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Pat Quinn, Governor |
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2007 APR Table of Contents
Emissions Reduction Market SystemAnnual Performance Review Report - 20077 Distribution of Emissions7.1 Geographic Distribution of TransactionsTable 7-1 summarizes the number of ATUs traded for each county. It should be noted the total number of ATUs that appear to be leaving the nonattainment area is much higher than the total coming in. This is mostly due to ATUs sold to general participants who do not reside in any particular county and who have not then traded those ATUs back into the area for use by a participant. In addition, ATUs traded to special participants are counted as being “sold” but not “bought” because all such ATUs are immediately retired without being used in a particular county. ATUs donated to ACMA would have a similar result as they are also not used in any particular county. Similarly, the ATUs for excursion compensation did not come from any county. Table 7-1: ATUs Traded by County
the county. The vast majority (over 5,000 ATUs) is due to 3M’s Environmental Management System Agreement which requires the source to donate half of their ATUs to a Special Participant. Counties that show an increase also include sources purchasing ATUs to cover past compliance problems. The history of ATUs traded by county can be found in Section 8.4. During the seven years of the program, no pattern or trend in trading, in terms of ATU flow among the counties has emerged. Table 7-2 provides a comparison by county showing baselines, allotments and actual reported ATU use. Table 7-2: ATU Comparison by County
The overall actual emissions in the nonattainment area and in all counties except Kendall were substantially lower than allotted emissions. Kendall’s excess emissions are due to a small increase in emissions from the single ERMS source in that county. Table 7-3 shows how many ATUs have expired and are being retained by county. The percent expired and percent retained is calculated based upon the 2007 allotment. Table 7-3: Total ATUs Expired and Retained by County
Illinois EPA has utilized townships to look at ATU trading activity in more detail. Specifically, the Public Land Survey System township locations were used. Survey townships were chosen for a number of reasons, including their generally uniform size, unchanging historical borders and readily available population data. The borders of other possible geographic units such as ZIP codes or census tracts could change due to factors not involved in ERMS. A listing of the townships is given in Appendix A. There are 61 townships with ERMS participants and a total of 118 townships in the nonattainment area. Tables 7-4 and 7-5 summarize the number of sources in townships and the area of townships. Table 7-4: Number of Sources per Township
Table 7-6 summarizes trading at the township level. Table 7-6: ATUs Traded by Township
Tables 7-7 and 7-8 summarize the ATUs expired and retained at the township level of the entire nonattainment area. The percentage given is for the number of ATUs that expired as compared to the number of ATUs allotted to the township in 2007. See Appendix B for full details by township number. Table 7-7: Expired ATUs by Township
Table 7-8: Retained ATUs by Township
To get a full picture of how the ERMS program works at a township level, it is necessary to look at the actual emissions rather than simply at trades. Some companies had excess ATUs they could have sold if a buyer had been located. Others may have chosen not to sell even if their emissions were lower than their allotments. Illinois EPA compared the actual emissions reported by participants in each township to the baselines and allotments for those townships and used this approach throughout the remainder of the analysis. In this analysis, Illinois EPA found that four townships, or 3.4 percent of the 118 townships in the entire Chicago NAA showed increases in emissions over their baselines, as shown in Table 7-9.Table 7-9: Townships with Emissions Over Baseline Level
Figure 7-1 shows all participating sources and the five townships highlighted in yellow with an increase over their baselines. Each township with an increase over its baseline has only one source. Table 7-10 identifies the townships that had 2007 seasonal emissions exceeding their allotment level. These six townships represent 5.1 percent of the total townships.Table 7-10: Townships with Emissions Over Allotment Level
Figure 7-2 shows all participating sources in the NAA and highlights in yellow the seven townships which show increases over their allotments. Figures 7-3 and 7-4 show the highlighted townships for both baseline and allotment comparisons and flag only those sources that traded. Both of these maps show a single buyer or two in each of the affected townships that put that township over its baseline or allotment. Every county, but one, and the nonattainment area overall showed emissions significantly less than both the baseline and allotment. Appendix B contains the data from which all of the above information was obtained and a map showing actual emissions compared to the allotment. 7.2 Type of SourceTable 7-11 identifies sources by their two-digit SIC code for each source that took part in a trade. Table 7-11: Transactions by SIC Code
Table 7-12 provides the allotments for every SIC code which has a participant and that are being retained by sources in that industrial category. Table 7-12: Total ATUs Expired and Retained by SIC Code
7.3 Trends and Spatial Distributions of Hazardous Air Pollutants (HAPs)This is the seventh year sources have reported their HAP emissions. Area-wide emissions of HAPs show a downward trend since the first reporting year of 2001. VOM emissions show a generally downward trend. Emissions of HAPs by county can be found in Section 8. Figures 7-5 and 7-6 show the previously mentioned townships and those ERMS sources that reported VOM HAPs in their SER. While most of the townships in question do contain sources that reported HAPs, there is no geographic concentration of such sources. To further examine any possible relationship between HAP emitters and those townships which saw an increase, Figures 7-7 and 7-8 show those sources which are both HAP reporters and also participated in a trade during the 2007 season. As can be seen on those figures, there were only three ATU buyers out of these HAP reporters in highlighted townships. All three of these buyers had a decrease in HAP emissions from 2006 to 2007. Table 7-13 shows the total HAPs reported for each township. It also shows the relative HAP emission density by looking at the percentage of HAP emissions compared to the total reported HAPs for the entire nonattainment area by ERMS sources and the net result of trading that took place in those townships. Once again, the areas with the highest HAP emissions were not buying ATUs and increasing HAP emissions. Furthermore, overall HAP emissions have decreased over the years for which data had been collected. From this, trading does not appear to influence HAP emissions.
Table 7-13: Reported HAP Emissions by Township
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Figures 7-9 and 7-10 compare changes in HAP emissions on both a source and on a township basis. For 2007 the number of sources with increases in HAP emissions were about the same as the number of sources with decreases in HAP emissions. The number of townships with increases in HAP emissions was slightly higher than the number of townships with decreases I HAP emissions. Overall, HAP emissions decreased about 7 tons for the area.
Illinois EPA also looked at population densities relative to HAP sources to determine if trading activity might be affecting the more densely populated areas. Population densities, rather than actual populations, were used to normalize the emissions as the population might be distributed over a wide area.
Figures 7-11 and 7-12 show the sources which reported HAPs on a map that is color-coded for population density. There are no higher density areas which also have a HAP reporter and emissions above the baseline or allotment level.
It should be noted that all of the sources that increased their HAP emissions could have done so without the ERMS program and would have been less restricted in doing so because the ERMS program holds them accountable for those emissions as with any other VOM emissions.
Table 7-14 summarizes the key results from evaluating Figures 7-9 through 7-12.
Table 7-14: Key Results on HAPs for Seven Highlighted Townships
Township |
HAP Source Present? |
Trading HAP Source? |
Population Density Level |
Percent of VOM that are HAPs |
3610 – Lockport |
Yes |
No |
2 |
7.2 |
3708 – Oswego |
Yes |
Yes |
1 |
6.6 |
3811 – Downer’s Grove |
Yes |
Yes |
3 |
5.0 |
4009 – Wayne |
No |
Yes |
3 |
0.0 |
4407 – Dorr |
Yes |
Yes |
1 |
20.3 |
4511 – Warren |
No |
Yes |
2 |
0.0 |
Illinois EPA’s Annual Emission Report rule allows the gathering of additional HAP information that may not have already been reported for the following three cases:
If a source identifies one or more of these cases, the Illinois EPA may send a HAP Information Request Letter. The main goal of acquiring additional information is to ensure the levels set for HAP reporting are adequate to catch any potential problems related to both HAPs and the ERMS program. For the 2007 season, the Illinois EPA did not have cause to send out any such letters.
The Illinois EPA’s analysis indicates the ERMS program does not affect changes in HAP emissions. The reporting levels in place within the AER rule are considered to be appropriate.



