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News & Events
EPA Publishes Proposed Combustion Standards, Announces Public Hearings, and Extends Comment Period (June 9, 2010) The proposed combustion standards and solid waste definition rules were published in the Federal Register on Friday, June 4, 2010: Definition of Solid Waste: http://edocket.access.gpo.gov/2010/pdf/2010-10837.pdf Boiler MACT: http://edocket.access.gpo.gov/2010/pdf/2010-10827.pdf Boiler Area Source NESHAP: http://edocket.access.gpo.gov/2010/pdf/2010-10832.pdf CISWI NSPS: http://edocket.access.gpo.gov/2010/pdf/2010-10821.pdf Also, EPA announced public hearings for June 15 and 22 and extended the public comment period to August 3, 2010. FR Notice: http://edocket.access.gpo.gov/2010/pdf/2010-13877.pdf More information on the proposed standards is provided in the article below. EPS Contact: Tommy Sweat, P.E. (tsweat@envplanning.com, 404-315-9113).
EPA Proposes New Combustion Emissions Standards and Finalizes GHG Tailoring Rule (May 13, 2010)
EPA has issued proposed and final regulations that will impact many industrial facilities – specifically those with boilers and process heaters and high GHG emissions. On April 29, 2010, a set of rules related to boilers and process heaters were proposed: Industrial, Commercial, and Institutional Boilers and Process Heaters NESHAP for Major Sources (“Boiler MACT”) Industrial, Commercial, and Institutional Boilers and Process Heaters NESHAP for Area Sources (“Boiler Area Source NESHAP”) Identification of Non-Hazardous Secondary Materials That Are Solid Wastes (“Definition of Solid Waste Rule”) Amendments to New Source Performance Standards and Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units (“CISWI NSPS”) The pre-publication versions of each rule are available here: http://www.epa.gov/airquality/combustion/ Boiler MACT EPA issued these proposed rules under a court order to address the June 8, 2007 vacatur of the previous Boiler MACT and CISWI Definitions Rule. Upon publication in the Federal Register, EPA will accept comments on the proposed rules for 45 days after the publication date. EPA is working to meet a court ordered deadline of December 16, 2010 to issue the final rules. Emissions limits for PM, HCl, Mercury, CO, and Dioxin/Furans are proposed for major HAP sources that operate boilers and process heaters with heat input capacity of 10 MMBtu/hr or greater, except natural gas/ refinery gas-fueled boilers. The proposed emissions limits are significantly lower than the previous Boiler MACT. Certain subcategories of boilers are subject to annual or biennial tune-ups to reduce CO emissions. Larger boilers would be required to install CEMS for CO and PM, and boilers subject to opacity standards would be required to install COMS. Sources demonstrating compliance through stack testing would be required to conduct initial and annual tests, until 3 consecutive years of low emissions are observed, when the frequency may be reduced. All major source facilities with boilers would be required to conduct an initial energy assessment, including energy consumption information, identification of energy conservation and efficiency improvement measures, and establishment of a facility energy management program. Existing facilities would be required to comply within 3 years of the final rule being published in the Federal Register. Boiler Area Source NESHAP
EPA proposed the Boiler Area Source NESHAP to regulate boilers located at minor (area) sources of HAP. Gas-fired boilers are specifically exempted from the rule. Boilers burning coal, oil, or biomass are subject to emissions standards. Emission limits for PM, CO, and Mercury are proposed. Similar to the Boiler MACT, initial and annual stack tests are required. CO CEMS would be required for larger boilers. Boilers subject to opacity standards would be required to install COMS. An initial energy assessment would be required at all facilities with coal, oil, or biomass boilers with heat input capacity greater than 10 MMBtu/hr. Coal, oil, or biomass boilers with heat input capacity of less than 10 MMBtu/hr must be tuned up biennially to minimize CO emissions. Existing facilities would be required to comply within 3 years of the final rule being published in the Federal Register. Definition of Solid Waste EPA is proposing a new rule under 40 CFR 241 to define solid wastes which may be used as fuels or as ingredients (combustion aids) in combustion units. In the proposed rule, EPA states that the following non-hazardous secondary materials are not wastes:
(1) Non-hazardous secondary materials used as a fuel in a combustion unit that remains within the control of the generator and that meets the legitimacy criteria.
(2) Non-hazardous secondary materials used as an ingredient in a combustion unit and that meets the legitimacy criteria.
(3) Fuel or ingredient products that have undergone processing from discarded non-hazardous secondary materials and that are used as fuels or ingredients in a combustion unit, and that meet the legitimacycriteria.
In the Boiler MACT and Area Source NESHAP, the definition of boiler excludes devices that combust solid waste. Therefore, if any solid waste is burned in the boiler or process heater, the CISWI NSPS (discussed below) will apply. The Definition of Solid Waste will be critical for facilities with boilers that burn wood biomass or other secondary non-hazardous materials. EPA has included a mechanism to obtain non-waste determinations in the proposed rule. CISWI NSPS and Emissions Guidelines The CISWI NSPS and Emissions Guidelines apply to new and existing energy recovery units (boilers) and other incinerators that burn non-hazardous solid waste (non-fuels). This rule applies regardless of HAP emission level. Therefore, the CISWI NSPS applies to both major and minor (area) sources of HAP. Many of the proposed CISWI NSPS emissions limits are significantly more stringent than the proposed Boiler MACT limits. GHG Tailoring Rule On May 13, 2010, EPA issued the final GHG PSD/Title V Tailoring Rule, specifying which facilities must undergo PSD review for GHG emissions, which facilities must obtain Title V permits due to their GHG emissions, and which facilities must address GHG emissions in their existing Title V permits. A pre-publication version of the final rule and EPA fact sheet are available here: http://www.epa.gov/nsr/actions.html#may10. In the final rule, EPA established a multi-step process for addressing GHG emissions in construction and operating permits: Phase
| PSD Permitting
| Title V Permitting
| Step 1 (January 2011 – June 2011)
| For sources subject to PSD due to non-GHG emissions (“anyway” sources), a PSD review (with BACT) for GHG emissions is required at a level of 75,000 tons/yr CO2e (potential to emit).
| For sources subject to Title V permitting due to non-GHG emissions (“anyway” sources), GHG emissions must be addressed in Title V permit applications and applicable GHG requirements must be included in Title V permits when amended or renewed.
| Step 2 (July 2011 – June 2013)
| The same conditions from Step 1 apply. In addition, new sources with potential to emit of 100,000 tons/yr CO2e and modifications resulting in potential emissions increases of 75,000 tons/yr CO2e or more at major sources are subject to PSD review (with BACT) for GHG emissions.
| The same conditions from Step 1 apply. In addition, sources with potential GHG emissions of 100,000 tons/yr CO2e would be required to obtain a Title V permit, if they do not already have one. Applicable GHG requirements (if any) must be incorporated into the Title V permit.
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Beyond these two steps, EPA is planning a Step 3 (July 2013 and beyond) in which lower major source or modification thresholds may be established. By July 1, 2012, EPA will issue a final rule establishing the thresholds for Step 3. Smaller sources will be given a 6-year exclusion from PSD and Title V permitting. Public Comment Upon publication of the proposed rules in the Federal Register, facilities will have 45 days to submit comments to EPA.
EPS Becomes Champion for the Partnership for a Sustainable Georgia
March 5, 2008
 EPS is proud to be a Champion for the Partnership for a Sustainable Georgia. We have made a commitment to help the Pollution Prevention Assistance Division (P2AD) of the Georgia Department of Natural Resources encourage participation in this voluntary Partnership, which helps companies find ways to cut costs, reduce waste streams, increase energy and water efficiency, and improve operations through environmental excellence. For more information about the Partnership for a Sustainable Georgia, visit www.p2ad.org.
Mandatory GHG Reporting - On the Horizon
February 27, 2008
In the Fiscal Year 2008 omnibus spending bill signed by President Bush on December 26, 2007 (H.R. 2764), the following requirement was included:
"Of the funds provided in the Environmental Programs and Management account, not less than $3,500,000 shall be provided for activities to develop and publish a draft rule not later than 9 months after the date of enactment of this Act, and a final rule not later than 18 months after the date of enactment of this Act, to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in all sectors of the economy of the United States."
With this statement, EPA has been charged with developing a mandatory U.S. greenhouse gas reporting system. The statement appears to give EPA discretion on the appropriate reporting thresholds and sources to include. The proposed rule is expected to be issued by September 2008, with a final rule being issued by May 2009.
The Climate Registry - Voluntary Reporting Available by Summer 2008
Some expect that EPA may use The Climate Registry (www.theclimateregistry.org) as the reporting system or at least use this organization's reporting protocols for the mandatory reporting requirement. The Climate Registry is being developed by several states, Canadian provinces, and tribes to provide a common GHG reporting system. The final reporting and verification protocols for The Climate Registry will be released by April 2008, and entities (companies, organizations) will be able to report emissions to Climate Registry Information System (CRIS) beginning on June 30, 2008. Companies that sign a statement of intent to report by May 1, 2008 will be recognized as Founding Reporters.
Senators Introduce Expanded Climate Change Information
News Departments > Policy Watch
Friday 19 October 2007
Sens. Joseph Lieberman, I-Conn., and John Warner R-Va., have introduced climate change legislation proposing mandatory greenhouse gas reductions.
The latest refinements to the Lieberman-Warner bill outline a cap-and-trade strategy to reduce emissions from covered sectors by 15% by 2020 and 70% by 2050. In addition, the bill has incorporated components of several other bills and proposals, including agricultural sequestration of carbon, improved building codes, and carbon capture and storage. Additional policies such as automobile efficiency, renewable energy standards and energy efficiency, currently passed by the House and Senate in the energy bill, may also complement a cap-and-trade program.
Adapting to Certainty in Age of Uncertainty
Geneva (Source: World Business Council for Sustainable Development -www.wbcsd.org)16 October 2007
Our members accept that they must work with governments and NGOs to limit climate change and its impacts. But UN and other reports suggest that the climate is already warming. Given the long life of greenhouse gases in the atmosphere, it will continue to do so for some time.
Climate change effects will alter existing business models and change current risk structures. Inaction is and will not be an option considering that the benefits of adaptation will outweigh its costs.
The current discussions on adaptation are fuzzy and there is a real need to raise awareness and highlight present and future challenges. Adaptation describes a set of responses to the actual and potential impacts of climate change to reduce the harm or take advantage of the opportunities that climate change may bring.
Business also must show leadership on the issue by examining the short-term and medium-term risk factors worldwide. Business must develop a business case that shows how companies can benefit from adapting to climate change by addressing evolving risk structures, ensuring that (a) sufficient quantities of needed resources such as water and energy are available for their operations in the future, and (b) by reducing losses that will be caused by climate change.
Several recent reports detail the impacts of climate change. For instance, the Intergovernmental Panel on Climate Change reported that 11 out of the last 12 years were the warmest since records started in 1850; mountain glaciers and snow cover are declining; sea levels have risen by 3.1 mm per year (1993-2003); polar regions are significantly warmer – sea levels could rise by 4 to 6 meters.
These impacts create immediate physical risks for business, including extreme events such as floods, cyclones windstorms, heat waves, wildfires and droughts, with the largest impacts on infrastructure, insurance costs, and business interruption. Background climate challenges include changes in sea levels causing coastal flood/inundation risk, changes in snow lines, soil moisture and mean temperatures, with the largest impact on agriculture, real estate, tourism and human health.
Climate change can sound almost gentle when spoken of in fractions of a degree of temperature rise or parts of millimeters of sea level rise. But greenhouse gas (GHG) emissions are essentially putting more energy into the atmosphere, and no one can predict the knock-on effects and feedback loops this new energy may cause. The Stern Review calculated that the costs from climate impacts will be equivalent to losing 5% of global GDP each year, minimum. A small rise in the intensity of major storms could double the damage costs to infrastructure, resulting in total losses of US$ 100-150 billion in the US alone. Climate change could also affect global financial markets if only because the world’s major financial centers are located in coastal areas; simultaneous impacts on the economy could overwhelm and destabilize markets and insurance premiums will rise, affecting bank lending practices, etc.
Quantitative assessments of the costs and benefits of adaptation are very limited. Nonetheless, evidence indicates that there are substantial gains to be had from integrating climate risk into decision-making. Spending on near-term projects can bring significant benefits at little cost, for example, altering water supply design, while longer-term investments can be more costly, for example, retrofitting existing infrastructure.
To date the focus has been on financing the cost of mitigation, but further attention is now being placed on covering the cost of adaptation, with a clear onus on the developed world – both governments and businesses – to contribute substantially to the cost of adaptation in developing countries. However, developed countries are still addressing adaptation on an individual basis, especially in relation to natural hazards.
Companies need to quantify risks and uncertainties from climate change and consider them holistically alongside changes in the regulatory and consumer environment. Then companies should develop and state an adaptation strategy to cope with and manage climate change impacts. Companies can also work to mitigate the causes of climate change (reduce emissions; invest in clean-tech solutions; develop climate changefriendly services/products) and then lead by example, educate on best practice, and encourage policy action. Finally, companies can gain competitive advantage by managing their reputation with shareholders, investors and customers.
Forests Join the Carbon Market
IPS, 6 October 2007 - With deforestation as the second leading source of climate-changing greenhouse gas emissions, experts are focusing the discussion on the viability of compensating countries for protecting their forests.
The proposal "Reduced Emissions from Deforestation" (RED) was not included in the Clean Development Mechanism (CDM) of the Kyoto Protocol on Climate Change. But now is being evaluated by scientists, companies and agencies in poor countries that have extensive forested areas.
The CDM allows governments and corporations of industrialised countries (required under the Protocol to cut greenhouse gas emissions) to meet part of their obligations by investing in "clean" projects in developing countries, by which they obtain certificates of emissions reductions -- at much lower cost than curbing emissions at home.
"Slowing emissions from deforestation would not stop climate change, but it could be an important part of a many-part strategy," Christopher Field, head of the global ecology department at the Carnegie Institution in Washington, said in an interview for this report.
RED emerged in 2005 at the 11th Conference of Parties to the United Nations Convention on Climate Change, led by Papua New Guinea and Costa Rica, with support from the Coalition for Rainforest Nations. Its aim is to include "avoided deforestation" in the global market of carbon credits -- carbon dioxide being the principal greenhouse gas.
Implementation is expected to be finalized at the 13 Conference of Parties, to take place in December on the Indonesian island of Bali.
Brazil, for its part, proposes a fund with voluntary contributions of public money to compensate the effort made by developing countries to reduce deforestation, and that they would be remunerated based on prevented emissions.
In the article "Tropical Forests and Climate Policy", published May 10 in "Science Express" online magazine, Field and other researchers propose to slow the current pace of deforestation 50 percent by the year 2050.
That would be the equivalent of 50 billion tonnes of carbon prevented from being released into the atmosphere, or equal to six years of emissions of gases from fossil fuel combustion, the experts say.
But that figure is meaningless, says to Almuth Ernsting, of the Britain-based Biofuelwatch campaign. Because RED does not intend to stop industrial-scale logging, "there is growing evidence that many rainforests, including the Amazon forest, will collapse well before the destruction of a further 50 percent."
The Amazon is the forest ecosystem with the most carbon: 305 tonnes per hectare, of which 28 percent is in the soil, according to a 1998 study.
Its destruction would release 120 billion tonnes of carbon by 2050, which would be catastrophic to the global climate, says Ernsting.
The transformation of natural ecosystems into farmland entails a loss of 75 percent of the carbon in tropical soils. That implies between 18 and 20 percent of the total emissions from deforestation, according to experts.
There is about twice as much carbon stored in forests and soils as exists in the atmosphere, said William Moomaw, director of the Centre for International Environment and Resource Policy, at Tufts University in the United States.
If one area is preserved, and another is deforested, how is this to be counted, asks Moomaw by way of example. Planting trees in other areas to compensate for logging does not work because it often is done in areas not apt for forests, he explained.
This problem has come up with tree plantations intended to absorb carbon, and could be repeated in a scheme for reducing emissions from deforestation, say critics.
The carbon market helped finance monoculture plantations, and had negative results for the soil, local communities, water resources and, ironically, carbon emissions, says Biofuelwatch's Ernsting.
There is also concern about the difficulties in controlling changes in the carbon stores of forests once the system is applied.
"Monitoring entails some costs, but existing satellite technologies make the challenge relatively straightforward," says Field, of the Carnegie Institution.
National measurement systems can function, according to Moomaw. In the international arena, the European Union, United States and Brazil would need to form a coordinated satellite monitoring team, available for countries with few resources but rich in forests.
Compensation for avoided deforestation should reduce net emissions, encouraging a change in international frameworks and adopting an emissions tariff for countries with little or no historic deforestation, according to the study "No Forest Left Behind", published by Conservation International in the Aug. 14 issue of the online journal Public Library of Science - Biology. Countries with much forest and relatively little deforestation are: Belize, Bhutan, Colombia, Democratic Republic of the Congo, French Guiana, Gabon, Guyana, Panama, Peru, Suriname and Zambia. Inhabited mostly by indigenous peoples, they would enter the carbon market through "preventive credits" or compensation that they would forfeit if there is an increase in loss of forest.
In order for the system to function equitably, it is important that local communities participate, according to experts.
"The principle of avoided deforestation is not a bad principle, however the means through which it could be realised are complex and fraught with unequal power relations," says Helen Leake, of the non-governmental Forest Peoples Programme. "The devil is in the details."
(*This story is part of a series of features on sustainable development by IPS-Inter Press Service and IFEJ-International Federation of Environmental Journalists.)
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