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What are the P2 opportunities in a state-level Clean Air Mercury Rule?




Hi, all, and thanks for taking the time to answer my (most likely naive) questions.

Background:
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.  
http://www.deq.state.ne.us/__862565E9004DFE93.nsf/0/0DA0784C33C6A744862571930070FC17?Open&Highlight=2,mercury
and
http://www.deq.state.ne.us/AirDivis.nsf/Pages/Mercury
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 possibilities?


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?

Thanks in advance for your interest and input.

rick







Richard Yoder, PE
Director, P2ric.org
University of Nebraska at Omaha
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