COULD TRADING MAKE SOME AREAS LESS LIKELY TO ACHIEVE THE OZONE STANDARD?
Another concern besides whether the trading program will achieve its potential cost savings is whether trading could make some areas less likely to meet the ozone standard. EPA’s Ozone Transport Rule calls for significant reductions in NOx emissions throughout the multistate region. Those reductions will be instrumental in reducing ozone concentrations and bringing many counties and metropolitan areas into compliance with the standard. Although introducing allowance trading does not alter the magnitude of the regional abatement effort, it is likely to alter how that effort is distributed among the 23 jurisdictions covered by the rule. With trading, EPA estimates, NOx emissions in 14 of those jurisdictions would be reduced by more than the amount specified in the Ozone Transport Rule. On the whole, electricity-generating sources in each of those 14 jurisdictions would be net sellers of emission allowances.(31) The nine other jurisdictions, the agency estimates, would experience smaller
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