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EPGA HEDD Proposal. EPGA recognizes the need for NOx emission reductions during HEDD periodsUses the power of market based regulationsProvides a mechanism for easy, quantifiable NOx emissions reductionsQuick and easy PaDEP regulation . EPGA HEDD Proposal Details. Non-CAIR affected electric genera
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1. EPGA Proposal for High Electric Demand Day NOx Emissions Reductions Douglas Biden, President
Electric Power Generation Association
May 30, 2007
2. EPGA HEDD Proposal EPGA recognizes the need for NOx emission reductions during HEDD periods
Uses the power of market based regulations
Provides a mechanism for easy, quantifiable NOx emissions reductions
Quick and easy PaDEP regulation
3. EPGA HEDD Proposal Details Non-CAIR affected electric generating sources surrender CAIR ozone season NOx allowances 1:1
No “opt-in” required
“CAIR affected” units not included
Part 75 monitoring and reporting not required
4. EPGA HEDD Proposal Details (cont.) One report submitted at the end of the ozone season
Current vintage ozone season CAIR NOx allowances submitted to PaDEP for permanent retirement
Affects all electric generating sources
Any electric generating source affected by this regulation would not be affected by the PA small source NOx regulation
5. EPGA HEDD Proposal Benefits Achieves real, quantifiable contemporaneous NOx reductions from non-CAIR affected electric generating sources
Cost effectively regulates small electric generating sources that operate mostly during HEDD periods
Inherently adjusts the reductions to account for more operations of these HEDD sources
6. EPGA HEDD Proposal Benefits (cont.) Results in lowest emitting electric generating sources operating first due to allowance costs
Preserves the cost efficiency of the market based regulations
Preserves electric system reliability
Can be implemented quickly and easily by PaDEP regulation