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



If "they" are going to implement a trading scheme of any kind, then there is
a P2 opportunity to enforce some basic competence into the emitters.

Let's never forget that *most* of the people making the management decisions
at the emission sources have STILL never heard of P2 or even think about it
like many of you do.  There are many possibilities they don't even know
about.  The decision makers are financial people now, running power plants
from offices 500 miles away, and don't understand this stuff.  The plant
managers don't do anything without corp approval and don't submit P2 budget
requests because they are not understood.  

What if management P2 training in mercury source reduction methods was
required as a condition of trading in the first place.  You HAVE to be
certified in mercury management and reduction or you can't trade.

There are only going to be hundreds, not millions, of people affected by
this.  It can be done.  And I am real interested to hear why the people
emitting the mercury should not be required to prove they know what the hell
they are doing and how to reduce emissions.  We know that much pollution is
created through ignorance.  Why should we tolerate this with mercury when we
know who specifically are the ignorant people?

Massachusets has done this same approach through Toxics Use Reduction
Planner certification for years.  It seems to work.  Why not with mercury
reduction?  And make top corp management take the training, not the facility
folks.

Mercury reduction in power plants and major sources is a corporate awareness
and behavior change issue.  Trading makes sense but only if all the players
are educated about the rules and the goals and motivated to play right.

Burton Hamner
President, Cleaner Production International LLC
Producer, http://www.CleanerProduction.Com - 
  #1 on Google for Cleaner Production and for Sustainable Business Training
wbhamner@cleanerproduction.com
(206) 526-5308, mobile (206) 491-0945
-- Check out the Sustainable Business CD Library - a guided tour and
collection of the best public-domain reference manuals and guides to
sustainable business in all its aspects.    http://www.cleanerproduction.com

 
-----Original Message-----
From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On
Behalf Of Reibstein, Rick (ENV)
Sent: Friday, July 07, 2006 10:56 AM
To: Rick Yoder; Sobin,Rodney
Cc: Steve Brachman; p2tech@great-lakes.net
Subject: 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 <mailto:ryoder@unomaha.edu> 
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/ <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 <mailto:rsobin@deq.virginia.gov>  
________________________________________________________
Environmental Assistance for Small Businesses
<http://www.deq.virginia.gov/osba/smallbiz.html>
http://www.deq.virginia.gov/osba/smallbiz.html
<http://www.deq.virginia.gov/osba/smallbiz.html>  
Virginia Comprehensive Assistance Network
<http://www.deq.state.va.us/osba/vacan/>
http://www.deq.state.va.us/osba/vacan/
<http://www.deq.state.va.us/osba/vacan/>  
DEQ Innovative Technology <http://www.deq.virginia.gov/innovtech>
http://www.deq.virginia.gov/innovtech
<http://www.deq.virginia.gov/innovtech>  
DEQ Distributed Energy Resources
<http://www.deq.virginia.gov/innovtech/der1.html>
http://www.deq.virginia.gov/innovtech/der1.html
<http://www.deq.virginia.gov/innovtech/der1.html> 
Virginia Environmental Services Network <http://www.vesn.biz/>
http://www.vesn.biz <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/0/0DA0784C33C6A74486257193
0070FC17?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 <mailto:ryoder@unomaha.edu> 
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/ <http://www.p2ric.org/> 
 	  

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


  



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