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



I'm having trouble, as usual, with the trading concept.  I don't think anyone should be able to buy or sell the right to emit mercury, because I think there is only one appropriate response to the issue of mercury emissions - which is to find the best way to reduce them at all source points. 
 
Now that I got that off my chest, you can tell me I'm being unreasonable, that trading is economically efficient.  But it has only been alleged to be that in situations that are fundamentally different from mercury (and I still don't buy it - because the alternative, an improved and more efficient system of emission limits, fully incorporating P2, was not tested).  Allowing one source to increase mercury emissions will create a hot spot.  Crafting a better rule could involve addressing the problems hotspots will cause.  I would suggest that if we are going to allow increases at individual sources through trading, that we might concentrate on mitigating that harm by requiring that a huge percentage be retired before the trade goes through, and that the buying company purchase bonds and insurance.  The bonds to be used for cleaning up mercury in local soils and water, and the insurance to be used for compensating people in the area who will end up with increased mercury in their bodies.  The company should also pay for free mercury tests before anything happens so that a comparative baseline can be laid down.  A rule of liability should be included making it easier for people to sue that source in personal injury if they are harmed, and that there is a presumption that they are harmed if there are increased levels of mercury in their bodies.  The rule should establish that they have standing to sue, and it should give them court costs, attorney's fees, and expert witness fees.  It should clarify that the source would be jointly and severally responsible, that the legal standard to apply would be strict liability, and that the standard of proof would be "more likely than not".  Now that might be preventive!


From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of Rick Yoder
Sent: Friday, July 07, 2006 12:06 PM
To: Sobin,Rodney
Cc: Steve Brachman; p2tech@great-lakes.net
Subject: RE: What are the P2 opportunities in a state-level Clean Air Mercury Rule?


Thanks, all,  for the input so far.  I'm still learning, thanks to your help!

Rodney, here are two things that you triggered:
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
http://www.epa.gov/chp/state_resources/output_based_reg.htm - with a link to the book
http://www.epa.gov/chp/pdf/output_rpt.pdf
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:
http://www.northeastchp.org/nac/policymakers/regs.htm
http://www.intermountainchp.org/policymakers/default.htm
http://www.epa.gov/cleanenergy/pdf/gta/guide_action_chap5.pdf
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.

Keep the ideas coming!!!

Richard Yoder, PE
Director, P2ric.org
University of Nebraska at Omaha
6001 Dodge Street, RH308
Omaha, NE 68182
vox: 402-554-6257
fax: 402-554-6260

http://www.p2ric.org/
 

P2RIC, the Pollution Prevention
Regional Information Center, is
a proud member of the Pollution Prevention
Resource Exchange, P2Rx.org.





"Sobin,Rodney" <rsobin@deq.virginia.gov>

07/07/2006 09:58 AM

To
"Steve Brachman" <brachman@uwm.edu>, "Rick Yoder" <ryoder@mail.unomaha.edu>, <p2tech@great-lakes.net>
cc
Subject
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).
 
Sorry for verbosity.  I hope this is helpful.
 
Rod
 
Rodney Sobin
Office of Small Business Assistance
Virginia Department of Environmental Quality
Postal: P.O. Box 10009, Richmond, VA 23240-0009
Street:  629 E. Main St., Richmond, VA 23219-2429
Tel. 804-698-4382       fax 804-698-4264

rsobin@deq.virginia.gov
________________________________________________________

Environmental Assistance for Small Businesses http://www.deq.virginia.gov/osba/smallbiz.html
Virginia Comprehensive Assistance Network http://www.deq.state.va.us/osba/vacan/
DEQ Innovative Technology http://www.deq.virginia.gov/innovtech
DEQ Distributed Energy Resources http://www.deq.virginia.gov/innovtech/der1.html
Virginia Environmental Services Network http://www.vesn.biz
-----Original Message-----
From:
owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of Steve Brachman
Sent:
Thursday, July 06, 2006 5:58 PM
To:
Rick Yoder; p2tech@great-lakes.net
Subject:
RE: What are the P2 opportunities in a state-level Clean Air Mercury Rule?

 
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 Specialist
UW-Extension Solid & Hazardous Waste Education Center
161 W. Wisconsin Ave., Suite 6000
Milwaukee, WI 53203
414-227-3160
http://shwec.uwm.edu
brachman@uwm.edu



From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of Rick Yoder
Sent:
Thursday, July 06, 2006 4:36 PM
To:
p2tech@great-lakes.net
Subject:
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
6001 Dodge Street, RH308
Omaha, NE 68182
vox: 402-554-6257
fax: 402-554-6260

http://www.p2ric.org/
 

P2RIC, the Pollution Prevention
Regional Information Center, is
a proud member of the Pollution Prevention
Resource Exchange, P2Rx.org.