As part of the State Implementation Plan for attaining the National Ambient Air Quality Standard for ozone, the Texas Commission of Environmental Quality has created a Highly Reactive Volatile Organic Compounds (HRVOC) Emissions Cap and Trade Program for industrial point sources in the Houston/Galveston/Brazoria area. This program has a number of unique features, including its focus on a limited group of ozone precursors and its provisions for trading emissions based on atmospheric reactivity. This series of papers examines the potential air quality impacts of this new emission trading program through photochemical modeling of potential trading scenarios; this first paper in the series describes the air quality modeling methods used to assess potential trades, the potential for localized increases in ozone concentrations (ozone "hot spots") due to HRVOC emission trading, and the use of reactivity scales in the trading. When HRVOC emissions are traded on a mass basis, the simulations indicate that trading of HRVOC allowances between facilities resulted in less than 0.15 ppb (<0.13%) and 0.06 ppb (<0.06%) increases in predicted maximum, area-wide 1-h averaged and 8-h averaged ozone concentrations, respectively. Maximum decreases in ozone concentrations associated with trading, as opposed to across-the-board reductions, were larger than the increases. All of these changes are small compared to the maximum changes in ozone concentrations due to the VOC emissions from these sources (up to 5-10 ppb for 8 h averages; up to 30 ppb for 1-h averages). When emissions of HRVOCs are traded for other, less reactive emissions, on a reactivity weighted basis, air quality simulations indicate that daily maximum ozone concentrations increased by less than 0.3%. Because these relatively small changes (< 1%) are for unlikely trading scenarios designed to produce a maximum change in ozone concentrations (all emissions traded into localized regions), the simulations indicate that the implementation of the trading program, as currently configured and possibly expanded, is unlikely to cause localized increases in ozone concentrations ("hot spots").