Do all emission reductions have to clear through the bank or can an operator use on-site emission reductions to meet emission reduction requirements?
This question is really one of netting. Can a source “net out” of emission offset requirements by using on-site emission reductions to reduce the net emission increase of a modification to below the emission threshold that triggers offsets? The answer is yes. However, be aware that for nonattainment pollutants the APCD uses the dual source definition. This means that for the modification, an operator cannot use on-site emission reductions to net out of an offset requirement. Such reductions may, however, be used as offsets at the offset trading ratio. For a new modification where the modification does not trigger nonattainment offset requirements by itself, but where the entire source may trigger offsets, and for attainment pollutant offset requirements, an operator can use on-site reductions to avoid offsets. See the later discussion in this section on the issue of netting.
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