Thanks, all, for the input so
far. I'm still learning, thanks to your help!
Rodney, here are two things that you
1) I didn't know of the output based
regulation (OBR) effort, so the mention of the book had me searching, and
in so doing I find that EPA has a decent starting point on their web site
- with a link to the book
The google search for the title of the
book also led me to some other good resource links for examples - using
emission reduction credits in addition to allowance trading:
2) I have more people to ask for input.
Both the contact at the CHP page on the EPA site, and you reminded
me of the DOE/NREL environment and energy section - I will be contacting
someone there for their input.
RE: What are the P2 opportunities in
a state-level Clean Air Mercury Rule?
Steve Brachman wrote “As
for p2, we’ve barely scratched the surface on demand side management.
Sure it will take a lot more than compact fluorescents to reduce
our energy footprint, but at least it’s a start.”
That’s for sure. One
approach that some states have taken with respect to the NOx SIP Call and
Clean Air Interstate Rule (CAIR) is to have NOx allowance set asides for
renewable energy and energy efficiency measures. Our neighbors in
MD, for instance, have a set aside or retirement mechanism for NOx allowances
that allows Montgomery County’s purchases of wind power in MD’s SIP.
This requires some reasonable estimate of emissions avoided by buying
green rather than conventional power. The set aside or retirement
approach gives some assurance that the avoided emissions aren’t emitted
elsewhere. A number of states are implementing set asides—IN and
MA are among other states that come to mind. There’s a proposal
here in VA for some modest efficiency/renewable set aside in our upcoming
CAIR rules. (Note: there is some devil in the details on how to incorporate
such set asides so they are effective.)
EPA and DOE both have been
working with some states on clean energy-air quality integration: how to
get green power and energy efficiency recognized or credited in the air
quality regulatory system.
Another piece to this is to
move from input-based emissions standards (lbs/million Btu input) to output-based
standards (lbs/kWh, also with consideration of useful heat output in combined
heat & power operations). Output-based standards would reward
improved efficiency. [EPA developed “Output-Based Regulations: A Handbook
for Air Regulators” as a resource for states.]
What does this have to do with
mercury and CAMR? I’m not completely sure but believe that NOx set
asides under CAIR may be a more useful mechanism to promote P2 in the form
of renewables and energy efficiency than CAMR though, as Rick suggests,
a set aside spproach could be applied to Hg. Use of output-based
emissions standards would be useful. And a state could impose fees/charges
on Hg emissions if it has the political will to do so. A variety
of states have “public benefit charges” on electric bills that are collected
to subsidize clean energy efforts—perhaps such charges can be based on
emissions rates somehow weighted among different pollutants (criteria,
CO2, Hg, other toxics).
In VA I believe our proposed
CAMR has a “public health set aside” that removes/retires some allowances
(why not issue fewer allowances rather than issue more but then retire
some as “public health set asides” is not clear to me).
Rick, your item 3 kinda hits
the issue on the head. As long as coal is cheap, plentiful, and politically
well connected, dirty options will prevail. For example, a recent
wind study in Wisconsin indicated that Lake Michigan has the equivalent
of at least 10 coal fired power plants, with the best resource right off
of Oak Creek, which just happens to be the location of what will be the
7th largest coal fired plant in the US shortly! Go figure.
Gasification was rejected because the technology is unproven, according
to the state PSC. Besides, who wants to eat fish from our lakes anyway?
IMHO, I think the states’ suit is our best option for holding up
the EPA rule at least until 2008 when perhaps a few less special interests
will be in power…
As for p2, we’ve barely scratched
the surface on demand side management. Sure it will take a lot more
than compact fluorescents to reduce our energy footprint, but at least
it’s a start. How about we charge large users MORE for their power,
rather than less, and see if that drives any efficiency? Increased
fuel prices sure have worked well on the SUV industry…
Steve Brachman, Waste Reduction
UW-Extension Solid & Hazardous
Waste Education Center
161 W. Wisconsin Ave., Suite
Milwaukee, WI 53203
[mailto:firstname.lastname@example.org] On Behalf Of Rick Yoder
Sent: Thursday, July 06, 2006 4:36 PM
Subject: What are the P2 opportunities in a state-level Clean Air Mercury
Hi, all, and thanks for taking the time to answer my (most likely naive)
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
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
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
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
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