PT AirWatchers’ comments on WA 2016 CO2 Reporting Rule

” gains made just on paper will be more destructive to protecting the atmosphere than doing nothing in that it will only serve to hide the lack of action and sources of the problem.

” CO2e emission reductions are sorely needed, and needed quickly. … the [potential] benefit [of this plan] is rendered almost to nil not only by legislative exemptions and considerations like those for so-called “biogenic” fuels and the EITE considerations, but also by rolling facilities in later in the program or for smaller facilities, not at all. “

” By the end of the program, Port Townsend Paper Corporation will only be responsible for a miniscule amount of reduction in CO2 (which could likely be met through trivial measures).

” Even in the best case scenario (without exemptions and enrolling in the first year), by the end of the program, they would still be emitting more than FOUR times the top tier threshold, in actual measurable CO2e emissions. ”

 

From PT AirWatchers, PO Box 1653, Port Townsend WA 98368

Date 2016 July 22

Re Ecology’s Proposed CO2 Reduction Plan

 

To WA Department of Ecology and whom it may concern:

 

Following are my and PT AirWatchers’ comments on Ecology’s proposed Carbon Dioxide Emissions Reduction Plan, comment period for which closes at midnight, 2016 July 22.

 

I thank you for taking the time to develop a program to reduce carbon dioxide emissions, and for the opportunity for the public to guide the process.

 

First, an already recorded comment, about the process:

Ecology held two recent in-person public hearings and two onine webinars, all much appreciated. The choice of online platform had enough technical issues to exclude much of the public: it needed fairly recent operating systems, newer than many of us have, and even once on, we could discern that others attending the webinar were also experiencing difficulties that precluded asking questions or giving testimony.

 

Challenges such as that unjustly serve to exclude the public and should be remedied to ensure that the widest amount of the public can actively participate.

 

Now, onto content-related comments.

CO2e emission reductions are sorely needed, and needed quickly. If not for all of the exemptions, this plan would be a start toward those reductions. In any case, I would recommend steps such as:

– Increase the percentage reduction. Without the exemptions and being enrolled into the program at the start might reduce one facility’s emissions by 10% over the span of the program. However, the benefit is rendered almost to nil not only by legislative exemptions and considerations like those for so-called “biogenic” fuels and the EITE considerations, but also by rolling facilities in later in the program or for smaller facilities, not at all.

To make up for that, the percentage should be raised; ways to compensate for reductions lost due to the biogenic exclusions should be found; ways to impel CO2e reductions by smaller facilities should be implemented whether in this program or another.

(The falsehood of arguments for excluding so-called “biogenic” CO2e emissions is well established in science and won’t be argued here. If needed, I and others will provide supporting documentation.)

– Unfortunately between exemptions, cap-and-trade and other alternatives to reduce the reduction commitments, it is hard to fathom that much actual reduction in CO2 emissions will occur. I will welcome being proven wrong on this point, but that’s how it appears. Please realign the program to make much larger real-world reductions happen locally to the facility.

 

A CASE EXAMPLE SHOWING WHERE THE PROGRAM BREAKS DOWN

I did rough calculations on the effect of the proposed plan on emissions from one of WA State’s largest CO2e emitters, the Port Townsend Paper Corporation.

 

They are given exemption after exemption until these reduction targets are meaningless. I recommend that a similar analysis be done on all other facilities in WA, using the actual (“biogenic” plus “non-biogenic”) CO2e emissions.

 

I am not necessarily blaming Ecology for exemptions that are currently out of their control. I would ask Ecology to work to overturn those exemptions (biogenic emissions and EITE specifically), and meanwhile to find ways to make their good efforts to protect our environment pay off with significant real-world environmental benefits.

 

I recognize that Ecology is somewhat limited in how they can address so-called “biogenic” CO2e emissions since exemptions for these have been worked throughout the statutory system by powerful industry interests.

 

However, if the plan is not evaluated for how it plays out with ALL real, actual, measurable CO2e emissions counted, then the plan bears little relationship with reality. If “biogenic” emissions are not included in the overall analysis, then any positive reductions in CO2e will be minimal compared to actual measurable CO2e emissions to the point of possibly rendering the program relatively meaningless.

 

I, along with PT AirWatchers members and supporters, want to encourage a reduction plan, but one that is strong and will make significant reductions in the actual amounts of CO2e emitted, that gains made just on paper will be more destructive to protecting the atmosphere than doing nothing in that it will only serve to hide the lack of action and sources of the problem.

 

That said, here is my rough analysis of how the plan plays out with respect to Port Townsend Paper Corp.

 

PTPC emits approximately 600,000 MT CO2e/year – actually, really, measurably.

This is around SIX times the top tier threshold.

  • They are “allowed” by statute to exempt 90% of that or 500,000 MT/yr due to fake accounting provided through biogenic CO2e exemptions for a paper result of 60,000 MT/yr.

This paper magic puts them in the bottom tier of the 24 major polluters and thus exempts them from enrolling in the program until year 2032.

 

  • Further, considerations given to them due to the EITE designation will allow them to continue emitting unabated at least through year 2032.

 

The tables below show the resulting reductions for PTPC only taking into account reductions due to the discredited biogenic exclusions.

 

  • The result: By the end of the program, PTPC will only be responsible for a miniscule amount of reduction in CO2 (which could likely be met through trivial measures).
  • Even in the best case scenario, by the end of the program, they would still be emitting more than FOUR times the top tier threshold, in actual measurable CO2e emissions.

 

(continued next page)

 

 

Table 1.

Original Annual Emissions Pct annual reduction
600,000 MTCO2e/yr 1.70% running total
Year reduction for that year allowable emissions avoided co2
enrolled in> 2017 0 600,000 0
2018 10,200 589,800 10,200
2019 10,027 579,773 30,427
2020 9,856 569,917 60,509
2021 9,689 560,229 100,281
2022 9,524 550,705 149,576
2023 9,362 541,343 208,233
2024 9,203 532,140 276,093
2025 9,046 523,094 353,000
2026 8,893 514,201 438,799
2027 8,741 505,460 533,339
2028 8,593 496,867 636,472
2029 8,447 488,420 748,052
2030 8,303 480,117 867,935
2031 8,162 471,955 995,980
2032 8,023 463,932 1,132,049
2033 7,887 456,045 1,276,004
2034 7,753 448,292 1,427,712
2035 7,621 440,671 1,435,333 <=Grand total avoided CO2e emissions
9,812,959 <=Grand total CO2e emitted
during program years

 

 

 

 

 

Table 2. Conclusion. Comparing Tables 1 and 3.

Above= if ALL actual CO2e is counted and PTPC enrolls at beginning
Conclusion:
MT CO2e from PTPC over span of program: Emitted: Avoided:
as proposed in plan 11.4 Million 4 thousand
including all CO2 and starting in 2017 as they should 9.8 Million 1.4 Million
Below=as in plan, counting only “non-biogenic” CO2e and PTPC enrolls in 2032

 

Table 3.

 

Below=as in plan, counting only “non-biogenic” CO2e and PTPC enrolls in 2032
Annual Emissions-actual> 600,000
Exempting “biogenic” Pct annual reduction
60,000 MTCO2e/yr 1.70%
Year reduction for that year allowable “non-biogenic” total actual emissions running total avoided co2
2017 0 60,000 600,000 0
2018 0 60,000 600,000 0
2019 0 60,000 600,000 0
2020 0 60,000 600,000 0
2021 0 60,000 600,000 0
2022 0 60,000 600,000 0
2023 0 60,000 600,000 0
2024 0 60,000 600,000 0
2025 0 60,000 600,000 0
2026 0 60,000 600,000 0
2027 0 60,000 600,000 0
2028 0 60,000 600,000 0
2029 0 60,000 600,000 0
2030 0 60,000 600,000 0
2031 0 60,000 600,000 0
enrolled in> 2032 0 60,000 600,000 0
2033 1,020 58,980 598,980 1,020
2034 1,003 57,977 598,997 3,043
2035 986 56,992 599,014 4,028 <=Grand total avoided CO2e emissions
1,133,949 <=total “non-biogenic” CO2e emissions
11,396,992 <=Grand total CO2e emitted
during program years

 

 

 

  • PTPC will not have to actually make even those paltry reductions because they will be allowed to offset them via a range of reductions:

– “good works” (which is how they’ve played for decades), buying and selling ERUs which means any possible reductions will be elsewhere.

– In their biomass power generation plan a few years ago, the parent of their parent company was setting up a structure whereby one arm would create ERUs and PTPC would feed benefits back to the parent of the parent. I can see similar happening and it should be guarded against.

 

Imminent projects by PTPC

  • Imminent reductions at PTPC due to a proposed replacement of one of their aging boilers with a modern efficient CNG while efficient, will only decrease the overall CO2 emissions by about 1%. That should not count toward their already paltry program requirements. (Not arguing other considerations of the change, pitting merits of much needed newer efficient equipment versus support of the fracking industry. CO2 only in this discussion.)

 

THEREFORE

Ecology should go back, take into account the extremely low measures that are being asked of facilities such as PTPC and re-engineer this program to require REAL, SIGNIFICANT REDUCTIONS in their ACTUAL CO2E EMISSIONS.

 

 

Cap-and-Trade, ERUs

See comment above about how PTPC earlier was aiming to game the trade in energy credits. This is a hazard of these schemes and seriously weakens any reduction program.

  • If ERUs and similar trading/credits are allowed,

-they should be limited to a very small percentage of the facility’s reduction quota

-they should be required to afford measurable reductions in the real world within a certain geographical distance of the facility.

– the rule has conflicting language about when operations slow-downs do or don’t create “banking” possibilities. As formulated it would seem to grant PTPC (for instance) opportunities to bank credits for seasonal or strategic operations slow-downs or simply times of slow business. That should be guarded against in the plan.

-there should be sanctions for playing the system.

 

In other areas

CO2 emissions by military operations

In recent years, the military has dramatically increased its activities throughout WA State, including numerous training exercises and flights of newer much larger aircraft. These emit significant amounts of CO2e into the atmosphere (along with other environmental impacts that should be mitigated).

 

Ecology should develop a plan to limit and require reductions in CO2 emissions.

My understanding so far is that:

– Fed law covers the military. Largely, although it seems that Ecology should have some avenues of jurisdiction to protect our WA State environment.

– It’s tough to include “end users” like cars and trucks because Ecy only has jurisdiction over emissions if the individual end user would trigger the treshold and/or the user operates wholly within WA State.

– Which is why they are focusing on producers of CO2e emitting substances, like jet fuel, to make reductions there. (This is another situation where misguided application of “biogenic” exclusions will render reduction targets toothless, so should not be allowed.)

– there might be room to require reductions at the user level if the user operates wholly [or mostly] within WA State. The military conducts these exercises and all of its operations as an entity and these operations take place almost wholly within the state.

 

Therefore, while individual end-user  levels might be below the threshold for inclusion in this plan, aggregated emissions by sources such as these collective military operations, should merit strong CO2e reduction goals.

 

Ecology should do the calculations on the aggregated CO2e impact of the military’s upsurging exercises, and require reductions of them. Significant reductions, too, without the exemptions and trading that is proposed.

 

Again, I appreciate Ecology’s goals of reducing CO2e emissions. I thank those I’ve spoken with now and over the years for fruitful conversations and their willingness to assist the public in meaningful engagement with the agency and the process.

 

My hope is that real and critically needed strides in reducing CO2e emissions are made and that Ecology arrives quickly with a program soundly based in real-world science that makes those reductions a reality.

 

Thank you for your attention,

Gretchen Brewer

Director, PT AirWatchers

PO Box 1653, Port Townsend WA 98368

ptawdirector@mailhaven.com

 

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