issues 

.• Should the program be limited to coal-fired units only? 

• A participating company (common owner or operator) 

must opt in all coal-fired units? 

• May individual plants opt in? 

OS » What pollutants are covered (PM, S02, NOx, CO)? 

•• Should there be a requirement for superior 

environmental performance? 

• What happens at the end of the program? 

.K- Should there be a sign-up period? 

• 
Should There Be Trading? 

• General Industry support for trading 

• Concerns from States and Environmental 

Groups related to attainment of NAAQS and 

CM 

e Class I areas if you allow trading 

• Are protections needed? 

«• Averaging or Trading? 

*-A- > 
Trading/Averaging Issues 

• How broad should trading be: 

• Geographically? 

, • Pollutants covered? 

-J • Company-wide versus Cross company traded? 

• Compliance time period (monthly, quarterly, yearly, etc.) 

• Do you allow banking? 

• How are shutdowns or changes in ownership treated? 

• Can new units come into the program? 

• What are the appropriate roles for State and Federal 

Governments? 
State and Federal Roles 

NSR/PSD Program is implemented by States through 

SIPs 

Issues 

& . Trading 

• Who tracks the emissions? 

• Who tracks the allowances/averages? 

• Who tracks compliance? (facility-wide or 

company-wide) 

Can States modify the Federal program? 

• •A- > 
Timeframes and Target Levels 

•• What is the rationale for selecting any target 

emission rates or levels? 

•- When does the program begin and how long 

w should it last? Why? 

• *•* > 

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