2014/02/21

Public comment on "Refining Emission Tracking Regulation" aka the fossil fuel industry is dying

The "Refining Emission Tracking Regulation" is a proposed rule for the Bay Area Air Quality Management District. Some groups are trying hard to make sure that it requires reporting of the types of crude oil the refineries take in. I agree with this goal, as you can see from the letter below.



February 21st, 2014

To: Stationary Source Committee
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109

Re: Comments on Petroleum Refining Emission Tracking Regulation, Greenhouse Gas Emissions, and the Regional Climate Action Strategy

        As you are no doubt aware, in November the Board passed a Climate Action Resolution (Resolution No. 2013) committing to a goal of reducing greenhouse gas (GHG) emissions to 80% below 1990 levels by 2050.

        Very few people have grappled with the enormity of this task. As luck would have it, just last night I was beginning to prepare for a presentation on the topic and I started working on a graph to illustrate the problem. I am not pleased with the aesthetics of the graph, but I am including it on the following page because it’s the best thing I have on hand at such short notice (I found out about this meeting and the submission deadline just a couple hours ago).

        A picture is worth a thousand words, but a poor picture requires a few dozen words for clarification.

        Although the graph is lightened only from 2014 onward, it is based on BAAQMD’s 2010 report, so the 2011 and 2014 numbers are projections. Nevertheless, you can see that BAAQMD was assuming a linear increase in all sources of greenhouse gases.

        The thick black line goes from the 2014 point to Executive Order S-3-05’s 2020 goal (matching 1990 levels) and then to the 2050 goal. The most important point to take away from this graph is that today’s refinery emissions are by themselves almost as high as the 2050 goal for all sources.

        It is clear that along with other sectors, the refineries must decrease their GHG emissions. Unlike other sectors, however, a large proportion of refineries’ emissions are inherent to the core function of the industry.

        The Bay Area refinery industry will have to contract, not only to meet the lower regional emissions caps, but also because of reduced demand of fossil fuels due to other sectors reducing their GHG emissions.

        It is important that BAAQMD keep a very close eye on refineries’ GHG emissions, and one of the most important determinants of their emissions is the type of crude oil (aka feedstock) that the refineries take in. BAAQMD must recognize that the Refinery Emission Tracking Regulation is a key tool to meet its own Climate Action Resolution and will be part of the Regional Climate Action Strategy currently being developed.

        For this reason the Refinery Emission Tracking Regulation should be as thorough as possible, it should include reporting and monitoring of refinery feedstock as well as strong punishments for misreporting, and it should be enacted reasonably quickly.

Yours,
Martin MacKerel




No comments: