First Name: | Sharon |
---|---|
Last Name: | Rubalcava |
Email Address: | sharon.rubalcava@alston.com |
Affiliation | Alston & Bird |
Subject | Comments on the Draft Final Report: Assembly Bill 1318: Assessment of Electrical Grid Reli |
Comment |
These comments are submitted on behalf of Plains All American Pipeline LLP. We are writing to comment on the draft report titled Assembly Bill 1318: Assessment of Electrical Grid Reliability Needs and Offset Requirements in the South Coast Air Basin (Draft Report) and specifically on the discussion of the availability of Emission Reduction Credits (ERCs) for new greenfield power generating capacity in the South Coast Air Basin (Basin). As the Draft Report explains, while there are exemptions for existing power plants that repower using advanced generating technologies, for new generation not directly linked to the retirement of existing steam boiler facilities offsets must be provided. The Draft Report estimates that under the high bookend scenario, the Basin would need an additional 615 megawatts of new, greenfield generation. Such new generation capacity would not be eligible for the offset exemption in Rule 1304(a)(2) but would have to supply offsets by purchasing ERCs or finding other means to generate surplus emission reductions. Over the last ten years, Plains has purchased a significant amount of ERCs for a project that is no longer proceeding, and it now has ERCs available for sale. Table III-4 of the Draft Report shows the estimated amount of credits required in the form of ERCs for new greenfield projects, assuming a 1.2:1 offset ratio. Using that information, the following table compares the estimated amount of ERCs needed for such projects in tons/day (pounds/day) to Plains current ERC holdings: Pollutant Tons/Day (lbs/day) Needed Plains’ ERC Holdings (lbs/day) NOx 0.76 (1520) 658 CO 0.93 (1860) 0 VOC 0.45 (900) 630 PM10 0.32 (640) 22 SOx 0.12 (240) 203 As you can see, Plains’ ERCs could provide offsets for a significant percentage of the additional 615 megawatts of power needed in the Basin under the high bookmark scenario. Also, since NOx and SOx are precursors to PM 10, the use of the NOx and/or SOx ERCs as interpollutant offsets, set an appropriate offset ratio, could provide an additional source of PM 10 offsets. (A new power plant would be in NOx RECLAIM and would not need the NOx ERCs.) Since Plains’ ERCs are available for sale and represent a significant commitment of resources on behalf of the company, Plains believes it is premature to claim that sufficient PM 10 offsets are not available at this time to satisfy the need for offsets from new generation, and would object to legislation to address this situation that might adversely affect the value of its credits. |
Attachment |
Original File Name:
Date and Time Comment Was Submitted: 2013-11-06 10:25:21 |
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