First Name | FIJI |
---|---|
Last Name | GEORGE |
Email Address | FIJI.GEORGE@ELPASO.COM |
Affiliation | EL PASO CORP-PIPELINE GROUP |
Subject | COMMENTS ON MAC RECOMMENDATIONS |
Comment | On behalf of El Paso Corporation Pipeline Group, I would like to thank the Market Advisory Committee (MAC) on their diligent work in developing the recommendations on "Designing a Greenhouse Gas Cap-and-Trade System for California". Based on the review of the final recommendations, El Paso would like to highlight the issues we raised in our comments to the MAC, especially related to regulatory concerns with respect to designing cap-and-trade programs for interstate natural gas pipelines. Our comments are summarized below and I am re-attaching our June 15, 2007 comments for the Board's consideration: Summary of El Paso’s comments with respect to the Program Scope: • There are major regulatory and commercial hurdles that have not been considered by the MAC, under Option B, that outweigh any perceived administrative efficacy derived from fewer regulated entities. • El Paso recommends not including both fugitive and vented methane emissions in any cap-and-trade programs due to substantial uncertainty surrounding emission estimates from these categories. • Vented emissions should not be considered as process emissions. Instead, this category should be considered as a separate source category and not be included in the overall cap-and-trade program. . Summary of El Paso’s comments with respect to Early Action Credits: • El Paso recommends issuance of allowances for early action credits for the natural gas transmission and distribution sectors. • Fugitive and vented emissions of natural gas transmission companies represent a small fraction of California’s overall 2004 GHG emissions. • El Paso and other natural gas transmission companies have already deployed technologies over the past several years to mitigate and reduce fugitive and vented emissions. • Not providing allowances for early actions will create inconsistencies with programs such as RGGI. Summary of El Paso’s comments with respect to Emission Offsets: • El Paso recommends incorporation of both case-by-case and performance-based standards emission offsets. • El Paso supports development of performance-based offset standards and has led industry and stakeholder efforts in this area. • The quality of the GHG offsets must be the primary criterion for deciding between performance-based and case-by-case offset standards. • The CDM board has approved AM0023 to quantify GHG offsets from natural gas facilities. El Paso has developed a policy-neutral technical protocol that incorporates the technical attributes of AM0023. • Inclusion of El Paso’s case-by-case offset protocol for natural gas transmission and distribution facilities will ensure the availability of high quality GHG offsets to California’s cap-and-trade program. • Experience gained through case-by-case offset development will form the cornerstone for future performance-based offset standards. Thank you for your consideration of our comments and if you have any further questions, please do not hesitate to contact me. Sincerely, Fiji George |
Attachment | www.arb.ca.gov/lists/ccmac06/5-mac_cap_and_trade_el_paso_comments_061507__final_ecopy_.pdf |
Original File Name | MAC Cap and trade El Paso Comments_061507__FINAL_Ecopy_.pdf |
Date and Time Comment Was Submitted | 2007-07-20 08:31:28 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.