Why isn EPA willing to use the facilitys allowable emission rate as the baseline against which the project is measured? Doesn this penalize the facility for being a good environmental performer?
From the start, Project XL has been designed to provide future environmental benefits by encouraging superior environmental performance, not just to reward past behavior. Thus, in judging XL proposals, EPA assumes that voluntary controls already in place will remain in place regardless of whether an XL project is implemented. In addition, had the facility been emitting the maximum amount permitted by law, EPA would almost certainly have required greater reductions in the emission rate than the amount it requested in this instance. Further, if EPA were to give the companies credit based on their statement that, in the absence of Project XL, the facility would begin operating at the applicable allowable rate, it would be providing better treatment to companies inclined to eliminate preexisting voluntary controls than to companies that intend to continue practicing good environmental stewardship.
Related Questions
- Why isn EPA willing to use the facilitys allowable emission rate as the baseline against which the project is measured? Doesn this penalize the facility for being a good environmental performer?
- What is EPA policy regarding whether an organization that previously received funding for a particular project is eligible to apply for funding under this RFP for the same project?
- What is EPA anticipating the length of each project period to be for the prime recipients in this program?
