In summary, what are EPAs reasons for refusing to accept this proposal in Project XL?
First, the proposal provides, at most, a 2.5 percent reduction in the actual emission rate of the facility, and in a previous experiment — with units that were already subject to a greater degree of control — EPA required a 5 to 10 percent reduction in the actual emission rate. Second, the promised reduction is not guaranteed because the companies can retire allowances if the facility exceeds the target emission rate. Third, the proposal offers little to EPA in the way of new information regarding the bubbling concept. Finally, implementation of the proposal would require overcoming serious legal obstacles. As a result of all of these reasons, EPA decided that, on the whole, the proposal does not meet the requirements of Project XL.
Related Questions
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- In summary, what are EPAs reasons for refusing to accept this proposal in Project XL?