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State Attorneys General, Governors & Global Warming

State Attorneys General (SAGs) are asking President Bush to support mandatory reductions of carbon dioxide. The National Governor's Association (NGA) wants more studies. AAEA supports mandatory reductions of carbon dioxide with emissions trading mechanisms. SAGs from Alaska, California, Connecticut, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont sent a letter to the president noting that because states are going their own way on climate change policy, "The resulting combination of state-by-state regulations and litigation will necessarily lessen regulatory certainty and increase the ultimate costs of addressing climate change..." These 11 SAGs have it right. Interestingly, they represent 143 of Al Gore's electoral votes and 7 of President Bush's total of 271. I wouldn't be surprised if the SAGs' letter to President Bush was stamped, "Return to Sender--Address Unknown."

The NGA takes a softer, less effective approach. They recommend that the U.S.:

not sign or ratify any agreement that mandates new commitments to limit or reduce greenhouse gas emissions for the U.S., unless such an agreement mandates new specific scheduled commitments to limit or reduce greenhouse gas emissions for developing countries within the same compliance period;
aggressively undertake strategies for including emissions-reduction commitments from developing countries;
not sign or ratify any agreement that would result in serious harm to the economy of the U.S.;
support flexible policies and measures in continuing negotiations that provide an opportunity for the U.S. to meet global environmental goals without jeopardizing U.S. jobs, trade or economic competitiveness..."

AAEA has a comprehensive strategy for clean air and global climate change:

Emissions allowance trading,
Mandatory emissions caps for carbon dioxide, NOX, SO2 & mercury,
Aggressive federal subsidies for commercialization of solar, wind power and other alternative technologies,
Aggressive federal subsidies for electric vehicles,
Construction of new nuclear power plants, and
Commercialization and subsidies for clean coal technogies, such as Electro-Catalytic Oxidation (All-in-one scrubber for SO2, NOx, PM & Mercury).

Global Warming Links

The is the Old Version (See New Version)

PRINCIPLES TO GUIDE DEVELOPMENT OF A TRADING PROCESS

TO REDUCE GREENHOUSE GAS EMISSIONS

Created and Endorsed By

The Greenhouse Gas Alliance for Credit Trading (GHG ACT)

The potential threats associated with climate change are sufficiently severe to justify prudent, meaningful action by the world community. This recognition is reflected in the United Nations Framework Convention on Climate Change (UNFCCC)1, to which the United States is a ratified signatory, as well as the Climate Change Action Plan of the New England Governors/Eastern Canadian Premiers.

Massachusetts is the first U.S. state to adopt legislation and regulations that reduce greenhouse gas (GHG) emissions from existing power plants (310 CMR 7.29). {California has passed a greenhouse gas law aimed at automobiles.} The lack of effective on-site reduction technology means these plants will meet their requirements through GHG credit trading.

By adopting GHG credit rules that encourage economically efficient emission reductions, Massachusetts can demonstrate that sensible actions can be taken now to achieve meaningful GHG reductions without harm to its economy from large increases in energy costs. In fact, Massachusetts can send a powerful message to other states and the federal government on taking prudent, meaningful action now by creating a sustainable and affective GHG trading system.

The following principles will achieve the goal of creating a workable trading system that provides incentives for environmentally and economically beneficial action:

1. Credits may be earned by any source that avoids, reduces or sequesters GHG as long as the reductions are real, surplus, enforceable and verifiable

2. Attributes of a credit should be fully disclosed to market participants and the public

3. Compliance with GHG requirements should be met by the most cost effective means

4. Trading policies and programs should recognize the global nature of greenhouse gases and encourage cooperation among regions and nations

5. Projects filling the requirements of Principle #1 should get credit for GHG emissions avoided, reduced or sequestered regardless of project costs

6. Banking, without discounting future value, should be allowed

Successful implementation of GHG reductions trading system based on the above principles will:

· Produce the most cost effective reductions

· Have the support of a broad and diverse stakeholder constituency

· Establish Massachusetts as a U.S. leader in the banking and trading of GHG emission credits, and potentially provide the state with significant economic benefits

Encourage other states and nations to join Massachusetts in taking concrete step to address climate change

1 Formed in 1992, the United Nations Framework Convention on Climate Change (UNFCCC) sets an "ultimate objective" of stabilizing atmospheric concentrations of greenhouse gases at safe levels. Such levels, which the Convention does not quantify, should allow ecosystems to adapt naturally to climate change, ensure that food production is not threatened and enable economic development to proceed in a sustainable manner. To achieve this objective, all member countries have a general commitment to address climate change, adapt to its effects, and report on the action they are taking to implement the Convention.

Summary of CO2 caps in MA and NH

Massachusetts

The regulation is 310 CMR 7.29 “Emissions Standards for Power Plants”

Announced by Gov. Jane Swift on 23 April 2001

Affected facilities: several characteristics basically define 6 facilities. Massachusetts is a deregulated market.

NOx

- on 1 October, 2004 1.5 lbs/MWh calculated over any consecutive 12 month period, recalculated monthly

- on 1 October, 2006 3.0 lbs/MWh calculated over any individual month

- no credit trading option exists

SO2

- on 1 October, 2004 6.0 lbs/MWh calculated over any consecutive 12 month period, recalculated monthly

- on 1 October, 2006 3.0 lbs/MWh calculated over any consecutive 12 month period, recalculated monthly AND shall not exceed 6.0 lbs/MWh over any individual month

- early reductions at the affected facility can be banked for use later with out penalty or discounting

- SO2 allowances can be purchased from the market and can be applied in a discounting ratio of 3 allowances for every ton emitted over the cap; this is above and beyond credits used to meet the Federal caps

Mercury (Hg)

- 1 Dec, 2002 DEP will complete evaluation of the technological and economic feasibility of controlling Hg in accordance with the NEG/ECP plan

- within 6 months of that, the DEP will propose standards for a compliance date of 1 October, 2006

CO2

- emissions for the year 2004 and 2005 must not exceed historical actual emissions

- emissions for 2006 and every year thereafter must not exceed 1800lbs/MWh average (=total CO2 emitted for the year/total MWh generated in that year)

- CO2 emissions caps can be met with offsite reductions or sequestration

If an affected facility chooses to meet any part of this regulation by adding controls or repowering one or more units at the facility and submits an application to do so by 1 January 2003, dates for meeting all requirements at all units at the facility move back two years (2004 to 2006, 2006 to 2008).

There are spaces reserved for possible future carbon monoxide (CO) and particulate mater (PM) regulations. Finally, there is also an annual reporting requirement for all of the above.

New Hampshire

Legislation HB 284 (Clean Power Act), was signed into law by Gov. Jeanne Shaheen on 9 May 2002.

Affected facilities: those “grandfathered” by the Clean Air Act, Merrimack Units 1 &2, Schiller Units 4, 5 & 6, and Newington Unit 1. All of these units are owned and operated by PSNH. Costs of compliance can be recovered through regulated rates.

SO2

- beginning 31 December 2006, total SO2 emissions from affected sources must not exceed 7,289 tons annually (75% less than current levels)

NOx

- beginning 31 December 2006, total NOx emissions from affected sources must not exceed 3,644 tons annually (70% less than current levels)

Mercury (Hg)

- a Hg cap will be suggested after the US EPA sets a national regulation but not after 31 March 2004. Compliance still appears to be 31 December 2006.

CO2

- from 31 December 2006 thru 31 December 2010, total CO2 emissions from affected sources must not exceed 5,425,866 tons annually. After this, a lower cap will be used to be suggested by 31 March 2004.

Allowances will be given out up to the cap. Additional allowances can be bought on national markets to meet the requirements.

For each 0.80 SO2 allowance purchased from upwind sources, the state will grant an additional 0.20 allowance. SO2 allowances doled out by the state will not exceed 20,000 each year.

NOx allowances cannot be bought for emission between 1 May and 30 September.

Early reductions of CO2 may be banked for future use in regional or national trading programs or to meet this emission cap.

Money spent on energy efficiency, new renewable energy, or conservation and load management projects, will receive emission allowances worth (on the market) the amount of the investment in such projects.

In the future, purchased Hg credits can only be used for the portion of this rule more stringent then federal requirements.

Various fines will be imposed on violators, including “not more than $25,000” per violation per day.

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