1. Addressing Declining Emissions in Title V Fee Program Design Connecticut’s Approach Anne Gobin NACAA Fall Membership Meeting October 5, 2011

2. The “Challenge” The air program success dependent on emissions decreasing. Flat fee models are not sustainable. Solution-- balance cost and revenue.

3. 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.

4. Fee Calculation Total Premise Actual Emissions $25 per ton in 1989 adjusted by CPI ISF Emission Fee ISF= 133,665 tons divided by inventory for the current year

5. 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.”

6. 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

7. Budget Transparency ANNUAL FINANCIAL REPORT FOR 2011 ISF FLEXIBILITY CONSIDERATION Title V Program FY 2010ESTIMATEDPROJECTED EXPENDITURESACTUALSFY 2011FY 2012FY 2013 SALARIES 5 $2,100,349$2,329,956$2,459,999$2,651,720 FRINGE BENEFITS1,344,4891,531,4281,598,9991,723,618 OTHER EXPENSES38,92730,77333,51235,000 EQUIPMENT11,174010,00050,000 GRANTS/CONTRACTS606,5261,172,226432,048500,000 SUPPORT COSTS 1 867,444759,100801,468863,930 4,968,9095,823,4845,336,0265,824,268 ACCOUNT SUMMARY: BEGINNING BALANCE$15,605,808 REVENUES 2 2,641,974 PROJECTED REVENUE4,000,000 3 5,200,000 4 5,400,000 4 BALANCE$13,278,873$11,455,389$11,319,363$10,895,095

8. 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.

9. 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

10. CT Emissions & Emissions Fees

11. Contributions by Sector 1996 2008 Electric Generator Pharmaceuticals Aerospace Refuse Incineration All Other