First Name | Laurie & Allan |
---|---|
Last Name | Williams/Zabel |
Email Address | williams.zabel@gmail.com |
Affiliation | Citizens Climate Lobby & as Individuals |
Subject | Comment Regarding ODS Protocol |
Comment | Ozone Depleting Substances Protocol – Summary of Evidence AB 32 Offsets Challenge – Public Comments on October 19, 2011 Laurie Williams and Allan Zabel, as individuals and as volunteers for Citizens Climate Lobby Summary of Evidence that Proposed Greenhouse Gas Offset Protocols and Regulations do not meet the AB 32 Integrity Criteria Standard in Protocol: The proposed Ozone Depleting Substances (“ODS”) Protocol would provide offset credits for any ODS projects that meet the description of such a project. This is contrary to the AB 32 Integrity Criteria -- the requirement that all emission reductions meet the following criteria (See Section 38562(d)): AB 32 Integrity Criteria: “(d) Any regulation adopted by the state board pursuant to this part or Part 5 (commencing with Section 38570) shall ensure all of the following: (1) The greenhouse gas emission reductions achieved are real, permanent, quantifiable, verifiable, and enforceable by the state board. (2) For regulations pursuant to Part 5 (commencing with Section 38570), the reduction is in addition to any greenhouse gas emission reduction otherwise required by law or regulation, and any other greenhouse gas emission reduction that otherwise would occur. Evidence of Failure to Meet Integrity Criteria 1. All Reductions Are Deemed Additional: In the ODS Protocol, the ARB establishes a standard which treats all ODS reductions from allowed projects as being additional. This standard relies on grossly distorted, misinterpreted, and incomplete information used by the Climate Action Reserve (“CAR”) to draft an earlier version of the ODS protocol (“CAR ODS Protocol”). In establishing this standard, the ARB also ignores more recent data gathered and published by the ARB itself concerning California data. a. Flaws in Earlier CAR ODS Protocol: In Appendix B of the CAR ODS Protocol (Attachment 1, pp. 59-62), CAR sets forth data which, CAR claims, demonstrates that very little ODS is destroyed in the United States. Table B.1. Destruction of ODS in the U.S. CFC 2003 Destroyed (kg) 2004 Destroyed (kg) CFC-11 58,846 109,884 CFC-12 23,709 62,364 CFC-114 464 4,044 CFC-115 4,401 6,737 Source: Reproduced from ICF, ODS Destruction in the United States of America and Abroad (2009), prepared for U.S. EPA. However, the “ODS Destruction in the United State of America and Abroad” (“2009 Report”) from which CAR took this data very clearly states that the data is very incomplete. “Table 3 presents the total reported quantity of ODS (by type) destroyed in the U.S. for the years 2003 and 2004. Data is only presented for those facilities destroying ODS commercially that provided responses to questionnaires. Several other companies reported sending ODS to other off-site destruction facilities, but these data were not included due to their incomplete nature. Therefore, the data presented are not inclusive of all commercial ODS destruction that occurred in the U.S. in 2003 and 2004. Quantities of ODS destruction as reported in the TRI database, are presented in Appendix C.” See Attachment 2, at p. 20 of 2009 Report, emphasis in original. The data in Appendix C, taken from EPA’s Toxic Release Inventory, shows that the 2003 data used by CAR understates the actual ODS destruction as follows: CFC 2003 Destroyed Kg (CAR) 2003 Destroyed Kg (EPA TRI) CFC-11 58,846 103,995 CFC-12 23,709 38,599 CFC-114 464 1,085,015 CFC-115 4,401 314,143 Even these TRI figures may undercount actual destruction because, as stated in the 2009 report, ODS listed as “Treated Off-Site” in the TRI data base were not included as destroyed due to lack of certainty that they were, in fact, destroyed. See Attachment 2, at pp. 48-9 of 2009 Report). In addition to understating ODS destruction rates by more than a factor of 17 times for the combination of the 4 CFC listed, CAR also “interpreted” the meaning of this data and added its own completely unverifiable data. CAR decided that the 2003-04 data represented practices of handling ODS which were “not yet influenced” by the potential incentives for generating GAG offsets and further relied up data provided by industry anonymously in minimizing the amount of historic and ongoing ODS destruction which might qualify for generating offsets under the ODS Protocol. Attachment 1, at p. 59-60. b. Current ODS Recovery From Foam in California: “California has two appliance recycling facilities operated by JACO Environmental, and two facilities operated by Appliance Recycling Centers of America (ARCA). They handle about 145,000 to 150 000 units per year, with the vast majority of units recycled as part of a state-wide electric utility incentive program to remove older working appliances (that are energy efficient) from the electricity grid. JACK and ARCA handle 80,000 units for Southern California Edison, 40,000 units for Pacific Gas & Electric (PG&E) and a further 25,000 units for Sacramento Municipal Utility District (SAUD). Therefore about 12- 13% of residential refrigerator-freezers reaching end-of-life in California is recycled using a comprehensive foam blowing agent recovery process.” See Attachment 3, pp. 51-2. 2. ODS Projects Already Occurring: Projects of the type described in the ODS Protocol are currently being implemented. Therefore, the ODS Protocol would grant credit to projects which have occurred and will continue to occur in the course of business-as-usual. a. Huge Project in Philadelphia: “GE and ARCA Inc. announced Sept. 9 that the UNTHA Recycling Technology system was ready to crunch its first refrigerator. It will recover about 95 percent of the insulating foam, plus high-quality plastics, aluminum, copper and steel. The new UNTHA Recycling Technology (URT) system at the Appliance Recycling Centers of America (ARCA)’s facility in Philadelphia is ready to begin recycling as many as 150,000 refrigerators annually, GE and ARCA announced Sept. 9. ARCA hired 50 new employees as part of its $10 million investment in URT and other new capital equipment. Since February, the two companies said, they have doubled the number of states served, feeding 100,000 additional appliance units to the Pennsylvania facility from Massachusetts, Connecticut, Pennsylvania, Maryland, Virginia, West Virginia, New Jersey, New York, North Carolina, Delaware, Rhode Island and Vermont. Consumers bring their used refrigerators to participating retailers, who then send them to ARCA as part of GE’s participation in the EPA Responsible Appliance Disposal program.” See Attachment 4. b. Utilities Fund Projects, Realize Benefits: Southern California Edison states that its participation in EPA’s RAD Program, which involved recycling old and inefficient but still working refrigerators and freezers, had a benefit-cost ratio of 3:1 or greater, saving the company tens of millions of dollars. See Attachment 5. c. Retailers Joining Recycling Program: Major retailers, including Home Depot, Sears, and Best Buy have joined EPA’s RAD Program to recycle refrigerators and freezers. See Attachment 6. 3. ODS Protocol Ignores Profitability of New Destruction Technology: The standard created by the Protocol ignores recent advances in technology, developed in Europe, which are cost-effective and profitable. This new technology has been established in the United States and, given its competitive advantages, is very likely to gain wide-spread usage. a. ARCA Shows New Technology is Profitable: The 2010 ARCA annual report shows the refrigerator and freezer recycling, especially with the new control technology, is profitable. “2010 was a solid year for our appliance recycling operations. Appliance recycling revenues increased from $15.9 million in 2009 to $19.4 million in 2010, mainly as a result of new recycling contracts we were awarded during the year. Gross profit as a percentage of total revenues—excluding our new joint venture, ARCA Advanced Processing, which began operations in February 2010—increased to 42.8% from 35.6% in 2009. Gross profit increased 32%, from $9.2 million in 2009 to $12.1 million in 2010, which we attribute to stronger byproduct revenues and improved efficiencies implemented throughout our recycling operations. We signed twelve contracts with electric utilities last year, making 2010 one of our most productive years ever in terms of adding new customers. Also of note, we were successful in retaining the business of many of our current customers, including renewed contracts with all of our major utility customers in California. Southern California Edison, whose program we have provided turnkey refrigerator and freezer recycling services for since 1994, is rapidly approaching the collection of their 1,000,000th appliance. The consistently high energy savings demonstrated through programs such as Edison’s have contributed to making appliance recycling a mainstay of energy efficiency portfolios across North America. The February 2010 opening of our ARCA Advanced Processing facility in Philadelphia, which was accomplished through a joint venture with 4301 Operations, LLC, was a pivotal event in our efforts to permanently retire old appliances through a highly effective process and technology. Our major contract on the East Coast now provides us with the steady stream of appliances required to make a fully integrated appliance recycling center economically attractive. We expect to complete the installation of an UNTHA Recycling Technology (URT) materials recovery system for refrigerators and freezers in our Philadelphia recycling center during the second quarter of 2011. This equipment will not only significantly reduce emissions of greenhouse gases and ozone-depleting substances that can occur during the disposal of appliances, but will also r educe the typical landfill waste of a refrigerator by approximately 85% by weight. Another benefit of this technology is that the URT system will enable us to generate a finer grade of byproduct materials to sell to metals and plastics recyclers.” See Attachment 7, p. 7. 4. New ODS Destruction Technology Creates Market Advantage: Marketing information created and published by General Electric shows there is a very significant marketing advantage for retail sellers of refrigerators in being able to offer and perform environmentally friendly recycling of customers’ old refrigerators. a. Recycling Creates Market Advantage: 70% of customers want appliance recycling (see Attachment 8, p. 2), 82% of customers will go out of their way to purchase from a manufacturer that recycles (see Attachment 9, p. 2), and 67% of customers are willing to pay more if a retailer offers recycling programs (see Attachment 9, p. 2). List of Attachments 1. Climate Action Reserve, U.S. Ozone Depleting Substances Project Protocol, February 3, 2010 2. ICF International, ODS Destruction in the United State of America and Abroad, May 2009, as attached to, Compilation of Strategies for the Environmentally Sound Management of Banks of Ozone-Depleting Substances, United Nations Environment Programme, June 26, 2009 3. California Air Resources Board and California Environmental Protection Agency, Developing a California Inventory for Ozone Depleting Substances (ODS) and Hydrofluorocarbon (HFC) Foam Banks and Emissions from Foams, March 14, 2011 4. Environmental Protection, Big Goals for Philadelphia Refrigerator Recycling Project, September 3, 2011 5. EPA and Southern California Edison, Safeguarding the Environment One Appliance at a Time, undated 6. Consumer Reports, It's Getting Easier to Recycle Your Old Appliances, September 9, 2011 7. Appliance Recycling Centers of America, Inc., 2010 Annual Report 8. General Electric, GE Partners with EPA on Responsible Appliance Disposal (RAD) Program to Reduce Greenhouse Gas Emissions and Landfill, February 8, 2011 9. New York Times, GE Expands Appliance Recycling for Consumers and Retailers – How RAD, September 9, 2011 |
Attachment | www.arb.ca.gov/lists/capandtrade11/92-ods_docs_10-11.zip |
Original File Name | ODS docs 10-11.zip |
Date and Time Comment Was Submitted | 2011-10-18 21:49:10 |
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