Clean Air Branch Greenhouse Gas Rules Stakeholders Meeting 10182013 State GHG Requirements In 2007 Act 234 was enacted Act 234 required Statewide GHG limit set to 1990 levels To be achieved by 2020 ID: 270141
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Slide1
Response to Comments on HAR Amendments
Clean Air Branch
Greenhouse Gas Rules Stakeholders Meeting10/18/2013 Slide2
State GHG Requirements
In 2007, Act 234 was enacted.Act 234 required:
Statewide GHG limit set to 1990 levels. To be achieved by 2020.DOH to adopt GHG rules to ensure GHG limit is met.
Background
Slide3
Federal GHG Requirements
In 2007, GHG emissions became regulated. In 2009,
Mandatory GHG Reporting Rules.In 2010, Tailoring Rule regulates GHG emissions under PSD and Title V. In 2013, President’s Climate Action Plan directs EPA to issue GHG rules for power plants.
Background
Slide4
Public Comment Period
Public hearings in November 2012. Comment period extended from 12/7/2012 to
1/14/2013. 18 testifiers submitted oral testimony at the hearings. 23 commenters submitted written comments .
Introduction
Slide5
Results of Comments R
eceived
GHG cap revised from 25% to 16%.Public participation for GHG reduction plan approvals. Deadline for GHG reduction plans extended to 12 months.Landfills with controls exempt from GHG cap.No retroactive GHG fees.Revised definition of “subject to regulation”
Introduction
Slide6
Comments Addressed
Scope of AuthorityLife Cycle AssessmentFacility Wide GHG Cap
GHG Emissions Reduction PlanPartneringMWC & MSW Landfills exemptionGHG FeesBACT ThresholdDefinition of “Subject to Regulation”
Comments Addressed
Slide7
Scope of Authority
Two separate sources of authority:General powers under 342B-3, HRS and specific powers under 342b-12.
Subpart VI, 342B, HRS (Act 234).
Scope of Authority Slide8
Act 234 Hawaii’s Global Warming Solution Law (2007)
Sets a Statewide GHG Emissions Limit to
reduce GHG emissions from 2010 levels to 1990 levels by 2020.
Scope of Authority Slide9
Life Cycle Assessment (LCA)
DOH will not apply LCA at this time.Neither EPA nor any other state
nationwide applies LCA to stationary sources. DOH recognizes the merits of LCA.
LCA
Slide10
Facility-Wide GHG Emissions Cap
Cap changed from 25% to 16%.
Alternate cap based on GHG Control Assessment. Alternate Baseline Year.Facility-wide GHG Cap
Slide11
GHG Cap change from 25% to 16% (A)
Parameter
Initial 25% Percent ReductionRevised 16% Percent Reduction2010 affected facility actual emissionsQuestionable DOH emission estimates for 3 facilities Used GHGRP values instead of DOH estimates 2010 affected facility actual emissions Questionable GHGRP value reported for 4th facilityUsed EPA emission factors for 4th facilityState-wide 2010 emissionsBased on 2007 estimated emissionsBased on 2010 emissions projected2010 affected facility actual emissions from MWC operationsNoNo2010 affected facility actual emissions from MSW landfillsYesNo
Facility-wide GHG Cap
Slide12
Facility-wide GHG Cap
GHG Cap change from 25% to 16% (A)Slide13
Facility-wide GHG Cap
GHG Cap change from 25% to 16% (A)Slide14
Alternate Cap and GHG Control Assessment (B)
Facility must
conduct a GHG control assessment.Similar to BACT analysis. Director may approve an alternate cap.Cap will be incorporated into facility’s air permit.
Facility-wide GHG Cap
Slide15
Alternate GHG Cap Baseline Year (C)
2010 is the default baseline year.May propose an alternate baseline year
Methods to determine alternate baseline year are in HAR. Facility-wide GHG Cap Slide16
GHG Emission Reduction Plan
Director’s Discretion and Public Participation.
GHG Emission Reduction Plan Deadline.
GHG Emission Reduction Plan Slide17
Director’s Discretion and Public Participation (A)
Provisions for public participation are in HAR 11-60.1-205.Provisions for contested case hearings are in HAR 11-60.1-206.
GHG Emission Reduction Plan Slide18
GHG Emission Reduction Plan Deadline (B)
Extended deadline to 12 months from the effective date of the rules.
Provisions for extending the deadline.GHG Emission Reduction Plan Slide19
Proposed Control Strategy – Partnering
Partnering sources propose emissions above or below the facility-wide cap.
Each partner agrees to a revised emission level.Revised GHG emissions cap placed in permit.Each partner responsible for meeting its own cap.
Proposed Control Strategy - Partnering
Slide20
MWC & MSW Landfill Exemptions
MWC operations
MWC reduce waste going into landfills.GHGs from MWC have minor effect on reduction levels. MSW Landfills with controlsLandfill controls significantly reduce GHG emissions.GHG from landfills with controls have minor effect on reduction levels.
MWC Operations and MSW Landfills Slide21
BACT Applicability Threshold
State BACT threshold remains at 40,000 tpy CO2e.
State threshold is lower than 75,000 tpy CO2e federal threshold.Lower state threshold will regulate emission growth from new sources.BACT Applicability Threshold
Slide22
GHG Fees
Draft rules were amended to charge fees only after rules adoption.
Fees for GHG starts in 2015.GHG Fees Slide23
Definition of “Subject to Regulation”
Consistent with federal definition Temporary exemption of biogenic
CO2 emissions removed.
Definition
of Subject to Regulation Slide24
Where is Project Now?
GHG Rules are being circulated for approval
DOH will send notification to all commenters after rules are adopted.ConclusionSlide25
Questions ?
Additional information
Clean Air Branch (808) 586-4200www.health.hawaii.gov/cab/ConclusionSlide26
GHG Rules Emission Reduction
Covered (EPA GHGRP & DOH Data)
“Missing”2010 Statewide Total Stationary (ICF)
1990 Statewide Total Stationary (ICF)
Required Stationary Reduction
S = Small
Large (> 100k CO2e Short Ton/yr)
S
Affected
E = Exempted
E
Key Input Revisions
Large Covered
2010 Statewide Total
Drives
“Missing”
E
S
X 12%
=
Uncontrolled
Uncontrolled
Growth
“Missing”
E
S
X 12%
+
Affected
=
Affected Source % Reduction
Total Required Reduction