Category Archives: Greenhouse gas emissions

Air pollution, Air quality violations, Federal deregulation, Greenhouse gas emissions, Keeping Watch on Earth News, Mercury emissions, Toxic pollutants, Trump administration, US Environmental Protection Agency

What Just Happened to the Mercury Rule?

Energy Institute Blog, by Meredith Fowlie, April 20, 2020

Last week’s EPA decision adds insult to injury for our already vulnerable communities.

Perhaps you missed it. There’s a lot going on right now. But amidst all the COVID-19 headlines last week, the EPA decided that it is not “appropriate and necessary” for the government to limit emissions of mercury and other hazardous air pollutants from power plants.

coal
Source: Pixabay

This is not a roll-back of a regulation. It’s more nuanced than that. It’s a high-stakes procedural move with two important implications:

First, it scraps the legal basis for the Mercury and Air Toxics Standards (MATS) which limit hazardous air pollution from coal and oil-fired power plants. Having knocked the legal foundations out from under this important regulation, I think there’s a real risk that power plants will find ways to dial back on compliance in the future.

Second, it sets a dangerous precedent for how the benefits and costs of federal environmental regulations are assessed. The ruling removes significant health benefits from cost-benefit consideration on the grounds that they are not directly targeted by MATS.

This announcement comes at a time when the country is reeling from the global coronavirus pandemic. Protecting public health is top of mind. We’ve all become keenly aware of how actions we take can indirectly protect the health of the most vulnerable among us. With these benefits in mind, we are taking action.

Meanwhile, the EPA has decided that the indirect health benefits of pollution reductions should not be considered in regulatory cost-benefit analysis. This decision departs recklessly from standard practices for responsible public decision-making.

Some colleagues and I recently published this paper (based on our longer report) which points out deep flaws in this EPA decision. The agency’s own Science Advisory Board released a report calling for a “do-over”. Hundreds of thousands of public comments raise concerns. Even the electricity sector stands in opposition. The Trump EPA response: To hell with it. We are pushing ahead.

To understand what this means, we need to remember how we got here.

The Mercury and Air Toxics Standards limits the emissions of mercury and other hazardous air pollutants (HAPs) from power plants. To justify the rule, the EPA must demonstrate that it is appropriate and necessary. Back in 2011, the EPA supported this argument with a detailed analysis that projected big public health benefits from the power plant emissions reductions expected under the regulation. The table below, taken from the 2011 analysis, shows monetized benefits far exceeding the costs.

table
Summary of the quantified benefits and costs in the 2011 RIA for the MATS rule. These are projected for the year 2016. The data reported in this table are from Table ES-1 of EPA (2011).

There were some serious bumps on the road to implementation. But power plants began complying in 2016. The industry has since invested billions to install pollution abatement equipment in order to meet MATS requirements.

Last year, the Trump EPA started working to reverse the appropriate and necessary finding. The agency issued this six-page memo that re-interprets the 2011 cost-benefit analysis. There’s no new information here. The big change is that the “co-benefits” – health benefits that result indirectly from MATS compliance—have been wiped off the cost-benefit board. If we ignore these benefits (row 3 in the table above), MATS appears to fail the cost-benefit test.

There are many reasons to be concerned about this maneuver.  Let me unpack three:

  1. Co-benefits are real benefits

When power plants reduce mercury emissions, they also reduce emissions of precursors to harmful particulate matter (PM). Reducing exposure to small particulates saves lives. These benefits are referred to as “co-benefits” because they are caused by – but not directly targeted by – the regulation.

If a policy will generate big health benefits, directly or indirectly, these should be counted. Federal agencies are under Executive Order to weigh the available evidence on all significant costs and benefits in their regulatory assessments. This is also required under the EPA’s own guidelines for economic analysis.

An official decision that eliminates or reduces consideration of co-benefits sets a troubling precedent for future regulatory decisions. If this approach becomes standard, it becomes much more difficult for the EPA to justify socially beneficial regulations. Greenhouse gas emissions regulations- which can deliver significant reductions in local air pollution- are one important example.

  1. Direct benefits estimates are outdated and incomplete

The 2011 direct benefit projections that serve as a basis for last week’s decision reflect only one health benefit from reducing mercury emissions: improvements in the IQs of children whose families catch and eat freshwater fish. This narrow focus explains why those 2011 direct benefits estimates are so small.

A decade later, we know a lot more about how power-plant mercury accumulates in commercial seafood consumed by many Americans. In addition, recent research suggests that mercury exposure could cause cardiovascular problems. If these additional health impacts were accounted for, the direct benefits of HAP reductions would look quite different. But the 2020 EPA decision is still referencing outdated and incomplete 2011 benefits numbers.

  1. Costs are largely in the past

To comply with MATS, billions have been invested in equipment that scrubs harmful pollution out of power plant emissions. In other words, the investment costs that comprise the majority of the 2011 cost projections have already been incurred. Going forward, the costs we need to consider are the costs of operating this pollution abatement equipment. Estimates I’ve seen range from  $1.80/MWh to as high as $7.92/MWh (a non-trivial increase in coal-fired electricity generation costs).

FGD
Flue gas desulfurization is one of the technologies used to comply with MATS (Source)

By dismissing the legal basis for the rule, MATS is left wide open to the challenge that the pollution controls are no longer legally required. If I were a coal plant operator, I might read between the lines of this decision and conclude that the EPA is not so concerned about enforcing MATS going forward.

Coal plants across the U.S. are struggling to compete with natural gas and renewables. If MATS requirements are not there to keep pollution controls switched on, plants in competitive electricity markets will have an incentive to turn this equipment off to save a few dollars/MWh. If this happens, downwind communities will pay a hefty health price.

Adding insult to injury

You would think that a high-stakes regulatory decision like this would merit an analysis update given that almost a decade has passed since the original assessment was done. The reams of data and scientific evidence that have accumulated since 2011 could provide a much more accurate evaluation of the rule’s benefits and costs, in addition to a more informed basis for re-evaluating the appropriate and necessary finding.  Instead, this EPA has dusted off a stale 2011 analysis, deleted the co-benefits, and declared the rule unnecessary and/or inappropriate.

The timing of this decision feels particularly callous because the communities that have historically been most exposed to high levels of air pollution are the ones being hit hardest by the COVID-19 crisis. This recent study suggests that even small increases in long-term exposure to particulate matter significantly increase COVID-19 fatality risk.

The Trump administration assures us it is putting “safety first” during this COVID-19 epidemic. But in the background, Trump appointees have been doing quite the opposite with decision after decision after decision. This MATS reversal has the potential to do real damage. But if there is good news to be found in this story, it’s that it will take time to play out. One more reason to work hard to course correct in November.

Keep up with Energy Institute blogs, research, and events on Twitter @energyathaas

Suggested citation: Fowlie, Meredith. “What Just Happened to the Mercury Rule?” Energy Institute Blog, UC Berkeley, April 20, 2020, https://energyathaas.wordpress.com/2020/04/20/what-just-happened-to-the-mercury-rule/

California oil industry, California Regulation, Greenhouse gas emissions, Oil and gas industry

Oil and gas production in California – Extraordinary?

Repost from Legal Planet

Guest Bloggers Deborah Gordon and Frances Reuland: Is California Extraordinary? Its Oil Resources Certainly Are

Facts About California’s Oil and Greenhouse Gas Emissions

Despite ongoing federal rollbacks to environmental regulations, California has the right to set its own clean air standards because it is truly extraordinary. Truth be told, the compelling circumstances that first set in motion California’s vehicle emissions standards remain entirely valid. And there are four recent conditions, related to California’s oil supply, production, and refining, that bolster California’s case against the Administration’s threat to strip California of its clean car clout.

In 1967, then governor Ronald Reagan adopted statewide vehicle emissions regulations to address California’s severe air pollution. Shortly thereafter, when the federal Clean Air Act was adopted, California was granted a waiver to set its own tougher vehicle emissions standards. Over the decades, California has repeatedly ratcheted up these regulations to also include greenhouse gas (GHG) emissions. In order to maintain its waiver, California’s emissions standards must be deemed necessary to meet “compelling and extraordinary conditions.” Historically, these referred to the state’s unique meteorology, geography, population, and air pollution levels.

All of these still hold true: the sun shines strong, the weather is warm, mountains wall in emissions from cars and other sources, one in eight American drivers reside here, and the air is still very dirty.

But there are four more extraordinary circumstances, all relating to California’s oil resources, that need to be factored into the case for preserving and strengthening California’s clean car program.

These circumstances are bolstered by the fact that California’s gasoline and diesel markets are geographically isolated from other locations in the United States that produce refined products. As such, California is essentially self-sufficient, refining its own transport fuels. Little, if any, gasoline and diesel are obtained from outside the state to balance out supply with demand.

All of the oil California produces ends up in its own refineries, and this is not an environmentally-friendly affair, especially in a state that has taken the lead on clean air and climate change. According to the Oil Climate Index (OCI)—an open source tool (developed by Gordon and her partners at Stanford and the University of Calgary) that compares the climate impacts of global oils—extracting and refining oil in California is dirtier than anywhere else in the United States. Weakening California’s vehicle emissions standards will force Californians to consume more of the state’s dirty oil longer into the future. This will increase pollution levels and elevate risks to public welfare in the state with the nation’s worst air pollution—69 percent of counties had unhealthy air on 33 days last year.

California’s oil resources are extraordinarily strained

As Texas, North Dakota, New Mexico, and overall U.S. oil production rises, California production is in decline. Since 1985, California’s crude oil production has dropped steadily: the state now produces under 500,000 barrels per day, less than half of its output 30 years ago. California’s aging oil fields, unstable seismic geology, and tight environmental rules all work to limit oil production. Successfully running its oil refineries at their current capacity of 2 million barrels a day to meet Californians’ gasoline and diesel demands requires the state to feed the entirety of its domestic oil into its refineries and then import 70 percent more oil. If realized, Trump’s plan to weaken the state’s clean car standards would increase gasoline and diesel demand, exacerbating the state’s already-strained oil resources and further pressuring security of its energy supplies.

California’s oil resources are extraordinarily dirty

California’s oils have some of the largest carbon footprints worldwide. Producing, refining, and consuming a barrel of California oil emits more GHGs than other global barrels. For example, the state’s largest oilfield, Midway Sunset, is estimated to be more carbon intensive than Canada’s oil sands. California’s South Belridge and Wilmington fields are also among the highest-emitting in the nation. Trump’s plan would increase California’s GHG footprint, countering the state’s climate goals.

California’s oils are extraordinarily energy intensive

Aging oils in California require significant amounts of energy to extract and refine, much more than newer resources in North Dakota, the Gulf of Mexico, and elsewhere. Fossil fuels, like natural gas and diesel, provide these extra energy inputs. A barrel of California’s Midway Sunset oil, for example, uses one-third of its total energy just to extract and refine it into petroleum products like gasoline and jet fuel. Likewise, California’s complex refineries consume nearly five times more energy to turn the state’s oil into marketable products than simpler refineries. Much more manpower and money are spent bringing California oil to market than elsewhere in the country.

California’s oils are extraordinarily undocumented

Unlike other states and countries, California does not document its oil quality. The problem is that California’s oil resources are more dangerous to handle than most global oils. In 2011, for example, a California oil field worker was buried alive when the ground gave way as steam was being cycled through the oil field. California’s complex oil was documented long ago by the federal government, but recommendations for oil data transparency have gone unheeded for over a century. These large information gaps introduce new environmental risks for California.

California’s 30 million motor vehicles that far outnumber any other state are a major source of air pollution. Clean car rollbacks are a threat to the state’s environmental progress—and energy security. The state needs to fight hard to preserve its pioneering vehicle emissions standards on behalf of itself and several U.S. states and international provinces that have already adopted them. Beyond preserving the standards in place, state policymakers should also consider tightening their emissions standards if they are going to make real headway addressing climate change. In this historic fight, California can draw on its extraordinary status—namely its exceedingly dirty, depleting oils that are unusually energy intensive and fundamentally unknown.

Deborah Gordon is the director of the Energy and Climate Program at the Carnegie Endowment for International Peace and a senior fellow at the Watson Institute for International & Public Affairs at Brown University. Frances Reuland is Carnegie’s James C. Gaither Junior Fellow in the Energy and Climate Program.

California Governor Jerry Brown, Cap-and-trade, Clean energy, Climate action, Communities For A Better Environment (CBE), Greenhouse gas emissions, Oil exports, Oil imports, Oil refineries, Tar sands crude

Until California curbs its oil refineries, it won’t meet its climate goals (Benicia & others are heroes)

Repost from the Los Angeles Times
[Editor: Significant quote, Benicia in final paragraph – “In the absence of action at the state level, it has fallen to localities to prevent refineries from at least increasing crude oil imports to their facilities. Over the last decade elected officials in half-a-dozen communities from Benicia to San Luis Obispo County have blocked refinery infrastructure projects that would allow more crude oil imports. They’re the real heroes of California’s climate saga — too bad they won’t be the ones in the spotlight at the summit.”  – RS]

Until California curbs its oil refineries, it won’t meet its climate goals

By Jacques Leslie, Sep 11, 2018 | 4:15 AM
Until California curbs its oil refineries, it won't meet its climate goals
The Phillips 66 refinery in the Wilmington neighborhood of Los Angeles. (Rick Loomis / Los Angeles Times)

While Gov. Jerry Brown and other California leaders bask under an international spotlight at this week’s Global Climate Action Summit in San Francisco, there is one highly relevant topic they’re not likely to bring up: oil refineries.

That’s because refineries are crucially absent from California’s climate change strategy. The state has justifiably gotten credit for addressing climate change issues that the nation won’t — promoting renewable energy, cap-and-trade greenhouse gas emission limits, and electric vehicles — but it has backed off from challenging refineries, the centerpieces of California’s oil supply infrastructure.

Concentrated in Los Angeles’ South Bay and the San Francisco Bay Area, the state’s 17 refineries comprise the largest oil processing center in western North America. Unless emissions from those refineries are curbed, the state has no chance of meeting its long-range climate change goals.

Greg Karras, a senior scientist at Huntington Park-based Communities for a Better Environment, calculates that without restraints on refineries, even if emission reductions from all other sources hit their targets, oil sector pollution through 2050 would cause the state to exceed its overall climate goals by roughly 40%.

“Refineries have been largely exempted from the state’s cap and trade program, which charges fees for emissions.”

That’s primarily because refineries have been largely exempted from the state’s cap and trade program, which charges fees for emissions. Last year, the legislature extended the program for another decade, from 2020 to 2030, but only after bowing to the oil industry’s wishes. To win a needed two-thirds majority, cap and trade supporters exempted the industry from fees for all but a tenth of refinery emissions through 2030. The legislation also prohibited regional air districts from imposing their own limits on refinery carbon dioxide emissions, a severe blow to communities suffering from pollution from nearby operations. Instead of curbing refineries, these provisions gave them a decade-long free pass.

To make matters worse, the oil that is being processed is bound to get dirtier, resulting in a higher rate of greenhouse gas emissions throughout the fuel-production chain. Oil used by the state’s refineries already contains the highest intensity of greenhouse gas pollutants of any refining region in the country. As drillers pump the dregs from the state’s nearly spent fields, that intensity is increasing.

With California oil extraction in decline, its refineries will want to import more crude oil from other states and nations. That could include tapping the Canadian tar sands, notorious for its off-the-charts, climate-busting pollutants. Completion of the stalled Trans Mountain pipeline expansion in Canada would facilitate what Greenpeace calls a “tanker superhighway” from Vancouver to California ports. California refineries have tried to win approval for rail terminals and ports that would receive tar sands oil but have so far been blocked by local governments.

The refineries’ contributions to greenhouse gas emissions don’t end with their own production, of course. When the fuel they produce is used, it’s one of the primary contributors to climate change. As California shifts to renewable energy and electric vehicles, less refined fuel will be consumed here and more will be exported to other states and nations.

As a result, the state could become, in Karras’ words, “the gas station of the Pacific Rim.” And as exports grow to countries like India with lax environmental standards, refineries won’t even need to meet California’s more stringent regulations on fuel composition; instead, they will export more pollution.

The main reason state leaders have done little to limit oil supply is obvious: The oil industry remains a formidable adversary, wielding its financial and lobbying might to head off restraints. For virtually all Republican state legislators and a substantial number of Democrats, oil supply is too hot a topic to touch, Karras told me.

Meanwhile, state policy calls for greenhouse gas emissions to drop by 80% of 1990 levels by 2050. Given the oil industry’s cap and trade refinery exemptions in place through 2030, the only way to achieve that level is to place drastic limits on refineries as soon as those exemptions expire, which is unlikely to happen. A more realistic approach would remove the oil industry’s exemptions and impose cuts of 5% a year on refinery emissions immediately — an urgent task that state leaders have shown no interest in carrying out.

In the absence of action at the state level, it has fallen to localities to prevent refineries from at least increasing crude oil imports to their facilities. Over the last decade elected officials in half-a-dozen communities from Benicia to San Luis Obispo County have blocked refinery infrastructure projects that would allow more crude oil imports. They’re the real heroes of California’s climate saga — too bad they won’t be the ones in the spotlight at the summit.

Jacques Leslie is contributing writer to Opinion.
Climate Change, Climate change denial, Global warming, Greenhouse gas emissions, Keeping Watch on Earth News, Oil industry knew, Shell Oil

Here is what #Shell Knew about Climate Change in the 1980s

Repost from DeSmogBlog
[Editor: Here’s the link to the original 1988 Shell internal document.  ALSO, see previous stories 2015-2016.  – RS]

Here is what #Shell Knew about Climate Change in the 1980s

By Mat Hope • Wednesday, April 4, 2018 – 23:15
Cover pages of a Shell internal document

Shell knew climate change was going to be big, was going to be bad, and that its products were responsible for global warming all the way back in the 1980s, a tranche of new documents reveal.

Documents unearthed by Jelmer Mommers of De Correspondent, published today on Climate Files, a project of the Climate Investigations Center, show intense interest in climate change internally at Shell.

The documents date back to 1988, meaning Shell was doing climate change research before the UN’s scientific authority on the issue, the Intergovernmental Panel on Climate Change, was established.

Here’s a quick run through of a 1988 document entitled, ‘The Greenhouse Effect’. Continue reading Here is what #Shell Knew about Climate Change in the 1980s →