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

1. The Designated Representative and Allowance Accounts Under CAIR,CAMR, and the ARP EPA Region 7 Workshop Kansas City, Kansas August 16, 2007 Robert Miller

2. What is a Designated Representative? • A person authorized by the owners and operators of a facility to: • Sign, date, & attest to the truth, accuracy, and completeness of submissions made under CAIR, CAMR, or the ARP. • The DR must be the same person for CAIR, CAMR, and the ARP.

3. What Kinds of SubmissionsDoes the DR Make? • The DR submits, and attests to the truth, accuracy, and completeness of (among other things): • Certificate of Representation • Emissions data reports • Monitoring plans and certification applications • Permit applications • Allowance transfers • Monitoring petitions

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

5. Who Can Be a DR? • EPA is not hung up on titles, but . . . • The DR must be a person (no companies, associations, LLCs, etc.), and; • Must have the necessary authority to carry out his or her responsibilities as the DR, and; • Must be the same person for CAIR, CAMR, and the ARP

6. Other Persons Can Act on Behalf of the Designated Representative • Alternate Designated Representatives • Agents • Source management agents • Allowance trading agents • Compliance agents • General accounts management agents • The DR is still ultimately responsible for all submissions made on behalf of the owners and operators of the facility

7. How Does a PersonBecome a DR? • Submission of a complete Certificate of Representation (DR form) to EPA HQ (CAMD) establishes the DR (and ADR, if applicable) for the facility. • There is no deadline for submission of the DR form, but it must be submitted before any other submission can be legally made under CAIR, CAMR, or the ARP.

8. Certificate of Representation • Facility name, State, and plant code (same as ORIS or facility code) • County name where the facility is located • Latitude and longitude of the facility • Name, title, company name of DR • Fax, Phone, and email address (not an option)

9. DR Form (cont’d) • For each unit subject to CAIR, CAMR, or the ARP, fill out one “Page 2” • Check the box(es) indicating the Program(s) the unit is subject to • Duct burners and steam turbines are not listed • Indicate the unit type

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

11. DR Form, Cont’d. • Page 2, cont’d. • Enter the generator ID # • Enter the nameplate capacity of each generator served by the unit in MWe • For ARP-affected units in NADB: use “NAMEPCAP” in NADB for ARP nameplate capacity

12. DR Form, Cont’d. • Page 2, cont’d. • For CAIR-CAMR affected units, & ARP affected units not in NADB, use the higher of 2 numbers for both ARP & CAIR-CAMR nameplate capacity: • Manufacturer’s rating for maximum electrical generating output capacity, or; • If physical change increases maximum electrical generating output, the increased maximum electrical generating output

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

14. Submitting the DR Form • Hardcopy submissions: • EPA must receive originals (no faxes) • Form must be complete, even if only minor changes are being made • In a hurry? Overnight mail is best if CBS not an option, OR . . . . .

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

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

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

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

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

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

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

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