Options Diminishing for Obtaining Emission Reduction Credits in

California

Electric Utilities Environmental Conference

January 27 – 30, 2002 Tucson, Arizona

by

Joel Reisman and John LaneGreystone

Environmental Consultants, Inc.

Focus on PM10 ERCs

Background Potential Sources Road Paving ERC Process

Quantity and Cost of ERCs Needed

Typical 520 MW Combined-cycle, natural gas-fired power plant

Varies; 50 – 150 tpy PM10 Emissions PM10 ERCs cost $5,000 to $20,000 per

ton Offset ratio depending on distance from

source – 1.0 to 2.0 Total Cost: $250,000 to $6,000,000

ERC Eligibility

RealPermanentQuantifiableSurplusEnforceableTimely

PM10 Ambient Air Quality Standards (μg/m3)

Period NAAQS CAAQS

24-hr 150 50

Annual

(Arithmetic Mean)

50 ---

Annual

(Geometric Mean)

--- 30

Federal/California PM10 Nonattainment Areas

Potential Sources of PM10 ERCs

Shutdown/replace or install controls on combustion sources

Install controls on material handling sources of dust

Agricultural activities (e.g., burning) Install controls on mobile sources Take enforceable permit limits (e.g., hours) Upgrade woodstoves Pave unpaved roads

Unpaved Road Emission Factor

Eext = k(s/12)a (W/3)b [(365-p)/365] [lb/VMT]

(Mdry/0.2)c

(Assumes vehicle speed > 15 mph)

Source: AP-42 Section 13.2.2 Unpaved Roads

Paved Road Emission Factor

E = k(sL/2)0.65 x (W/3)1.5 [lb/VMT]

Source: AP-42 Section 13.2.1 Paved Roads

Data Needs

Traffic, VMT Silt Content, sMean vehicle weight, WDefaults available for:

Moisture Content, Mdry

p, k, a, b, c Silt Loading, sL

Traffic Data

Traffic counter data preferred

If seasonal, use other data to support traffic data:Number of employeesAmount of product shippedStore receipts

ERC Process

Meet with Agency Prepare/submit application Agency Review ERC certificate issued to road owner Road owner must agree to maintain road Transfer certificate to project (prior

agreement) Surrender certificate to Agency prior to

construction

Potential Stumbling Blocks

BACM, RACT requirements Some Districts have seasonal offsetting

requirements Negative comments from CARB, EPA,

or intervenors New concern – PM2.5

SUMMARY

Tougher to find Banked PM10 ERCs

High CostMust be CreativeMust be able to Substantiate Eligibility

and QuantitiesAgencies/Regulations Must be

Agreeable