Environmental Management and Compliance News, Tips and Tools

March 31, 2012

And so it begins…

image: power plant emissions

It’s what you can’t see that is causing all the fuss…

The US Environmental Protection Agency has formally proposed the first national limits on emissions of greenhouse gases, specifically carbon dioxide. The Carbon Pollution Standard, proposed on March 27, will apply to new fossil-fuel electric utility generating units (EGUs). Affected units include boilers, integrated gasification combined cycle (IGCC) units and combined cycle turbine units larger than 25 megawatts. “New” excludes existing units and permitted units that begin construction within the next 12 months. The standard also will not apply to new EGUs that do not burn fossil fuels (for example, facilities that use biomass as fuel).

The proposed standard limits carbon dioxide emissions to 1,000 pounds of carbon dioxide per megawatt-hour of power output. EPA believes that new natural gas fired power plants will be able to meet the standard without add-on emission controls, but coal or petroleum coke units would need to incorporate additional control technologies, such as carbon capture and storage. While the standard does not explicitly forbid the construction of new coal-fired plants, the prohibitive costs for these carbon control technologies will arguably result in a de facto ban on new coal-burning facilities.
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Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 2:11 pm

January 30, 2012

Global warming worries? Just, relax…

image: snowstorm

Perhaps we’ll be enjoying these scenes for a long time yet…

Are concerns over man-made global warming (i.e., anthropogenic global climate change) overblown? So says this January 27 opinion piece in the Wall Street Journal online, written by sixteen eminent physical scientists. They argue that predictive computer models have exaggerated the potential effects of continued emissions of carbon dioxide, and point to the documented halt (or pause, depending on your perspective) in rising global temperatures over the last decade or so as evidence supporting their position.

Not to be outdone, the UK Daily Mail waded into the global warming debate with two seemingly contradictory articles: First, theorizing that global cooling, not warming, may be a more immediate concern on the global temperature front, based on solar energy cycles – and then, on the same day, reporting that the British government’s national risk assessment on climate change warns that increasing temperatures will lead to “major increases in flooding, heatwaves and water shortages that could kill thousands of people a year.”

What should we make of the current state of anthropogenic climate change science?
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Filed under: Air Pollution,Climate Change,Greenhouse Gases — TCozzie @ 11:03 am

March 18, 2011

Not ready to report greenhouse gas emissions? No worries…

The Environmental Protection Agency has finalized its rule to extend the deadline for reporting 2010 emissions of greenhouse gases (GHGs) to September 30, 2011. (Reports had been due by the end of this month.)

Those facilities required to report their GHG emissions must first register with the EPA’s electronic greenhouse gas reporting tool (“e-GGRT”). Registration will now be due 60 days prior to the reporting deadline, or by August 1.

For information on the GHG reporting requirements, visit www.epa.gov/climatechange/emissions/ghgrulemaking.html. The e-GGRT reporting tool can be accessed at ghgreporting.epa.gov/ghg/login.do.  And come back to this site soon for upcoming posts on GHG rules.

Filed under: Air Pollution,Climate Change,Compliance,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 3:26 pm

August 9, 2010

Scoffing at skeptics…

On July 29, The U.S. Environmental Protection Agency (EPA) denied 10 petitions challenging its 2009 determination that

  • climate change is real,
  • it is occurring due to emissions of greenhouse gases from human activities, and
  • it threatens human health and the environment.

EPA’s decision rejected claims that climate science cannot be trusted and that collusion (dare we say, a “conspiracy”?) among members of leading research bodies to suppress conflicting data and hide errors or gaps in their own research invalidates the findings of the Intergovernmental Panel on Climate Change (IPCC), the U.S. National Academy of Sciences, and the U.S. Global Change Research Program. Having given “months of serious consideration” to the petitions and to the state of climate change science, EPA found no evidence to support these claims. In fact, EPA has determined that climate science is credible, compelling, and growing stronger!

EPA Administrator Lisa P. Jackson blamed the petitions on “defenders of the status quo [who] will try to slow our efforts to get America running on clean energy,” and called on petitioners “to join the vast majority of the American people who want to see more green jobs, more clean energy innovation and an end to the oil addiction that pollutes our planet and jeopardizes our national security.”

The basic assertions by the petitioners and EPA responses follow.
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Filed under: Air Pollution,Climate Change,Greenhouse Gases,USEPA — TCozzie @ 2:36 pm

May 13, 2010

Thresholds for greenhouse gas permitting announced

On May 13, the US Environmental Protection Agency (EPA) announced its final “GHG Tailoring” rule to address greenhouse gas (GHG) emissions from stationary sources. The phased-in approach will initially address large facilities like power plants and oil refineries that emit most of the greenhouse gases from stationary sources. The regulated GHGs include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.

(image of clouds)Starting in January 2011, Clean Air Act permitting requirements for GHGs will apply to large facilities that are already obtaining Clean Air Act permits for other pollutants. Those facilities will be required to include GHGs in their permit if they increase their GHG emissions by 75,000 tons per year (tpy). In July 2011, permitting requirements will expand to cover all new facilities with GHG emissions of at least 100,000 tpy and modifications at existing facilities that would increase GHG emissions by at least 75,000 tpy. The permits must demonstrate the use of best available control technologies to minimize GHG emission increases when facilities are constructed or significantly modified. EPA estimates approximately 900 additional permitting actions covering new sources and modifications to existing sources would be subject to review each year. In addition, 550 sources will need to obtain operating permits for the first time because of their GHG emissions.

Permitting requirements for smaller sources will await the findings of a 5-year study of the effects of GHG permitting of these sources, slated for completion in 2015.

According to the EPA press release announcing the final rule, the agency received about 450,000 (!) comments within the 60-day public comment period that followed issuance of the proposed rule in October 2009.

More information on the GHG Tailoring Rule and its implementation schedule can be found at http://www.epa.gov/nsr/actions.html.

What do you think? Has EPA struck the proper balance between regulating a significant threat to health and the environment and providing relief to small businesses and farms?

Filed under: Air Pollution,Compliance,Greenhouse Gases,Permits,USEPA — TCozzie @ 5:01 pm

April 20, 2010

EPA proposes expansion of mandatory greenhouse gases reporting requirements

In three four (!) separate notices published in the April 12 Federal Register, the US Environmental Protection Agency has proposed to expand the information required under the Mandatory Reporting of Greenhouse Gases Rule.  The additional information to be required includes…

  • reporting of emissions of fluorinated greenhouse gases (GHGs) from certain sources, such as electronics manufacturing, production of fluorinated gases, and use of electrical transmission and distribution equipment, as well as manufacture or refurbishment of electrical equipment;
  • reporting on carbon dioxide (CO2) injection and geologic sequestration;
  • emissions reporting from the following industry segments:  petroleum and natural gas production, natural gas processing, natural gas transmission compressor stations, underground natural gas storage, liquefied natural gas (LNG) storage, LNG import and export terminals and distribution; and
  • for reporters subject to the rule to provide:  the name, address, and ownership status of their US parent company; their primary and all other applicable North American Industry Classification System (NAICS) codes; and an indication of whether or not any of their reported emissions are from a cogeneration unit.

For more information on the proposed rules and how to comment, visit the EPA’s GHG reporting web page.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Reporting,Rules and Regulations,USEPA — TCozzie @ 5:50 pm

March 29, 2010

EPA formally announces greenhouse gas permitting schedule

The US Environmental Protection Agency (EPA) has announced  that Clean Air Act permits for stationary sources of greenhouse gases (GHGs) will not be required before January 2011 – or, to put it another way, EPA has put the largest sources of greenhouse gas emissions on notice that permitting will commence in January 2011.

Clean Air Act construction and operating permit requirements for the facilities emitting the largest quantities of GHGs will begin when the first national GHG control rule takes effect.  EPA’s target date for implementation of a rule regulating GHG emissions from cars and light trucks is January 2011, when model year 2012 vehicles meeting the standards can first be sold in the United States.  Final greenhouse gas emissions standards for vehicles are pending. image: air emissions stacks at industrial facility

At this point, potentially regulated sources are still waiting for EPA to formally reveal the threshold quantities of GHG emissions that will trigger the requirement for permit limitations on these emissions.

What do you think – too soon?  Can we expect that regulators and regulated industries will be able to identify, engineer and implement effective control technologies and procedures in timely fashion?  And how will the costs affect not only the permitted industries but also chances for an economic recovery?

More information on the EPA approach and its intended timeline can be found at www.epa.gov/nsr/guidance.html.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Permits,Rules and Regulations — TCozzie @ 9:09 pm

February 23, 2010

EPA Administrator offers timetable for regulating greenhouse gas emissions

In a February 22 letter to members of the US Senate, EPA Administrator Lisa Jackson has proposed a rough schedule for phasing in of regulatory control of greenhouse gas emissions from stationary sources.

Ms. Jackson’s letter (which can be read in its entirety here) anticipates that permit requirements for control of greenhouse gas emissions from large stationary sources will appear in 2011, requiring first those facilities already subject to permitting as major sources of priority or hazardous air pollutants to address greenhouse gas emissions in their permit applications.  Other “large” sources (i.e., those emitting more than 25,000 tons of carbon dioxide and other greenhouse gases per year) will follow, though the Administrator expressed an expectation that the threshold for permitting through 2013 will be substantially higher than the original 25,000 ton level.  Permitting for smaller sources is not anticipated prior to the year 2016, according to Administrator Jackson.

We’ll offer an interpretation of other points raised or answered in Ms. Jackson’s letter in a later post.

Filed under: Air Pollution,Greenhouse Gases,Rules and Regulations,USEPA — TCozzie @ 3:46 pm

January 18, 2010

Update: Greenhouse Gases and Global Warming

In the aftermath of a brutal cold wave that swept across the US (yes, even to our normally balmy South Florida), we take note of a flurry of interesting news stories concerning global climate change and the likelihood of immediate regulatory action to combat greenhouse gas emissions.  Here is a sampling…

From the Wall Street Journal, various states are pressing the US Environmental Protection Agency (EPA) to delay rulemaking intended to curb emissions of greenhouse gases, fearing that their permitting and regulatory capabilities (and budgets) will be overwhelmed. See online.wsj.com/article/SB126317107565923971.html.

From the Times UK, an allegation that the UN Intergovernmental Panel on Climate Change (IPCC) used very weak science – or more precisely, mere speculation – in forecasting the imminent disappearance of major Himalayan glaciers.  See www.timesonline.co.uk/tol/news/environment/article6991177.ece.

And a recent monograph published in the journal Geophysical Letters Review, www.agu.org/pubs/crossref/2009/2009GL040613.shtml, questions whether any statistically significant rise in the airborne fraction of anthropogenetic carbon dioxide (CO2) emissions has occurred in the past 150 years.
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Filed under: Air Pollution,Greenhouse Gases — TCozzie @ 3:24 pm

December 18, 2009

Conclusion: Greenhouse gases threaten human health and the environment

Or perhaps more precisely, a foregone conclusion?

As announced on December 7 (UPDATE: and published on December 15 in the Federal Register), the US Environmental Protection Agency administrator has signed two findings on greenhouse gases under the Clean Air Act:

  • Endangerment: That current and projected concentrations of the six key greenhouse gases – carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) – in the atmosphere threaten the public health and welfare of current and future generations; and
  • Cause or Contribute: That the combined emissions of these well-mixed greenhouse gases from new motor vehicles and new motor vehicle engines contribute to the greenhouse gas pollution which threatens public health and welfare.

These determinations are prerequisite for EPA to finalize its greenhouse gas emissions limitations for light-duty vehicles, including passenger automobiles, proposed in September.

Unless you have not been paying attention to the news on climate change issues, you might also know that the endangerment finding also paves the way for regulatory control of greenhouse gas emissions from stationary sources. In lieu of the uncertain “cap and trade” legislation, EPA can begin to regulate GHGs through the administrative rulemaking process, and has signalled its intent to apply regulatory controls to power plants and other large emitters of GHGs, as noted here on October 13.

For more information on regulatory implications of greenhouse gases and climate change, visit our web page at www.tcozzie.com/greenhouse_gases.htm.

Filed under: Air Pollution,Greenhouse Gases,Rules and Regulations — admin @ 3:55 pm
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