Cap-and-Trade (C&T) programs have become increasingly important in the control and regulation of regional and global air pollutants. In contrast to traditional air pollution regulations, C&T programs require subject facilities to comply with a facility emissions cap that declines on an annual basis, while providing the flexibility to buy and sell excess emission reductions (referred as allowances or credits). Since the 1990 Clean Air Amendments, C&T programs have been used to regulate regional air pollutants, such as volatile organic compounds (VOCs), oxides of nitrogen (NOx), and oxides of sulfur (SOx). In recent years, C&T programs are being used as the primary regulatory vehicle for controlling greenhouse gas (GHG) emissions within the U.S. and internationally.
Where applicable, C&T programs can impact many different types of air pollution sources and industrial sectors, including heavy industry, manufacturing, power, transportation fuels, and utilities. Depending upon the specific rules developed by the regulatory authority, C&T facilities must contend with numerous compliance requirements that far exceed traditional air pollution regulations, which may include:
- Declining annual permit limits
- Industry benchmarking for free credit allowances
- Daily, monthly and/or annual emissions reporting
- Quarterly and annual permit reconciliations
- Buying and selling of emission credits
- Forecasting future emissions and credit needs
- Developing air pollution control plans and strategies
- Continuous Emissions Monitoring (CEMS)
- Frequent regulatory audits, inspections and testing
- Independent 3rd party verifications
Trinity’s multi-disciplined staff provides the highest quality C&T support services that enhance strategic planning and regulatory compliance while maximizing operational flexibility. Trinity helps its clients accomplish this by combining regulatory expertise, technical proficiency, responsiveness, and creative thinking.
Trinity offers strategic advisory and consulting services to prepare and support clients in all phases of C&T regulatory programs, including:
- Early stages of rule development
- Annual reporting and compliance
- Buying/selling of allowances
- Air pollution control plans and compliance forecasting
Trinity regularly monitors the development of C&T programs and actively supports hundreds of regulated facilities throughout the United States and international territories. For more information on Trinity’s C&T regulatory services, please contact Charles Lee or Steve Walters at (949) 567-9880.