Has the Regional Greenhouse Gas Initiative Been Successful?

The Regional Greenhouse Gas Initiative (RGGI) was supposed to be nearing completion of a 2016 Program Review[1] but the election of Donald Trump and the fate of the national Clean Power Plan has delayed that process. This is the first post in a series of posts that will discuss how RGGI has fared so far. This particular post will provide background information so that I don’t have to include it every time. The RGGI stakeholder process is dominated by its adherents and now that I am retired I can offer an alternative view of the program. In this post I will offer my thoughts on whether the program has been successful.

RGGI is a cap and auction program in nine states – Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island and Vermont – to reduce greenhouse gas emissions[2]. According to the most recent RGGI Investment Summary Report[3]:

Proceeds from the Regional Greenhouse Gas Initiative (RGGI) have powered an investment of $1.37 billion in the energy future of the New England and Mid-Atlantic states. This report reviews the benefits of programs funded through 2014 by RGGI investments, which have reduced harmful carbon dioxide (CO2) pollution while spurring local economic growth and job creation. The lifetime effects of these RGGI investments are projected to save 76.1 million MMBtu of fossil fuel energy and 20.6 million MWh of electricity, avoiding the release of approximately 15.4 million short tons of carbon pollution.

I have been involved in the RGGI program process since its inception. Before retirement from a Non-Regulated Generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance. From that background let’s look at the RGGI results quoted above.

The biggest flaw in the adherent’s vision of RGGI success is that RGGI is a driver of affected source decisions. In my opinion based on my experience and discussion with company folks responsible for the economics and operations of affected facilities where I worked and elsewhere, RGGI is simply a tax. Yes it adds to the cost of doing business but because the cost of allowances can be added into the bid price it is a nuisance and not a driver of decisions. I will address how this added cost ultimately affects emissions in a later post.

When RGGI notes that $1.37 billion is being invested in the energy future of the New England and Mid-Atlantic states that number reflects the proceeds from the allowance auctions aka the tax. Because this is a carbon tax there a couple of cautionary tales. The reference notes that the nine participating RGGI states received $1.79 billion in auction proceeds in the period covered by this report. RGGI investments represent $1.37 billion spent to date and another $329.4 million is committed to 2015 and future programs. Note that these numbers do not total up. Despite best intentions by those folks who set up the program $93.1 million has been transferred to state general funds by politicians. In other words any carbon tax should have iron clad specifications on how the money will be used or politicians will get involved and co-opt the stated goal of the tax.

In RGGI the stated goal was to invest the RGGI proceeds in programs that would ultimately reduce carbon emissions and protect the rate-payers. The Investment Summary Report notes the fraction of funding that reduce carbon emissions (overall 80%) for energy efficiency (57%), clean & renewable energy (15%), and GHG abatement (8%) programs. Direct bill assistance (15%) is a more difficult sell as a carbon abatement program but because increased costs to the consumer disproportionately affect those least able to afford those increases I personally can live with those programs. However, 4% of the funds went to “administration” and another 1% to the RGGI organization itself. Clearly when big bucks are involved politicians are not the only ones attracted to the trough. The concept of a carbon tax that offsets that cost and returns all proceeds to offset other taxes is attractive. Based on RGGI, however, be careful what you wish for.

To their credit RGGI analyses have always been careful to not over-sell the actual emission reductions due to RGGI itself. When the Program Review notes that the lifetime effects of these RGGI investments are projected to save 76.1 million MMBtu of fossil fuel energy and 20.6 million MWh of electricity they are basing those numbers on the displacement of energy and emissions due to their energy efficiency, clean and renewable energy and GHG abatement programs. As noted earlier these numbers will be addressed in a later post.

Finally let’s consider the ultimate goal of the program – GHG reductions. The Program Review Summary claims their investments have avoided the release of approximately 15.4 million short tons of carbon pollution. However, note that they spent $1.37 billion to achieve those reductions so the cost per ton is $88.67. Given that the EPA social cost of carbon is $36 per ton these reductions are not cost effective by that measure.

However one thing is missing in all of the analyses and reports to date. The ultimate purpose of the program is to lower global warming but nothing has ever been published quantifying what these reductions will do in that regard. A back of the envelope calculation shows why. A recently published paper[4] estimates that the Federal Clean Power Plan will reduce global temperature rise by 0.013 degrees Centigrade. The Clean Power Plan is supposed to reduce CO2 emissions by 870 million tons. The carbon reductions attributable to RGGI are 15.4 million tons and simply pro-rating the published projection of global temperature rise with the RGGI emissions yields 0.00023 degrees Centigrade. In my opinion because we cannot possibly measure that small a change in temperature the global warming benefit of this program is nil.

I will give RGGI credit for developing the infrastructure to conduct a cap and auction program. They have an auction system that has conducted numerous sales without a hitch, there is a CO2 tracking program and the compliance methodology works. In addition the investments in energy efficiency and direct bill assistance are social benefits with no regrets.  As a result I believe that RGGI is only a qualified limited success and no where near as successful as it its adherents claim.

[1] https://www.rggi.org/design/2016-program-review

[2] https://www.rggi.org/rggi

[3] https://www.rggi.org/rggi_benefits

[4] Bjorn Lombory, 2015: Impact of Current Climate Proposals, Global Policy, Article first published online: 9 NOV 2015, DOI: 10.1111/1758-5899.12295, http://onlinelibrary.wiley.com/doi/10.1111/1758-5899.12295/full

Scott Pruitt Nomination and EPA Approach to Interstate Transport Ozone Attainment

At this time there is quite a bit of noise about potential problems if Scott Pruitt is confirmed to head EPA because he would “hamstring EPA’s authority to set nationwide environmental standards”. As I understand it he is proposing to cooperate more with the states. This post describes a particular example where states proposed an alternative approach but in a recent action EPA continues to ignore the alternative proposed. I hope to show why I think that is a mistake. If Pruitt can get EPA to respond to this type of state action I support his nomination.

In my opinion one of the bigger air quality issues is ozone attainment, particularly as it relates to interstate transport. EPA explains that “air transport refers to pollution from upwind emission sources that impact air quality in a given location downwind”.  Emissions of nitrogen oxides (NOX) and Volatile Organic Compounds (VOC) can each undergo chemical reactions in the atmosphere to create ground-level ozone (smog) pollution.

The EPA website for interstate air pollution explains the “Good Neighbor” provision that requires EPA and states to address interstate transport of air pollution that affects downwind states’ ability to attain and maintain ambient standards. One of the reasons that the ozone limit has proved to be particularly difficult to attain is that the standard was recently tightened. In this example, I want to address the recent EPA Notice of Data Availability for the preliminary interstate ozone modeling data for this new limit.

EPA notes that they have completed preliminary interstate ozone transport modeling relevant for the 2015 ozone national ambient air quality standard. We are currently in the public comment period where the Agency is providing an opportunity for public review of this modeling data, including projected ozone concentrations and contributions for 2023, as well as projected emissions, including emissions from the power sector, that were used for this modeling.

In EPA’s approach the modeling projects ozone concentrations in 2023 at individual monitoring locations to determine the state-by-state contribution. EPA used a 2011-based air quality modeling platform which includes emissions, meteorology and other inputs for 2011 as the base year for the modeling and then projected the 2011 base year emissions to the 2023 base case scenario. The modeling domain covers the entire United States with a grid resolution of 12 km. I refer you to the technical support document for details of this modeling analysis.

I think that there are two glaring problems with EPA’s approach: one related to the emissions and one related to the air quality modeling. Both are related to the fact that the current ozone problem is episodic. Peak ozone concentrations only occur during several-day summertime hot and humid periods which also are periods of peak electrical demand.

EPA’s emissions approach goes to great lengths to project future year emissions at the expense of actual observed emissions. EPA uses the Integrated Planning Model, a massive proprietary planning model to project the emissions in future years. Because emissions are dependent upon fuel prices, technology, regulations, and energy use trying to estimate future emissions is a very complex undertaking and can only provide annual or seasonal average estimates. However, the primary concern are the peak periods and this model does not project these extreme periods well.

In order to address that problem the Eastern Regional Technical Advisory Committee was formed to prepare an alternative to the EPA emissions modeling approach. Basically the states and industry collaborated to develop an alternative based on adjustments to observed emission and operating rates. The result was Eastern Regional Technical Advisory Committee Electricity Generating Unit Emission Projection Tool. Importantly, this approach more accurately represents the actual and future emissions during ozone episodes than the EPA approach.  Unfortunately, this alternative approach was not used by EPA for this modeling.

Although EPA’s air quality modeling analysis is an impressive effort it also falls short of what I think is needed. As noted previously, EPA’s ozone projection methodology covers the entire United States on a 12 km by 12 km grid. My primary interest is New York State and the largest interstate impact of New York sources to ozone monitoring stations is downwind of New York City in Connecticut. I am convinced that the complex meteorological conditions during ozone episodes in this situation (land and sea breezes, elevated terrain concerns, and the nocturnal boundary layer structure along the coast) cannot be represented well enough to be accurate using such a coarse grid. Moreover, using that grid means that the many of the emissions are incorporated into the modeling at the same coarse grid resolution and there are indications that leads to further inaccuracies.

There is another problem with EPA’s modeling. They used a base year of 2011. As part of comments I developed to address the previous round of EPA interstate modeling, I compared daily New York electric generating unit emissions and observed ozone levels on an annual basis by running a regression to determine if there was a relationship. Not surprisingly there always was a statistically significant relationship. However what was interesting is that that strength of the relationship has changed recently. Prior to 2014 the regression analysis always indicated that there was a relatively strong relationship but in the last three years the relationship has deteriorated substantially. In order to accurately determine what is causing high ozone today a base year in the last three years is needed when this different regime of the relationship occurred.

I believe that in order to solve the interstate ozone transport problem it is first necessary to understand what is going on. EPA’s preliminary modeling described in their December 2016 Notice of Data Availability will not provide the necessary level of detail to describe the current situation. The Eastern Regional Technical Advisory Committee emissions modeling approach addresses one aspect that needs to be corrected. If Scott Pruitt’s approach to administering EPA would facilitate EPA using this alternative and modeling this problem differently then I believe his nomination should be supported.

Pragmatic Environmentalist of New York Principle 4: We can do almost anything we want, but we can’t do everything.

This is a background post for my perception of pragmatic environmentalists per the principles listed in the about section of this blog.

Environmental initiatives often are presented simply as things we can do. Over at Climate Etc. the Planning Engineer coined this statement when he said that when his children asked “Can we do this?” he used to annoy his children with the answer “We can do almost anything we want, but we can’t do everything.” They came to learn that response meant that something “unthinkable” would likely have to be given up to indulge the extravagance.

This is a fundamental aspect of pragmatic environmentalism. While it is fine and appropriate to propose actions to reduce environmental risks that are technologically feasible, in the real world the costs to implement those policies carry costs that have to be considered. Moreover there could be unintended consequences.

As the Planning Engineer explains in his blog post: “There is no bargain to be found by pushing jointly for both more microgrids and the greater integration of “clean” resources. Having both will require huge sacrifices. If society’s utmost desire is a “clean”, highly reliable grid, resilient, secure grid – we likely can build that at some enormous cost. However, if cost is a factor impacting electric supply then tradeoffs will have to be made from among competing goals and technologies.”

Pragmatic Environmentalist of New York Principle 3: Baloney Asymmetry Principle

This is a background post for my perception of pragmatic environmentalists per the principles listed in the about section of this blog.

I updated this on May 8, 2017 to add references for the lake effect snowstorm example and lake temperature data.

Alberto Brandolini: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.”

Brandolini’s link is to a presentation on the problem and includes recommendations for dealing with it in the context of the managerial leadership. However it is directly relevant to environmental issues as well.

Consider this example of global warming causing severe weather. In November 2014 there was a massive lake-effect snow storm in Western New York. New York’s Attorney General said the snowstorm was evidence of needed action on climate change. Slate followed the event with an article “proving” the claim.

In order to repudiate the global warming trigger claim the lake effect mechanism has to be explained and the relevant data from the event compiled. The Slate article explained that lake effect snow is caused by a temperature difference between a body of water and the air over the lake. The BS claim is that because the water is warmer then the storm was worse. However the alignment of the wind with the lake, the depth of the cold air layer, and the change of wind direction with height all contribute to the severity of a lake effect snowstorm.

To repudiate the BS claim these other factors have to be explained and the necessary data to show how they affected the storm compiled and presented. It turns out that the primary factor causing the extraordinary snow amounts with this particular storm was that the wind direction stayed constant for much longer than normal. That being the case how did global warming contribute to constant winds? Moreover, when I checked the actual lake temperature with the average lake temperature it was more or less the same as the average. The Slate article relied on average temperature data but not the data from the event.   If global warming were the cause then why wasn’t the lake warmer than average during the event?

Update May 8, 2017: References for the lake effect snowstorm example and lake temperature

Lake Effect Snowstorm November 17 – 19, 2014

Average Lake Erie Temperature Period of Record 1992 – 2016

  • November 19: 9.7 deg. C
  • November 20: 9.5 deg. C
  • November 21: 9.4 deg. C

Actual Lake Erie Temperature during the event – All three days were colder than average!

  • November 19, 2014: 8.9 deg. C
  • November 20, 2014: 8.2 deg. C
  • November 21, 2014: 7.5 deg. C

 

Pragmatic Environmentalist of New York Principle 2: Sound Bite Environmental Issue Descriptions

This is a background post for my perception of pragmatic environmentalists per the principles listed in the about section of this blog.

Sound bite descriptions necessarily only tell one side of the story because they have to fit space available. As a result they frequently are mis-leading, not nuanced, or flat out wrong.

Sound bites are brief recorded statements (as by a public figure) broadcast especially on a television news program or a brief catchy comment or saying. In this principle, I would expand the definition to include the core information that “everyone knows” about a particular topic. In today’s society they unfortunately represent an inordinate share of the public’s knowledge of an environmental issue.

In my, admittedly limited, experience trying to describe a technical issue or project to the press or a public relations person the interview often led to innocent mis-characterizations. If the audience does not have relevant background and you are not experienced talking to that kind of audience to include appropriate background information, the resulting sound bite can be mis-leading.

Because there are space and time constraints there is no room for the background caveats to explain the nuances of the issue. This limitation also can be primarily innocent.

However, there can be more sinister implications to the sound bite when the story is politically motivated or fits the agenda of an organization. In these cases noble cause corruption can lead the author of the sound bite to deliberately characterize the issue incorrectly by selectively choosing the information included and not including key caveats.

Whatever the cause, the problem for pragmatic environmentalists is that correcting the record won’t be a sound bite so the audience that only has the patience to hear the sound bite may ignore the correction or lose interest in the complete story. Moreover space or time may not even be available to provide the clarifying information.

Pragmatic Environmentalist of New York Principle 1: Environmental Issues are Binary

This is a background post for my perception of pragmatic environmentalists per the principles listed in the about section of this blog.

In almost all environmental issues there are two legitimate sides. Pragmatic environmentalism is all about balancing the risks and benefits of both sides of the issue. In order to do that you have to show your work.

While this might seem patently obvious presented in this fashion consider how often the public discourse on an environmental issue is just a long list of environmental impacts that “everyone knows” and suggestions that those impacts will be catastrophic.

Consider this example: “For decades, power plants in our communities here in Western Queens have strongly contributed to increased asthma rates and increases in hospitalizations and ER visits that exceed the average in Queens,” said Councilman Costa Constantinides.

It is generally accepted that asthma rates have been increasing but the problem is that over the same period where they are increasing ambient pollution levels have been going down. Consider the EPA Air Quality Trends at New York City information that shows that from 2000 to 2015 ozone is down 16.7%, inhalable particulate matter is down 31.7% and sulfur dioxide is down 85.1%. These data suggest that increasing asthma rates are not the result of increasing pollution rates contradicting the environmental impact that “everyone knows” causes increasing asthma rates. For a comprehensive evaluation of the EPA science related to particulate matter health impacts I recommend “Scare Pollution: Why and How to Fix the EPA”.

Pragmatic environmentalists recognize that air pollution causes health impacts. However the risk that additional societal investments for increased pollution control could not provide the intended benefits has to be considered. In particular, if society spends money to reduce power plant emissions below the rates that have contributed to the lower observed pollution levels it may not improve asthma rates and worse may divert money that more appropriately should be invested into research determining why asthma rates are increasing so that the actual causes can be addressed.

Replacement Power for Indian Point

Summary

Since his election New York’s Governor Andrew Cuomo has threatened the closure of the Indian Point Energy Center located 25 miles north of New York City and in January 2017 finally announced its closure by April 2021. Cuomo claims that Indian Point produces 2,000 megawatts of electrical power and that “more than enough replacement power to replace this capacity will be available by 2021”.

However, when you look at what has been permitted to be built within that time frame it is not clear that is as straight forward as suggested. In the first place, Indian Point’s nameplate capacity is 2,150 MW not 2,000 as described. Nuclear power is characterized by high capacity factors and because Indian Point provides over 20% of New York City’s power the location of the replacement generation matters. The Champlain Hudson Power Express transmission line has been permitted to bring 1,000 MW of Hydro Quebec hydropower to New York City. The only other large generation resource that has been permitted close to New York City is the Cricket Valley Energy Center, a proposed 1,000 megawatt combined-cycle, electric generating plant. So nominally these two facilities can replace 2,000 MW of Indian Point but as shown in this post the devil is in the details.

Cuomo’s Indian Point Closure Plan

As part of his state of the state proposals, Governor Andrew M. Cuomo announced the closure of the Indian Point Energy Center by April 2021. As described in the press release the Governor’s position is:

  • Replacement Power: Indian Point produces 2,000 megawatts of electrical power. Currently, transmission upgrades and efficiency measures totaling over 700 megawatts are already in-service. Several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power. Together, these sources will be able to generate more than enough electrical power to replace Indian Point’s capacity by 2021.
  • Early Close Date: Entergy Corp. has agreed to cease all operations at Indian Point and will shut down the Unit 2 reactor in April of 2020. Unit 3 will be shut down in April of 2021. Unit 1 reactor was permanently shut down in October 1974 because the emergency core cooling system did not meet regulatory requirements. In the event of an emergency situation such as a terrorist attack affecting electricity generation, the State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively.
  • Negligible Bill Impact: The Public Service Commission’s Indian Point Contingency Plan and other planning efforts have ensured that more than adequate power resources are able to come online by 2021 to ensure reliability of the power grid. Given these planning efforts and likely replacement resources, the plant’s closure in 2021 will have little to no effect on New Yorkers’ electricity bills.
  • No Net Increase of Emissions Due to Closure: The Governor’s leadership on energy and climate change will ensure that Indian Point’s closure will not have an adverse impact on carbon emissions at the regional level. Through the Regional Greenhouse Gas Initiative, the state will continue to drive reductions in greenhouse gases across the power sector. Further, the Governor’s Clean Energy Standard to get 50 percent of New York’s electricity from renewables by 2030 is the most comprehensive and ambitious mandate in the state’s history to fight climate change, reduce harmful air pollution, and ensure a diverse and reliable energy supply at affordable prices.

Other Side of the Story – Replacement Power

There are two aspects of power generation that have to be considered when discussing replacement power: the potential power output or name plate capacity and the actual generation produced. The New York State Independent Operator annual load and capacity report, the “Gold Book” provides that information. The name plate capacity of Indian Point 2 is 1,070 MW and Indian Point 3 is 1,080 MW. The average net generation from 2011 to 2015 from Indian Point 2 was 8,530 GWh and from Indian Point 3 was 8,422 GWh or 16,953 GWh from the facility. My point is that the net generation is the key parameter for replacement not the capacity.

In order to determine whether the Governor’s plan holds water we have to parse the press release. The first suggested component is “transmission upgrades and efficiency measures totaling over 700 MW that are already in-service”. I have trouble understanding how these measures will replace observed generation. The aforementioned NYISO 2016 Gold Book describes distinct transmission projects approved by the PSC as part of the Indian Point Contingency Plan in October 2013 that were projected by the Transmission Owners to be in service by summer 2016 and also notes that it also included 125 MW of additional demand response and combined heat and power resources to be implemented by Consolidated Edison, some of which is already in effect. Presumably these projects are part of the 700 MW mentioned in the press release.

However, the contingency plan was developed to specifically address the problem that New York City is essentially a massive load pocket. Because most of New York City and Long Island are on islands they are a limited number of transmission lines into the City so the location of the generation matters. Moreover, because one of the City blackouts occurred because of a disruption to transmission into the City, reliability planning is a very important. My guess is that these in-service upgrades and measures are critical to that requirement. However because they were in place and Indian Point generation did not go down they do not represent actual displacement of the energy produced. Maybe it won’t be needed in New York City but it was used elsewhere and must be replaced.

The press release notes that “several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power.”   I assume that the hydropower replacement refers to Champlain Hudson Power Express. As noted previously the only other New York City are large generation resource that I know of is Cricket Valley.

According to the Champlain Hudson Power Express web site the project will bring up to 1,000 megawatts (MW) of clean, renewable power to the New York metro area. For the purposes of this analysis assume that this power can be provided 100% of the time. With that assumption, Champlain Hudson Power Express provides 8,760 GWh of power so we only have to replace 8,193 GWh of Indian Point Generation.

According to the Cricket Valley web site this is a proposed 1,000 megawatt (MW) combined-cycle, electric generating plant in Dover, NY. I could not find a proposed capacity factor (actual generation divided by the maximum potential generation) so assumed 80%. In that case, the net generation 7,008 GWh so the remaining generation needed is 1,185 GWh.

Therefore, in order to displace the actual average generation produced by Indian Point additional generation capacity capable of 1,185 GWh is needed. Implicit in the Governor’s plans is that renewable energy will be part of this replacement. Rather than trying to explain the difficulties of that approach myself, I refer you to the Planning Engineer’s explanation that Not all Megawatts are Equal. If the problems enumerated in this post could be overcome the total generation produced by 21 NYS industrial wind facilities in 2015 was 3,983 GWh so it appears that seven more wind facilities could produce the remaining generation. Note however, that the total wind energy nameplate capacity is 1,892 MW with a capacity factor of 28% in 2015. Because Indian Point generation is dispatchable that means true replacement energy has to produce dispatchable power and that requires storage. Moreover, the timing of when wind is available means that more nameplate capacity would be required than necessary at first glance. There are similar concerns relative to the use of solar renewable energy. So I remain unconvinced that replacement will be as easy as proposed.

Other Sides – Timing, Bill Impact and Emissions

Each of these topics could have their own post but I am only going to address each briefly.

The schedule is for Entergy Corp. to shut down the Unit 2 reactor in April 2020 and Unit 3 in April 2021. The State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively. Both the Champlain Express and Cricket Valley projects have been permitted but neither has started construction. The expected construction time for Champlain Express is three and a half years which means that it will not be ready by April 2020. Because natural gas combined cycle plants have relatively short construction times that facility probably will meet the first closure date if construction begins soon. I strongly believe that no new generation facility greater than 25 MW in New York State can be permitted in less than five years because of the extraordinary permitting requirements in place so nothing else could be permitted and constructed by the second closure date. So I expect that the extensions will be needed.

The Governor claims there will be negligible bill impact because of planning efforts and likely replacement resources. I am not an economist but the expected costs of Champlain Express $2.2 billion and Cricket Valley $1.5 billion have to be paid for somewhere. Surely the costs to continue operating Indian Point are less than that. Why won’t pre-mature retirement of this resource have a bill impact?

This plan is supposed to lead to no net increase of emissions due to closure. The emphasis has always been on carbon “pollution” and the press release is careful to claim no adverse impact on carbon emissions at the regional level skirting the question whether NY emissions will increase. In fact even if Cricket Valley is the only fossil replacement power for Indian Point there were will be an increase of over 3,630,484 tons of GHG emissions (Table 4-2 in the Cricket Valley DEIS). The missing pollutant is Nitrogen Oxides. The final Cross State Air Pollution Rule allowance budget and the Governor’s policies on allowance distributions could very likely lead to a problem covering emissions with allowances (a topic for a separate post). If the generation gap from the closure of Indian Point is made up of New York’s existing natural gas plants and Cricket Valley then there could over 400 tons of additional NOx emissions. Emissions in the 2016 ozone season were 6,521 and the allowance budget is only 5,135 tons. New York State has aggressively pursued NOx reduction policies and there are not many opportunities left for additional reductions so any increase is problematic.