4 The record articles

Did you know there are 5 emissions trading programs in Texas?!

Posted: November 5th, 2019

Authors: Tanner H. 

This blog is the first in a series where I will discuss Texas Emissions Banking and Trading (EBT) programs specifically in the Houston-Galveston-Brazoria (HGB) region.  In this edition, I will explain what EBT programs are, the purpose they serve, the different types of programs, and the requirements for following their regulations.

At the publish date of this article, the HGB region has ozone levels above the National Ambient Air Quality Standards (NAAQS), making it a non-attainment area for ozone.  Because of this, a State Implementation Plan (SIP) is required.  The purpose of a SIP is for states to reduce emissions with the goal of reducing pollutant levels back below the NAAQS.  One of the most popular ways for states to reduce emissions is by implementing EBT programs.  EBT programs provide facilities flexibility in their methods to reduce emissions and in permitting matters.

There are two main categories of EBT programs; voluntary and mandatory.  The voluntary EBT programs are the Discrete Emission Credit (DERC) program (30 Texas Administrative Code [TAC] Chapter 101, Subchapter H, Division 4) and the Emission Reduction Credit (ERC) program (30 TAC Chapter 101, Subchapter H, Division 1).  Mandatory EBT programs are the Emissions Banking and Trading of Allowances (EBTA) program (30 TAC Chapter 101, Subchapter H, Division 2), the Highly Reactive Volatile Organic Compound Emissions Cap and Trade (HECT) program (30 TAC Chapter 101, Subchapter H, Division 6), and the Mass Emissions Cap and Trade (MECT) program (30 TAC Chapter 101, Subchapter H, Division 3).

The voluntary EBT programs give facilities the opportunity to generate emission reduction credits by making permanent emissions reductions (e.g., permanent shutdown of an emissions unit, installation of an air pollution control device) at their facilities.  These credits can be used in many ways.  One popular way to use emission reduction credits is for offsets for a new source or major modification to an existing source.

Facilities that are required to participate in mandatory EBT programs (e.g., emissions cap and trade programs) must cover their emissions that exceed their allocations by purchasing additional allowances.  These programs give the Texas Commission on Environmental Quality (TCEQ) an avenue to control emissions in nonattainment areas, for example in the HGB region to bring ozone levels back down below the NAAQS.

Stay tuned for an upcoming edition of 4 The Record where I will discuss more in depth about the MECT program which affects major sources in the HGB region.  If you have any questions regarding this blog, please do not hesitate to reach out to me at thenson@all4inc.com or 281-937-7553 x308.

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