Emission Reduction Credit Availability/Cost/Efforts Taken in South Coast Los Angeles Area Chamber of Commerce Environment Committee Meeting November 28, 27, Wednesday L.A. Area Chamber of Commerce Headquarters Mohsen Nazemi, P.E. Assistant Deputy Executive Officer South Coast Air Quality Management District 1
New Source Review (NSR) Rules Federal Clean Air Act & California Clean Air Act New, Modified or Relocated Facilities SCAQMD s Non-Attainment NSR Reg. XIII/Rule 25 Major Components of Non-Attainment NSR BACT/LAER Offsets Modeling 2
NSR Emission Offset Requirements Unless exempt, all emission increases are to be offset through: Internal Facility Emission Reductions, or External Emission Reduction Credits (ERCs/RTCs) Exemptions from offset requirements Small Sources (<4 tons per year) Essential Public Services (i.e. POTWs, Schools, Power Plants) Special Cases (i.e. Air Pollution Control, Regulatory Compliance) 3
ERCs in South Coast ERCs are generated from: Equipment shut-downs, primarily or Voluntary add on controls ERCs must meet 5 criteria: Real, Permanent, Quantifiable, Enforceable & Surplus ERCs used for VOCs, NOx, SOx & PM1 EPA has re-designated South Coast as attainment for CO effective June 11, 27. RECLAIM facilities use RTCs for NOx & SOx 4
lbs/day Status of ERC Generation & Use (2-26) 18, 17,398 Total ERCs used is 4 times ERCs generated 15, 12, 9, 6, 4,193 4,67 4,138 3, 1,568 1,983 859 641 792 78 ROG NOX SOX CO PM1 ERCs Generated (lbs/day) ERCs Used (lbs/day) 5
Supply (lbs/day) Cost ($/lbs/day) VOC ERC Supply/Cost Trends (2-26) 35 Supply dropped by 54% from 2 to 26 Cost increased by 136% from 2 to 26 27 3 25 2 15 1 5 24 21 18 15 12 9 6 3 2 21 22 23 24 25 26 ERC Supply (lb/day) ERC Cost ($/lb/day) 6
Supply (lbs/day) Cost ($/lbs/day) 45 4 35 3 25 2 15 1 5 NOx ERC Supply/Cost Trends (2-26) Supply increased by 7% from 2 to 26 Cost increased by 632% from 2 to 26 2 21 22 23 24 25 26 6 5 4 3 2 1 ERC Supply (lb/day) ERC Cost ($/lb/day) 7
Supply (lbs/day) Cost ($/lbs/day) 18 SOx ERC Supply/Cost Trends (2-26) Supply dropped by 52% from 2 to 26 Cost increased by 1241% from 2 to 26 15 15 125 12 1 9 75 6 5 3 25 2 21 22 23 24 25 26 ERC Supply (lb/day) ERC Cost ($/lb/day) 8
Supply (lbs/day) Cost ($/lbs/day) 7 CO ERC Supply/Cost Trends (2-26) Supply dropped by 64% from 2 to 26 Cost increased by 738% from 2 to 26 9 6 75 5 4 3 2 1 6 45 3 15 2 21 22 23 24 25 26 ERC Supply (lb/day) ERC Cost ($/lb/day) 9
Supply dropped by 63% from 2 to 26 Cost increased by 1942% from 2 to 26 1
<2k 6k to <8k 12k to <14k 18k to <2k 24k to <26k 3k to <32k 36k to <38k 42k to <44k 48k to <5k 54k to <56k 6k to <62k Number of NOx Transactions Statewide 26 NOx Transaction Costs 25 2 Median $25, 15 1 5 Mean $75,625 High $41,959 South Coast 27 South Coast All Other Districts Dollars per Ton NOx 11
to <5k 1k to <15k 2k to <25k 3k to <35k 4k to <45k 5k to <55k 6k to <65k 7k to <75k 8k to <85k 9k to <95k Number of VOC Transactions Statewide 26 VOC Transaction Costs 9 8 7 6 5 4 3 2 1 Median $8,219 Mean $8,755 High $64, South Coast 27 South Coast All Other Districts Dollars per Ton VOC 12
<2k 4k to <6k 8k to <1k 12k to <14k 16k to <18k 2k to <22k 24k to <26k 28k to <3k 32k to <34k Number of SOx Transactions Statewide 26 SOx Transaction Costs 25 2 15 1 5 Median $8,188 Mean $47,945 High $273,973 South Coast 27 South Coast All Other Districts Dollars per Ton SOx 13
<5k 5k to <1k 1k to <15k 15k to <2k 2k to <25k 25k to <3k 3k to <35k 35k to <4k 4k to <45k Number of CO Transactions Statewide 26 CO Transaction Costs 12 1 8 6 4 Median $8,837 Mean $14,12 High $41,96 South Coast 27 South Coast All Other Districts 2 Dollars per Ton CO 14
to <15k 3k to <45k 6k to <75k 9k to <15k 12k to <135k 15k to <165k 18k to <195k 21k to <225k 24k to <255k 27k to <285k 3k to <315k 33k to <345k 36k to <375k 39k to <45k 42k to <435k 45k to <465k 48k to <495k 6k to <7k 8k to <9k Number of PM1 Transactions Statewide 26 PM1 Transaction Costs 9 8 7 6 5 4 3 2 1 Median $14,729 Mean $28,733 High $494,151 South Coast 27 South Coast All Other Districts Dollars per Ton PM1 15
ERC/Supply/Demand/Cost Analysis ERC supplies for SOx, VOCs, CO, and PM1 are declining considerably ERC prices for VOCs, CO and particularly SOx and PM1 are increasing considerably NOx ERC supply and price was stable from 2-24 but prices jumped more than 6 fold in 26 compared to the average for 2-24 despite stable supply; 27 NOx prices are 2 % higher than in 26 Large demand for ERCs due to projected growth in the Energy Sector 16
Average ERC Sale Price ($/lb/day) ERC Pricing Trends Average ERC Sale Price (21-27*) $1, $1, $1, Log Scale $1 21 22 23 24 25 26 27* Year *Includes Jan through October CO NOx PM1 ROG SOx 17
26-27 ROG Trades by Investor (Percent of Total Trades) 36% 29% non-investor sales to investor investor sales to investor 11% non-investor sales to non-investor investor sales to noninvestor 24% 18
26-27 ROG Trades by Investor (Percent of Total Quantity) 29% 28% non-investor sales to investor 22% 22% investor sales to investor non-investor sales to non-investor investor sales to noninvestor 19
Efforts Taken by SCAQMD Regarding Availability of ERCs Offset Exemptions for Certain Sources in Rules 134 & 139.1 (i.e. Utility Repowering, APC Systems, Essential Public Services Inter-Pollutant Offset Trades (i.e. SOx for PM1) Option to Opt into RECLAIM for NOx & SOx Sources Option for Power Plants to Access Priority Reserve Bank (Amendments to Rule 139.1) Adopted an NSR Tracking & Equivalency Rule (Adopted Rule 1315) Encourage ERC Generation from Non- Traditional Sources (Mobile/Area) 2