Air Quality: Multi-Pollutant Legislation

Order Code RL31326

Report for Congress

Received through the CRS Web

Air Quality:

Multi-Pollutant Legislation

Updated October 22, 2002

Larry Parker and John Blodgett

Specialists

Resources, Science, and Industry Division

Congressional Research Service ˜ The Library of Congress

Air Quality: Multi-Pollutant Legislation

Summary

With the prospect of new layers of complexity being added to air pollution

controls and with electricity restructuring putting a premium on economic efficiency,

interest is being expressed in finding mechanisms to achieve health and

environmental goals in simpler, more cost-effective ways. The electric utility

industry is a major source of air pollution, particularly sulfur dioxide (SO2), nitrogen

oxides (NOx), and Mercury (Hg), as well as suspected greenhouse gases, particularly

carbon dioxide (CO2). At issue is whether a new approach to environmental

protection could achieve the Nation’s air quality goals more cost-effectively than the

current system.

One approach being proposed is a “multi-pollutant” strategy – a framework

based on a consistent set of emissions caps, implemented through emissions trading.

Just how the proposed approach would fit with the current (and proposed) diverse

regulatory regimes remains to be worked out; they might be replaced to the greatest

extent feasible, or they might be overlaid by the framework of emissions caps.

Currently, eight bills have been introduced that would impose multi-pollutant

controls on utilities. All of the bills control at least NOx and SO2; others include CO2

and Hg. All of these bills involve some form of emission caps, typically taking effect

in 2007; and most include a tradeable credit program to implement that cap. On June

27, 2002, the Senate Environment and Public Works Committee reported out an

amended version of S. 566. Introduced by Senator Jeffords, the bill would place

emission caps on NOx, SO2, and CO2, and emission limitations on Hg.

In February 2002, the Bush Administration announced two air quality proposals.

The first would amend the Clean Air Act to place emission caps on electric utility

emissions of SO2, NOx, and Hg. Implemented through a tradeable allowance

program, the emissions caps would be imposed in two phases: 2008 and 2018. The

second Bush proposal initiates a new voluntary greenhouse gas reduction program.

This plan, rather than capping CO2 emissions, focuses on improving the carbon

efficiency of the economy, reducing current emissions of 183 metric tons per million

dollars of GDP to 151 metric tons per million dollars of GDP in 2012.

The Administration’s three-pollutant proposal was introduced July 26, 2002, as

H.R. 5266 (introduced in the Senate as S. 2815). Its provisions concerning SO2,

NOx, and Hg are less stringent than the other bills introduced and take effect later.

The Administration’s proposal concerning CO2 is difficult to compare with the

pending bills because it is voluntary rather than mandatory: Although the

Administration’s proposal is broader (covering all greenhouse gas emissions rather

than just utility CO2), it appears that actual U.S. greenhouse emissions would be

higher than allowed by the other bills.

This report will be updated as warranted.

Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Proposed Legislation and Legislative Action in the 107th Congress . . . . . . . 2

The Bush Administration’s Proposals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

List of Tables

Table 1: Emissions From U.S. Fossil-fuel Electric Generating Plants . . . . . . . . . 1

Table 2: Comparison of Administration Voluntary Program with Proposed

Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Appendix 1: Comparison of Multi-Pollutant Control Proposals . . . . . . . . . . . . . 7

Air Quality: Multi-Pollutant Legislation

Introduction

Electric utility generating facilities are a major source of air pollution. The

combustion of fossil fuels (petroleum, natural gas, and coal), which account for 67%

of U.S. electricity generation, results in the emission of a stream of gases. These

gases include several pollutants that directly pose risks to human health and welfare,

CRS-2

including particulate matter (PM),1 sulfur dioxides (SO2), nitrogen oxides (NOx), and

mercury (Hg). Particulate matter, sulfur dioxide and NOx are currently regulated

under the Clean Air Act (CAA), and the Environmental Protection Agency (EPA) has

announced its intention to regulate mercury. Other gases may pose indirect risks,

notably carbon dioxide (CO2), which may contribute to global warming.2 Table 1

provides estimates of SO2, NOx, and CO2 emissions from electric generating

facilities. Annual emissions of Hg from utility facilities are more uncertain; current

estimates indicate about 48 tons. Utilities are subject to an array of environmental

regulations, which affect in different ways both the cost of operating existing

generating facilities and of constructing new ones.

Table 1: Emissions From U.S. Fossil-fuel Electric Generating Plants

(thousands of short tons)

Emissions

1994

1995

1996

1997

1998

1999

SO2

14,211

11,437

12,053

12,317

12,432

11,968

NOx

6,790

6,737

6,996

7,227

7,221

7,051

CO2

1,986,079

1,995,471

2,065,339

2,142,118

2,209,286

2,191,576

Source: Energy Information Administration, Electric Power Annual 1999, vol. II, p. 40

The evolution of air pollution controls over time and as a result of growing

scientific understanding of health and environmental impacts has led to a

multilayered and interlocking patchwork of controls. Moreover, additional controls

are in the process of development, particularly with respect to NOx as a precursor to

ozone, to both NOx and SO2 as contributors to PM2.5, and to Hg as a toxic air

pollutant. Also, under the United Nations Framework Convention on Climate Change

(UNFCCC), the United States agreed to voluntary limits on CO2 emissions. The

current Bush Administration has rejected the Kyoto Protocol, which would impose

mandatory limits, in favor of a voluntary reduction program. Thus, mandatory

federal CO2 controls in the United States appear unlikely in the near term.

For many years the complexity of the air quality control regime has caused some

observers to call for a simplified approach. Now, with the potential both for

additional control programs on SO2 and NOx and for new controls directed at Hg and

CO2 intersecting with the technological and policy changes affecting the electric

1

Particulate matter is regulated depending on the particle size; current regulations address

particles less than 10 microns in diameter (PM10); EPA has promulgated regulations for

particles less than 2.5 microns in diameter (PM2.5) which have not been implemented. SO2

and NOx emissions could be affected by regulations of PM2.5. Current concerns about

emissions from fossil-fuel electric generating plants do not explicitly address PM, but could

indirectly do so through attention to SO2 and NOx.

2

Steam-electric utilities produce minor amounts of volatile organic compounds (VOCs),

carbon monoxide (CO), and lead — on the order of 2% or less of all sources.

CRS-3

utility industry, such calls for simplification have become more numerous and

insistent. One focus of this effort is the “multi-pollutant” or “four pollutant”

approach. This approach involves a mix of regulatory and economic mechanisms

that would apply to utility emissions of up to four pollutants in various proposals –

SO2, NOx, Hg, and CO2. The objective would be to balance the environmental goal

of effective controls across the pollutants covered with the industry goal of a stable

regulatory regime for a period of years.3

Proposed Legislation and Legislative Action in the 107th

Congress

Currently, eight bills have been introduced in the 107th Congress to reduce

emissions by increasing pollution controls on electric generating facilities. They are

summarized in Appendix 1. All of the bills control at least NOx and SO2; others

include CO2 and Hg. All of these bills involve some form of emission caps, and most

include a tradeable credit program to implement that cap.

Two bills, H.R. 25 and S. 588, are companion legislation focused on SO2 and

NOx, with a mandate to EPA to regulate Hg by 2005. The bills build on the SO2

allowance trading scheme contained in title IV of the 1990 Clean Air Act

Amendments (CAAA); under this program utilities are given a specific allocation of

permitted emissions (called allowances) and may choose to use those allowances at

their own facilities, or, if they do not use their full quota, to bank them for future use

or to sell them to other utilities needing additional allowances.

Two other bills, H.R. 1256 and S. 556 as originally introduced, are the same

except for minor wording differences. The bills would control SO2, NOx, Hg, and

CO2, but provide considerable flexibility to EPA in developing implementation

strategies. Specifically, EPA implementing regulations are required to allocate

reductions equitably and may consider market-oriented mechanisms, except for Hg.

The fifth bill introduced, H.R. 1335, controls SO2, NOx, Hg, and CO2, but with

individual unit-by-unit requirements for SO2 and NOx based on output-based

emission rates and average 1998-2000 fuel consumption4; a percentage reduction

requirement for Hg; and an allowance-based system for CO2.

The next two bills introduced, H.R. 5266 and S. 2815, are the Administration’s

proposal to control SO2, NOx, and Hg. It is discussed in the next section along with

the Administration’s voluntary CO2 initiative.

The final bill, S. 3135, controls SO2, NOx, Hg, and CO2 with an allowancebased trading system that includes a new source reserve to allocate allowances to

3

Larry Parker and John Blodgett, Electricity Generation and Air Quality: Multi-pollutant

Strategies, CRS Report RL30878, March 13, 2001.

4

Plants built after 2000 appear to be in an anomalous position; as their historical fuel

consumption would be zero, the bill would seem to imply they can emit no SO2 or NOx.

CRS-4

newly constructed sources. The bill includes provisions that would revise Clean Air

Act (CAA) provisions with respect to the New Source Review (NSR) trigger for

modified or reconstructed boilers, and include a cost threshold for the Lowest

Available Emission Rate (LAER) requirement in non-attainment areas. In addition,

S. 3135 would eliminate the CAA’s offset requirement for new electric generating

facilities constructed in non-attainment areas beginning in 2008.

On June 27, 2002, the Senate Environment and Public Works Committee

reported out an amended version of S. 556. As indicated in Appendix 1, in

comparison with the bill as introduced, the amended S. 566's compliance deadlines

for its reduction requirements have been extended one year to 2008. In addition, the

reported bill elaborates on provisions with respect to excess emissions penalties and

protections for possible local ambient air impacts. In particular, the reported bill has

detailed provisions for allocating SO2, NOx and CO2 allowances to various economic

sectors and interests. In most cases, these interests (or their trustees in the case of

households and dislocated workers and communities) would auction off (or otherwise

sell) their allowances to the affected utilities, and use the collected funds for their

designated purposes.

The Bush Administration’s Proposals

In February 2002, the Bush Administration announced two air quality

proposals.5 The first would amend the Clean Air Act to place emission caps on

electric utility emissions of SO2, NOx, and Hg. Implemented through a tradeable

allowance program, the emissions caps would be imposed in two phases: 2010 (2008

in the case of NOx) and 2018. It was introduced as part of a complete rewrite of

Title IV of the Clean Air Act on July 26 as H.R. 5266. It was introduced in the Senate

on July 29 as S. 2815.

As indicated in Appendix 1, H.R. 5266/S. 2815's NOx cap is significantly less

stringent for 2008 than the requirements for 2005 or 2007 in most of the bills

discussed above, and remains less stringent even through the second phase beginning

in 2018. The situation is similar for SO2, except that its 2010 cap is similar to the

H.R. 25/S. 588 cap for 2007 (and S. 3135 for 2008), and its 2018 cap is similar to the

H.R. 1335 cap for 2005. On mercury, H.R. 5266/S. 2815's caps are similar to those

in S. 3135 but come into effect later. H.R. 5266/S. 2815's 2018 Hg emissions goal

allows about 3 times more emissions than those allowed by S. 556, H.R. 1256, and

H.R. 1335 for 2005, 2007, or 2008. (It is not really possible to compare H.R. 25/S.

588, which do not specify an Hg emissions goal, leaving regulation up to EPA,

except that the bills set a regulatory deadline of 2005 while the Administration

proposal would begin regulating Hg in 2010.)

In addition to the emissions caps, H.R. 5266/S.2815 would substantially modify

or eliminate several provisions in the Clean Air Act with respect to electric

5

Papers outlining the Administration’s proposals are available from the White House web

site: [http://www.whitehouse.gov/news/releases/2002/02/clearskies.html] for the three

pollutant proposal and, for the climate change initiative:

[http://www.whitehouse.gov/news/releases/2002/02/climatechange.html].

CRS-5

generating facilities. The New Source Performance Standards (Section 111) would

be eliminated and replaced with standards for SO2, NOx, particulate matter, and Hg

for new sources, and modified sources that opt to comply with them in lieu of Best

Available Control Technology (BACT) determinations under Prevention of

Significant Deterioration (PSD) provisions (CAA, Part C) or Lowest Achievable

Emissions Rate (LAER) determination under non-attainment provisions (CAA, Part

D). Compliance with these provisions exempts such facilities from New Source

Review (NSR), PSD-BACT requirements, visibility (Best Available Retrofit

Technology) BART requirements, and non-attainment LAER requirements. The

exemption does not apply to PSD-BACT requirements if facilities are within 50 km

of a PSD Class 1 area.

Existing sources can also receive these exemptions if they agree to meet a

particulate matter standard specified in the bill along with good combustion practices

to minimize carbon monoxide emissions within 3 years of enactment.

Other exemptions provided by H.R. 5266/S. 2815 include an exemption for

steam electric generating facilities from regulation under Section 112 of the CAA,

and relief from enforcement of any Section 126 petition before 2012. As discussed

earlier, S. 3135 is the only other bill that contains any regulatory relief provisions.

The second Bush administration proposal (for which no legislation has been

introduced) initiates a new voluntary greenhouse gas reduction program, similar to

ones introduced by the earlier Bush and Clinton Administrations.6 Developed in

response to the U.S. ratification of the 1992 UNFCCC, these previous plans projected

U.S. compliance, or near compliance, with the UNFCCC goal of stabilizing

greenhouse gas emissions at their 1990 levels by the year 2000 through voluntary

measures. The new proposal introduced by the Bush Administration does not make

that claim, only projecting a 100 million metric ton reduction in emissions from what

would occur otherwise in the year 2012. Instead, the plan focuses on improving the

carbon efficiency of the economy, reducing current emissions of 183 metric tons per

million dollars of GDP to 151 metric tons per million dollars of GDP in 2012. It

proposes several voluntary initiatives, along with increased spending and tax

incentives, to achieve this goal. However, the Administration states that threequarters of the projected reduction would be achieved through current efforts

underway, not by the new initiatives.

It is difficult to compare the Administration’s proposal to the bills that have

been introduced, as it is a voluntary, not mandatory program. S. 556, H.R. 1256, and

H.R. 1335 set their caps at 1990 levels. S. 3135 sets its final cap at 2001 levels. In

contrast, the Administration’s proposal contains no cap or other limits on emissions.

Rather, following general climate change approaches of the earlier Bush

Administration and the Clinton Administration, the Administration’s proposal relies

on various voluntary programs and incentives to encourage reductions in greenhouse

gases from diverse sources, including CO2 from electric generation.

6

For a discussion of those previous plans, see Larry Parker and John Blodgett, Climate

Change Action Plans, CRS Report 94-404 ENR, May 9, 1994. (archived, available from the

author)

CRS-6

Based on the estimate provided by the Administration’s climate change

proposal, and using the 2002 Climate Action Report7 (CAR) for projections to 2010,

table 2 presents estimates of U.S. greenhouse gas emissions in 2010, assuming the

Administration’s voluntary program reaches its goals.8 This should not be taken as

a given, as neither the former Bush Administration’s program nor the Clinton

Administration’s program achieved their stated goals. Thus, in one sense, comparing

a mandatory reduction program, such as those proposed in legislation, with the

Administration’s voluntary program is comparing apples to oranges. The first is

legally binding, the second is an exhortation.

While S. 556, H.R. 1256, and H.R. 1335 address only electric utility emissions,

their mandated reductions would result in lower greenhouse gas emissions in 2010

than those projected to occur under the Administration’s initiative that includes all

sources of all greenhouse gases.9 Likewise, S. 3135 CO2 control requirement, while

less stringent than S. 556, H.R. 1256, and H.R. 1335, is also estimated to achieve

more reductions than the Administration’s initiative. However, neither S. 556, H.R.

1256, H.R. 1335, S. 3135 nor the Administration’s initiative would be sufficient to

bring U.S. emissions anywhere near the level committed to at Rio with the UNFCCC.

Indeed, discussion in the CAR suggests that a high economic growth scenario

would significantly increase energy use and related carbon emissions. For example,

under a high economic growth scenario, greenhouse emissions in 2010 would

increase 37.7% above those in 1990, based on energy growth alone. This increase

would represent an additional 53 million metric tons of emissions.10 However, S.

556, H.R. 1256, and H.R. 1335 would cap emissions from increased electricity

generation at 1990 levels, which would reduce the 53 million metric tons by 16

million metric tons, or 30% of the high growth increase. The Administration’s

initiative is voluntary, and contains no such mandatory caps on emissions growth.

Table 2: Comparison of Administration Voluntary Program with

Proposed Legislation

S. 556, H.R. 1256, H.R.

1335

Percentage Change v.

Business as Usual (2010)

Percentage Change v.

1990 levels per UNFCCC

-7.5%

+24.2%

7

This is the U.S. report to the UNFCCC Secretariat on U.S. emissions and measures taken

to reduce them. The Climate Action Report -- 2002, available at:

http://www.epa.gov/globalwarming/publications/car/index.html

8

For a discussion of emission projections and trends, see John Blodgett and Larry Parker,

Global Climate Change: U.S. Greenhouse Gas Emissions – Status, Trends, and Projections,

CRS Report 9-235 ENR (February 28, 2002).

9

The assessment assumes that the Administration’s proposal actually achieves its goal in

2010, rather than 2012.

10

Energy Information Administration, Annual Energy Outlook 2000, Washington D.C.,

DOE/EIA-0383 (2002), December 2001. p. 177.

CRS-7

S. 3135*

Administration Voluntary

Program*

Business as Usual

-5.1%

+27.5%

-4.4 to -4.5%

+28.3%

0

+34.4%

*Assumes requirement (S. 3135) or goal (Administration Voluntary Program) is achieved

in 2010, rather than 2012.

Source: CRS calculations based on projections contained in 2002 CAR.

CRS-8

Appendix 1: Comparison of Multi-Pollutant Control Proposals

H.R. 1256

(Waxman)/

S. 556 (as

introduced)

(Jeffords)

H.R. 5266/S. 2815

(Administration’s

Proposals)

S. 3135

(Carper)

estimated at 1.6

million tons in

2005, declining

with plant

retirements

2.1 million tons in

2008, declining to

1.7 million tons in

2018

1.87 million tons in

2008, declining to

1.7 million tons in

2012

2.23 million tons in

2007

estimated at 3.2

million tons in

2005, declining

with plant

retirements

4.5 million tons in

2010, declining to

3.0 million tons in

2018

4.5 million tons in

2008, declining to

2.25 million tons in

2015

estimated at 2.05

billion tons in

2008

estimated at 1.914

billion tons in 2007

1.914 billion tons in

2005

none, program is

voluntary

estimated at 2.6

billion tons in 2008,

declining to an

estimated 2.3

billion tons in 2012

EPA to regulate by

2005

estimated at 5 tons

in 2008

estimated at about

4-5 tons in 2007

estimated at about

4-5 tons in 2005

26 tons in 2010,

declining to 15 tons

in 2018

24 tons in 2008,

declining to 5-16

tons by 2012

according to an

EPA determination

48 contiguous states

and DC

50 states and DC

50 states and DC

50 states and DC

50 states, DC, and

territories

50 states and DC

Provisions

H.R. 25 (Sweeney)/

S. 588 (Schumer)

S. 556 (as reported)

(Jeffords)

Emissions Cap on

NOx

estimated at 1.5

million tons in 2007

with interim reductions

estimated at 1.5

million tons in

2008

estimated at 1.5

million tons in

2007

Emissions Cap on

SO2

4.45 million tons in

2007

2.25 million tons

in 2008

Emission Cap on

CO2

not covered

Emissions Cap on

Mercury

Scope

H.R. 1335

(Allen)

CRS-9

Provisions

H.R. 25 (Sweeney)/

S. 588 (Schumer)

S. 556 (as reported)

(Jeffords)

H.R. 1256

(Waxman)/

S. 556 (as

introduced)

(Jeffords)

Affected Units

electric generating

facilities 25 Mw or

greater

electric generating

facilities 15 Mw or

greater

electric generating

facilities 15 Mw or

greater

electric generating

facilities 15 Mw or

greater (50 Mw for

CO2)

for existing SO2,

NOx, and Hg,

electric generating

facilities 25 Mw or

greater; no size

minimum on new

facilities; voluntary

CO2 program is

economy-wide

fossil fuel-fired

electric generating

facilities greater

than 25 Mw (coalfired facilities in the

case of Hg controls)

Penalties for noncompliance

NOx: $6,000 per

excess ton plus onefor-one offset from

future emission

allocations

NOx and SO2:

same as CAA, title

IV except excess

emission penalty is

three times the

average market

price for

allowances

determined by EPA

NOx, SO2, Hg: no

special penalties

specified – CAA

penalties would

apply

NOx, SO2, Hg:

reduces the excess

emissions penalties

under CAA, title

IV to the lowest

EPA auction price

for allowances plus

one-for-one offset

from future

emission

allocations

NOx: $5,000 per

ton plus one-forone offset from

future emission

allocations

SO2: same as CAA,

title IV

CO2: three times

the average market

price per excess

metric ton of CO2

emissions

Hg: three times the

average Hg control

costs per gram of

excess emission

H.R. 1335

(Allen)

CO2: $100 per ton

plus one-for-one

offset from future

emission

allocations

H.R. 5266/S. 2815

(Administration’s

Proposals)

CO2: none –

voluntary program

S. 3135

(Carper)

SO2: same as CAA,

title IV

Hg: $10,000 per lb.

plus one-for-one

offset from future

emission

allocations

CO2: $100 per ton

plus one-for-one

offset from future

emission

allocations

CRS-10

Provisions

H.R. 25 (Sweeney)/

S. 588 (Schumer)

S. 556 (as reported)

(Jeffords)

H.R. 1256

(Waxman)/

S. 556 (as

introduced)

(Jeffords)

Special Provisions

NOx allowance value

halved during ozone

season;

all powerplants

30-years or older

must meet current

New Source

Performance

Standard (NSPS)

requirements

all powerplants 30years or older must

meet current New

Source

Performance

Standard (NSPS)

requirements

reserve of allowances

for new sources

SO2 cap divided by

region (West and

East)

other provisions to

protect local air

quality

H.R. 1335

(Allen)

permanent CO2 and

NOx reductions

through plant

retirements should

be credited in any

future climate

change

implementation

program enacted by

Congress

H.R. 5266/S. 2815

(Administration’s

Proposals)

new performance

standards for new

sources replace

current NSPS for

new sources.

Compliance

exempts such

facilities from New

Source Review

(NSR), PSD-BACT

requirements,

visibility BART

requirements, and

non-attainment

LAER

requirements. The

exemption does not

apply to PSDBACT

requirements if

facilities is within

50 Km of Class 1

area. Existing

sources can opt in

by meeting a

particulate standard

Exempts utility

units from

regulation under

CAA, Section 112

Prevents EPA from

S. 3135

(Carper)

tonnage limitations

in effect for 20

years; EPA to

reassess after 15

years

CO2 limitations

include provisions

providing CO2

allowances for

renewable energy,

sequestration, and

other greenhouse

gas emission

reduction projects

revises the trigger

for New Source

Review (NSR) to

modifications that

exceed 50% of new

construction costs;

and Lowest

Achievable

Emission Rate

(LAER) to include

a cost threshold; in

2008, eliminates the

offset requirement

in non-attainment

areas for new

electric generating

facilities

Provisions

H.R. 25 (Sweeney)/

S. 588 (Schumer)

S. 556 (as reported)

(Jeffords)

Implementation

Strategy

tradeable allowance

system

tradeable

allowance system

for SO2 (restricted

between East and

West regions),

NOx and CO2.

Allowances

allocated to

various sectors and

interests, including

households,

dislocated workers

and communities,

electricity

intensive

industries, affected

utilities, energy

efficiency and

renewable energy

activities, and

sequestration

activities

H.R. 1256

(Waxman)/

S. 556 (as

introduced)

(Jeffords)

to be determined by

EPA — market

mechanisms

permitted (except

for Hg)

H.R. 1335

(Allen)

unit-by-unit

compliance with

SO2, NOx, Hg

provisions;

tradeable allowance

system for CO2

Hg compliance on

a unit-by-unit

basis

Unless otherwise noted, estimates by CRS using Department of Energy and Environmental Protection Agency data

H.R. 5266/S. 2815

(Administration’s

Proposals)

tradeable allowance

system for SO2,

NOx, and Hg.

Allocation formulas

in the bill initially

provide most

allowances to

affected sources

free, with a small

percentage sold at

auction. Over time,

an increasing

percentage of the

allocation is sold at

auction with

affected sources

receiving fewer

allowances free

S. 3135

(Carper)

tradeable allowance

system for SO2,

NOx, Hg, and CO2.

Allocations

formulas for NOx,

Hg, and CO2 based

on generating

efficiency; SO2

allocations based on

current CAA, title

IV provisions.

Allocations

formulas for all

four pollutants

include a new

source reserve to

provide allowances

to newly

constructed sources