Although the NSR and PSD programs appear to have been effective for new facilities, such programs and related economic factors (1) provide an incentive for industries to extend the life of higher-emission (grandfathered) facilities and (2) lead to litigation alleging facility modifications (primarily to extend their useful lifetime) without prior approval.
The NSR and PSD programs do not affect a large fraction of the existing facilities that have not undergone major modifications but have remained in operation.
With the exception of CEM, there is limited ability to quantify stationary-source emissions.
Facility-specific emission standards have lowered emissions, but because they are often production-based standards, the potential remains for emissions to increase as economic activity or product demand increases.
The next phase of control on HAP emissions is predicated on the conclusions of a residual risk analysis that is fraught with scientific uncertainty.
Achieving the full potential of cap and trade will require applying the technique to a broader range of pollutants, implementing a less cumbersome process for revising caps and targets, developing enhanced and more cost-effective CEM and other monitoring technologies, and guarding against deleterious geographical and temporal distribution of emission reductions.
Controls on area sources lack focus and are hampered by a large number of uncertainties in the magnitude of the emissions from these sources.
To date, many emission-control programs for stationary sources have addressed pollutants separately, resulting in different time lines and different requirements for reductions of various pollutants at the same facility. That approach can raise the cost of emission control without adding any appreciable benefit in emission reductions. Recent legislative proposals for multipollutant reductions at electricity-generating facilities offer an opportunity to merge one of the most successful techniques—cap and trade—with a multipollutant approach. This merger would enable these facilities to develop long-term plans for capital improvements that minimize costs and reduce all relevant pollutant emissions at the same time.
Recommendations are provided in Chapter 7.