Comment Details
| Comment Author: | Gordon Lloyd |
| Organization: | Canadian Chemical Producers' Association |
| Comment Date: | Thursday, 04 June 2009 |
| Uploaded Comment File: | Download File |
| Comments: |
Response to Stakeholder Comments and Final Draft Essential Requirements of Mandatory Reporting for the WCI: Response to the WCI / EPA Reporting Rules 1 The proliferation of proposals for reporting is a symptom of bigger problems. There must be one and only one reporting requirement for facilities. The WCI quite rightly notes the number of jurisdictions developing proposals for reporting GHG emissions and other relevant information. CCPA and others are becoming increasingly concerned that “pride in authorship” will overtake a sensible discussion about a single window reporting system for industry. In the Canadian context, large final emitters already have experience with two mandatory reporting obligations and would argue the WCI has given little regard to what has actually already worked and what hasn’t. CCPA remains concerned over the prescriptive nature of the approaches being taken by both the WCI and EPA. The principle of “best available data” should prevail at least in the initial implementation stages until confidence in a fully mature system is developed. 2 Cap and Trade and intensity based framework each require the same level of accuracy. In that regard the Alberta experience is valuable. All climate change strategies to date have attempted to price emissions, be it $25, $250, or $15. Cap-and-trade does not in and of itself present specific requirements for precision unless the WCI or EPA can demonstrate this. In this regard, based on our member's experience, CCPA believes Alberta has established a reporting requirement that incorporates appropriate rigor to support emissions trading and continuous improvement. 3 There appears to be consensus that direct costs will be borne – CCPA believes WCI and others have understated the burden. This reporting proposal adds material cost to operations – capital investments will be required that in our experience, are unnecessary in order to provide regulators with first class information. The requirement to install flow meters and High Heating Value analyzers and the resulting calibration programs run in capital costs alone in the range of $25,000 to $70,000 per device. Quality Assurance accordance with the Alberta code of practice (similar codes are in place for Ontario too, and maybe other jurisdictions) for one CEMS for SOx and NOx is approximately $100,000 per year. For one facility with multiple stacks, quality assurance of multiple CEMS could be in the order of millions of dollars. Such an investment needs to be weighed against the gain in accuracy from inventory calculations. NPRA and API have well documented the capital cost implications and CCPA supports their conclusions. We believe existing reporting requirements in Alberta and with the federal government are more than adequate to obtain accurate information. 4 A smarter approach for the chemical sector. API methodologies are the industry backbone for GHG emission quantification. Regular scrutiny has proven their value. The compilation of GHG estimation methodologies outlined in API'S Compendium of Greenhouse Gas Emissions Estimation Methodologies for the Oil & Gas Industry includes a section on Petrochemical Manufacturing. 5 A de minimus approach to small emissions. WCI should require reporting from facilities emitting in excess of 100,000 metric tons of CO2-e per year of direct emissions. It is essential that the WCI consider the cost and benefits associated with establishing a reporting threshold which is less than 100,000 metric tons CO2e. The burden of the proposed reporting requirements on smaller facilities is excessive for the chemical sector. The 100,000 metric ton of CO2e threshold sufficiently captures the vast majority of GHG emissions in the U.S. and Canada, while excluding smaller facilities and sources. As an alternative, WCI could phase in reporting thresholds. For example, WCI could require the immediate reporting of emissions from facilities that emit greater than 100,000 MT per year of CO2e, and phase in greater than 50,000 MT CO2e and 25,000 MT CO2e per year thresholds at later dates. This approach would enable immediate reporting of nearly all of the emissions from the chemical industry. A phased approach would also enable WCI to evaluate the system and review the vast data. Once the analysis has been completed, WCI could make subsequent determinations on reporting thresholds. The concept of de minimus emissions within a facility can be considered from a couple of perspectives. De minimus can relate to small volumes that have limited significance relative to a facility total. Another perspective is for situations of relatively small volumes occurring in multiple locations. In both cases, what is important is to roughly weigh the work or cost to estimate the emissions versus the potential size of the emissions being considered. This assessment may result in concluding that investing resources is not warranted, or alternatively that there is value in estimating the small volumes, but only if a highly simplified low cost method is applied. This approach to de minimus is principled based, and would be applied to a given situation. Being limited to a fixed percentage of 3% or 20,000 metric tonnes may be too high in certain situations or too low in other cases. 6 Third party verification and audit. CCPA believes that taxation audit principles should be seen as adequate and apply here. Regulated facilities should be responsible for keeping all information required to support its filing and is open for review by competent. 7 Regulating authority is responsible for enforcement. The principal purpose of a central depository should be for harmonization assurances. 8 Conclusion – we need to be guided by sensible principles: Build on sound technical work already done by others such as API Establish a forum for protocol improvement. |
| Comments: |
Cover Letter: February 4, 2009 Mr. Jim Norton Chair: Reporting Committee Western Climate Initiative (Submitted electronically via www.westernclimateinitiative.org) Dear Mr. Norton: RE: Comments on Response to Stakeholder Comments and Final Draft Essential Requirements of Mandatory Reporting for the Western Climate Initiative The Canadian Chemical Producers’ Association (CCPA) welcomes the opportunity to comment on the Western Climate Initiative response to stakeholder comments on the Third Draft of the Essential Requirements of Mandatory Reporting. CCPA is the national trade association of Canadian chemical manufacturers, representing 60 companies and Responsible Care Partners with from 5 to 5,000 employees. CCPA supports the need for good emissions inventories representing all significant sources to fully understand GHG emissions in a jurisdiction and input to sound policy on actions to reduce GHG emissions. Reliable and accurate emission data is required for capped sources to develop sound emission caps, compliance, and support emissions trading. CCPA, other Canadian industry, federal and provincial governments and other stakeholders have years of experience working together to find efficient ways to meet pollutant and GHG release inventory needs. CCPA was a leading participant in a four year consultative process dedicated to GHG emission reporting, working collaboratively with federal and provincial governments, non-government organizations and other industry sectors through the National Advisory Committee on Reporting and the Stakeholder Advisory Committee on Reporting (NACR/SACR). The Canadian federal and provincial governments have GHG emission reporting systems that have been in place for a number of years, as well as a third party verification system that has been mandated with specific direction and requirements in Alberta. Unique in North America, the Alberta reporting system has a proven track record and seems to be working well and meeting reporting requirements, including necessary rigor to support emissions trading. CCPA is prepared to work with regulators to once again help ensure that inventory objectives are met in an efficient manner. CCPA is aware that you will be receiving detailed submissions from the American Chemistry Council (ACC), American Petroleum Institute (API), the National Petrochemical & Refiners Association (NPRA) and the Western States Petroleum Association (WSPA). CCPA sees these submissions from these US associations as quite consistent with the points CCPA made in our earlier extensive comments on the 3rd Draft of the Essential Requirements of Mandatory Reporting for the Western Climate Initiative, particularly with respect to appropriate methodologies as a backbone for our industry’s approach to accurately quantifying emissions at our facilities. The purpose of this note is to draw your attention to and emphasize the importance of a few critical matters: 1. The requirement for one reporting requirement for all climate change plans regardless of jurisdiction. 2. Unnecessary imposition of costs with questionable value. 3. Protecting Confidential Business Information 4. Impractical timelines. Please see the attached Response to the WCI / EPA Reporting Rules for details. CCPA has experience in working with stakeholders and governments to design a GHG reporting system that will be practical and workable. I would be happy to discuss these issues further at your convenience. Yours sincerely, Gordon Lloyd Vice President, Technical Affairs GEL/glm c.c.: George Enei, Acting Director General, Science and Risk Assessment, Environment Canada |
