The Houston-Galveston Brazoria (HGB) area includes the counties of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller come under the nonattainment status for ground-level ozone under the 8-hour standard).

As of 2016, facilities in the HGB area are required to participate in the Mass Emissions Cap and Trade (MECT) Program if their facilities have the potential to emit (PTE) over 10 tons of NOx. In addition, facilities with PTE over 25 tons of NOx and VOC must comply with the Emission Reduction Credit (ERC) program.

TCEQ is in the process of evaluating significant changes to the MECT program, which has created uncertainty surrounding the future value of credits. AEGIS is monitoring the situation and recommends clients consult with our team before taking any action in the market due to unusual risk levels.

AEGIS has significant experience assisting major new builds, expansions, and ongoing operations in this area, managing their ERC and MECT compliance, Highly Reactive Volatile Organic Compound (HRVOC) Emissions Cap and Trade Program.

The HECT Program is a market-based cap-and-trade program that implements an annual HRVOC emission cap for applicable facilities in Harris County. Program participants are required to use allowances to cover HRVOC emissions on an annual basis. The allowances available for use each year are capped at a level necessary to attain the National Ambient Air Quality Standard for ozone. Affected sites are required to participate.

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Strategies for California and Quebec facilities to reduce their compliance cost in the Carbon Cap and Trade Program

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