Addressing Declining Emissions in Title V Fee Program Design

Connecticut’s Approach

Anne GobinNACAA Fall Membership

Meeting October 5, 2011

The “Challenge”•The air program success dependent on

emissions decreasing.

•Flat fee models are not sustainable.

•Solution-- balance cost and revenue.

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.

Fee Calculation

ISF= 133,665 tons divided by inventory for the current year

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.”

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

Budget TransparencyANNUAL FINANCIAL REPORT FOR 2011 ISF FLEXIBILITY CONSIDERATION

Title V Program

FY 2010 ESTIMATED PROJECTED PROJECTEDEXPENDITURES ACTUALS FY 2011 FY 2012 FY 2013

SALARIES 5 $2,100,349 $2,329,956 $2,459,999 $2,651,720 FRINGE BENEFITS 1,344,489 1,531,428 1,598,999 1,723,618 OTHER EXPENSES 38,927 30,773 33,512 35,000 EQUIPMENT 11,174 0 10,000 50,000 GRANTS/CONTRACTS 606,526 1,172,226 432,048 500,000 SUPPORT COSTS 1 867,444 759,100 801,468 863,930

4,968,909 5,823,484 5,336,026 5,824,268

                     

ACCOUNT SUMMARY:      BEGINNING BALANCE $15,605,808   REVENUES 2 2,641,974  

PROJECTED REVENUE 4,000,000 3 5,200,000 4 5,400,000 4

    BALANCE $13,278,873 $11,455,389 $11,319,363 $10,895,095  

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.

The Process

Source enters emissions data

Emissions statement created in EMIT

DEEP sets fee parameters in EMIT

Fee report Generated

Fee bill sent to sources

CT Emissions & Emissions Fees

Contributions by Sector

1996

2008 Electric GeneratorPharmaceuticalsAerospace Refuse IncinerationAll Other