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RGGI Draft Model Rule General Comments from Environment Northeast Regional Greenhouse Gas Initiative Stakeholder Meeting Hartford, CT May 2, 2006 Derek.

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Presentation on theme: "RGGI Draft Model Rule General Comments from Environment Northeast Regional Greenhouse Gas Initiative Stakeholder Meeting Hartford, CT May 2, 2006 Derek."— Presentation transcript:

1 RGGI Draft Model Rule General Comments from Environment Northeast Regional Greenhouse Gas Initiative Stakeholder Meeting Hartford, CT May 2, 2006 Derek Murrow Director, Policy Analysis

2 General Issue 1 - The Cap Level is Set High Initial Cap Level is ~6.6% Above 2004 Emissions

3 RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006 General Issue 2 – Plant Exemptions without an Equal Reduction in Cap Level Issue:  Exemptions for Self-Generators (industrial units) that sell less than 10% of their power to the grid  Biomass exemptions (up to 50% fossil input could be exempt) Goal: Ensure a binding cap in the early years of the program and avoid loopholes for fossil combustion Recommendation:  States should voluntarily reduce their cap level (apportionment) based on average annual emissions of exempted units  Biomass emissions should be calculated based on the proportion of fossil fuel input to any dual-fueled plant, except for de minimus use of fossil (i.e. XX tons CO 2 per year), not allowing an up to 50% fossil loophole; annual reporting should be required of all biomass facilities over 25 MW

4 RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006 General Issue 3 – Early Reduction Credits that are Additional to the Cap Issue: Early Reduction Credits are interpreted to be additional to the cap (further inflation) Goal: Ensure a binding cap in the early years of the program Recommendation: Have the states provide the same incentive for early reduction through an allocation from within their existing cap level, as stated in the MOU

5 RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006 General Issue 4 – Consumer Benefit or Strategic Energy Allocation Issue: The Strategic Energy definition is vague and we are concerned that allowances could be used to support projects of little relevance to RGGI or which negatively impact the environment Goal: Use the value of allowances to reduce the cost of the RGGI program on the region’s electricity consumers Recommendation: clarify that all of the “consumer benefit or strategic energy purpose” allowance value must be used to:  Reduce the costs of the RGGI program to the state’s electricity ratepayers (would not exclude new supply side technologies);  Provide additional benefits for projects or activities that would not have occurred anyway and not replace existing programs or investments; and  Support programs and activities that do not pose a significant risk to human health and the environment.

6 RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006 Contact Information Derek K. Murrow Director of Policy Analysis Environment Northeast 101 Whitney Ave. New Haven, CT (203) Rockport, ME – Boston, MA – Hartford, CT


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