Hi, all, and thanks for taking the time
to answer my (most likely naive) questions.
If you are familiar with the Clean Air
Mercury Rule (CAMR) and the kerfuffle around it, you know much more than
I. I was lucky(?) enough to sit in the initial stakeholder meeting
held in Nebraska to craft NE's version of CAMR.
Suffice it to say that what I heard from the power plants was that they
mostly favor adopting EPA's model mercury rule as IA & MO have done
- but I think I understand NDEQ correctly - we do have an opportunity
to weave P2 components into the NE rule.
So here is my question: Do you have any ideas about appropriate P2
Here's what I'm thinking about with
my limited knowledge - feel free to let me know if I'm totally off base
- or even better, suggest more ideas:
1) Since Hg emission "allowances"
will be tradable- why not hold some or most of them in reserve? Companies
could presumably buy from other places in the country if necessary.
The scarcity will work to drive up prices of what is available, and
the current external costs would be more readily internalized. (I
doubt that this stands much of a chance - at least less of a chance with
each allowance held in reserve).
2) For power plants, provide an
equation whereby the transfer of possession of an allowance from a state-held
reserve is offered to firms for putting new, non-mercury producing power
capacity on line. The owners of these allowances could hold or sell
them as they see fit - using proceeds of the sale to reduce their cost
of implementation, for instance.
3) For power plants, establish a long-term
requirement to reduce the amount of mercury emitted/KWh of energy generation.
In the meeting, I was struck with by the power company mindset that
growth would happen, and therefore the future need would be for more mercury
emitting capacity. Why not plan for and encourage growth in non-mercury
emitting power production?
4) Use a fee (may not be possible) to
set up a fund to pay for the damages of mercury emissions. While
I hear an argument that mercury is naturally occurring, or that emissions
are fed into the global atmosphere (at least since the stacks were extended
in the 70's) I wonder how long before the people of the arctic http://www.inuitcircumpolar.com/
start to ask for compansation of past damage. Yes, I know this is
not P2 per se, but building additional internal costs to offset the historic
and current external costs would serve as an incentive for the companies
to come up with their own P2 activities.
5) Use a fee (may not be possible)
to set up a fund to pay for mercury reduction education programs and projects.
Seems like the least an emitter could do would be to fund the awareness
and understand of others who are not regulated.
6) One other fee idea - that might work
- is to pay for the establishment and administration of a coordinated regional
map of the most current Hg emissions coming from a facility (looking ahead
to what will be possible) - a rudimentary framework is shown in this
Google Maps mashup - http://www.sierraclub.org/maps/coal.asp This
is reminiscent of TRI & 33/50 in the sense that the public would be
able to see how plants compare with each other.
7) The facility and organization
offices could develop a mercury inventory and a mercury reduction plan
- eliminating mercury switches, lights, etc.... I'm thinking this
would not be a 1:1 emissions offset. Why allow Hg emissions at all
without demonstrating a willingness to eliminate the use of this toxic
materials everywhere else under their control?