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Addressing Declining Emissions in Title V Fee Program Design Connecticut’s Approach

Addressing Declining Emissions in Title V Fee Program Design Connecticut’s Approach. Anne Gobin NACAA Fall Membership Meeting October 5, 2011. The “Challenge”. The air program success dependent on emissions decreasing. Flat fee models are not sustainable.

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Addressing Declining Emissions in Title V Fee Program Design Connecticut’s Approach

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  1. Addressing Declining Emissions in Title V Fee Program DesignConnecticut’s Approach Anne Gobin NACAA Fall Membership Meeting October 5, 2011

  2. The “Challenge” • The air program success dependent on emissions decreasing. • Flat fee models are not sustainable. • Solution-- balance cost and revenue.

  3. Inventory Stabilization Factor (ISF) • Designed to maintain adequate funding for Title V program by compensating for emissions decrease in the fee calculation formula. • Incentive for a source to beat the average decrease or fees increase.

  4. Fee Calculation ISF= 133,665 tons divided by inventory for the current year

  5. RCSA 22a-174-26(d)(4)(C) … “Inventory Stabilization Factor… is a value equal to the total actual emissions of 133,665 tons per year from stationary sources in the 1990 Inventory divided by the total statewide stationary source actual emissions from the previous calendar year…. The commissioner shall, thirty days prior to application of the Inventory Stabilization Factor, file with the Secretary of the Office of Policy and Management a report describing the calculation of the Inventory Stabilization Factor with relevant supporting documentation.”

  6. Justification • New, unknown CAA amendments of 1990 • Fee demonstration required by EPA • All sources pay equivalent of $25/ton (mobile $4 every two years) • Minimum ($5000) and Maximum ($500,000 in 1989 $) • Fees solely for Title V program • Oversight by OPM

  7. Budget Transparency

  8. Avoid Surplus by Reducing the ISF • Regulations allows for fiscal analysis and reducing fees. • The reduction cannot cause the Air Emissions Permit Operating Fee account balance to fall below an amount sufficient to cover two years of Title V program expenses. • What constitutes a Title V program expense is determined in accordance with section 502(b)(3) of the Clean Air Act.

  9. The Process Source enters emissions data Emissions statement created in EMIT DEEP sets fee parameters in EMIT Fee bill sent to sources Fee report Generated

  10. CT Emissions & Emissions Fees

  11. Contributions by Sector Electric Generator Pharmaceuticals Aerospace Refuse Incineration All Other 2008 1996

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