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I have nearly listened to all the MN House hearings on the Global Warming Mitigation Act of 2007 (H.F. 375). By the end of the week, I hope to have a post that offers more detailed discussion of the hearings around that bill. As of now, the fate of the Mitigation Act looks uncertain but is leaning toward death from what I can tell.

I have had some thoughts and concerns over the course of the 12-15 hours of testimony and debate over this bill that I have been dying to express. They follow.

Much of the testimony on the bill is on section 5 (I'll explain the bill in greater detail in a future post) which requires any new large generation source to offset its GHG emissions. This has a major impact on the proposed Big Stone II plant in South Dakota (to supply electricity to Minnesota) and has therefore drawn a lot of ire from the utilities who have invested in Big Stone II and plan on it to supply future baseload power.

After listening to the same people offer the same testimony in front of two MN House committees (Energy Cmte and the Enviro and Natural Resources Cmte) as well as the Senate, I get testy. The utility testimony from Otter Tail Power offered the same flawed analogy 3 times in exactly the same wording without comment from anyone.

Big Stone II will be the most efficient plant for its time (a super critical pulverized coal), creating just less than 1 ton of carbon dioxide per megawatt hour produced. Otter Tail Power notes that it will be considerably more efficient than existing coal plants and should therefore be considered similiar to a hybrid vehicle. In this analogy their existing plants are essentially less efficient vehicles with greater pollution. They argue that not building Big Stone II, Otter Tail Power will be giving up a hybrid vehicle while it is forced to wait for some future zero emission vehicle. The lesson of the analogy is that such a wait is nonsensical.

This analogy is flawed in several ways. For one thing, Otter Tail gives the impression that they are replacing the old vehicle with the new hybrid, but they are in fact, continuing to run the old vehicles constantly while adding a new hybrid which pollutes a little bit less than the old vehicles, but still greatly adds to emissions. They have suggested that they might be able to retire one of the older plants five years after Big Stone II goes online, but have no obligation to do so.

The Mitigation Act legislation emphatically allows Otter Tail to do what their analogy suggests. They can offset their emissions from Big Stone II by reducing emissions from their older, dirtier, less efficient plants. This would be a tremendous benefit for the environment although such a trade certainly would not help Otter Tail add more baseload to their portfolio.

Otter Tail was not the only to note that plants like Big Stone II are good because they allow us to use coal more efficiently but they never noted that they are really proposing to continue using coal less inefficiently even after building these new facilities. No legislation is preventing them from making their older units more efficient.

Another concern of mine centers from that cold weekend in February when MISO asked everyone to conserve electricity because the grid had very little reserve capacity. This was brought on both due to extremely low wind speeds during high demand and the unplanned outage of a large coal generator (at the Sherco plant). Some Representatives (shockingly, only those who deny climate change science) have hammered on this issue by saying we need more coal generation to back up wind generation.

This is indeed one lesson that can be learned from that weekend. However, distributed generation advocates could also claim that by building massive centralized coal plants, we are setting ourselves up for a fall when one too many of the generators have an unplanned outage. This would also be a flawed lesson but seems just as valid as ignoring that component of the low reserve capacity in order to make a point.

What it comes down to is that a strong grid must have different technologies that compliment each other. As Chairman Hilty brilliantly reminded everyone, no utility is required to build that much wind to satisfy the renewable energy standard (although Xcel is - for reasons that I don't think were every justified). Utilities are required to build generation from a selection of eligible technologies. They have overwhelmingly chosen wind, despite its shortcomings, because it is cheaper. A stronger grid may not come cheap, but can be done by increased reliance on other eligible technologies like solar (though intermittent, tends to peak when needed) and biomass.

My last concern is about the rules of the Chicago Climate Exchange (CCX - wikipedia has the basics). While I like the idea of the climate exchange, I am concerned about what would happen if Minnesota joined it.

The way I understand it, CCX creates a baseline of greenhouse gas (GHG) emissions based on the client's emissions over base years 1998-2003 (or something close to that). It then requires (through force of binding contract) reductions from that baseline by certain percentages each year. Any upward deviation from those reductions requires credits from the exchange (currently selling around $4 per ton of carbon dioxide).

My main concern is with the accounting. If the Metropolitan Council joins CCX, its baseline will include the years before the Hiawatha light rail line began operation. LRT requires massive amounts of electricity, which is especially carbon intensive in this region. How is the Met Council expected to reduce its baseline with a spike on that magnitude?

LRT is a net reducer of GHGs but the Met Council does not get credit for the thousands of cars not driving when people take the train instead. This seems a fundamental flaw in CCX (unless I have misunderstood how it works) because it effectively penalizes the Met Council for reducing emissions via the LRT because the Met Council's baseline does not include emissions from all the private vehicles which are taken off the road.

Is CCX the only option under

Is CCX the only option under discussion?  The way I read the bill, it seems like there are a number of other exchanges that could qualify under the language.  I'm thinking in particular about the forthcoming California program, as well as RGGI/ECR.  Has the testimony focused on CCX to the exclusion of other schemes?

CCX only

Yes, the only discussion I heard off offsets from the utilities was related to CCX. Credits from other states' systems like RGGI would be allowed under section 5, but utilities have avoided discussing it rather than explaining why it would not work or would be too expensive...

I have not yet listened to the Senate testimony entirely though and still have 2 hours from the House

CCX Question

I guess I don't understand how an entity like the Met Council could join the CCX ... it would seem that any participant would have to directly produce greenhouse gases (utility, industrial customer, owner of large fleet of vehicles, etc.). I tried to read more at the CCX site but there wasn't any: "who can participate" nor "how it really works" information. I wouldn't think the Met Council could join and include the Hiawatha Light Rail (because the emissions, ultimately, would come from Xcel Energy plants). I would think they could join and include their fleet of vehicles, but not things that indirectly affect the amount of GHGs.

Thoughts?

I am the CCX Expert

Now that I have put myself out on a limb here, let me say that I'm currently doing my capstone project on the CCX and the U so I have a lot of information.

As it stands now any company or other entity (aka municipalities) can join, but to answer one of the big questions here, yes they have to emit carbon either directly or indirectly (unless they are strictly a mitigation entity). So, if the Met Council were to join, they would average out their direct emissions from 1998-2001 to form their baseline, and then would be required to make reductions off of that.

In addition to direct emissions caused from burning fossil fuels, and I imagine that with the cold winters in Minnesota Met Council uses a lot of carbon to heat their buildings, an entity can opt in many other sources. These include purchased electricity from outside sources (Xcel), public transportation fleets, landfills, small sources, etc.

So, if the light rail line was not built in 2001, and they opted in electricity, that would be a large additional source of electricity that would need to be offset.

The state of New Mexico joined the CCX, as have a number of cities and counties. Although finding information on New Mexico is difficult, the other municipalities only count their own direct and opted in emissions. So no credits would be received for the cars off the streets, but credit is received for the bus fleets that run more efficiently. This may apply to the light rail (i do not know enough about transportation) if it replaced a number of dirty buses. Then again it might not.

It seems to me, from reading the bill, that the "market", which is focused on the power sector, would require those sectors to join the CCX as individual entities if the CCX mechanism is going to be used. To me, within the context of the bill, this does not make much sense. It seems what the bill is advocating is that Minnesota itself create a carbon market for the power sector within the state, a la California style (or REGGI if you consider that any utility within the member states are required to offset emissions), unless Minnesota can mandate that the power companies join CCX, which does not seem likely.

I am happy to answer any further questions about CCX you might have

CCX Cap and Trade vs GHG Cap and Tax

Can you explain the difference between CCX's Cap and Trade versus a green house gas 'Cap and Tax' option? How come this option is not on the table in Minnesota, or is it? From what I have heard of the EU experience with cap and trade, some utilities made windfall profits because of how the exchange was set up.

CCX V GHG Cap and Tax

I'm not sure what you mean by a GHG "Cap and Tax" option. There are generally two options - a carbon tax or a cap and trade program.

Caps are best for making sure GHG emissions do not exceed some arbitrary amount whereas the tax generally discourages carbon emissions by putting a price on it. The higher the price, the fewer the emissions.

For MN, there is no agreement yet as to what would be best but due to people's resistance to that three letter word starting with a 't,' the cap and trade has been assumed to be the more politically feasible.

In Europe, when they set up the cap and trade, they issued too many emissions allowances from what I understand. This made it really easy for everyone to emit lots of GHGs. I don't know who benefited from that, but I think we all lost.

The main issue with CCX is that it is voluntary to join. Despite Bush's support, voluntary approaches will not cut GHGs by the amount needed to slow climate change.

Allotment vs. Auction

As I understand it, the primary problem with Europe's carbon market has been that allowances were issued directly to polluters (that is, utilities) based on historical emissions levels, rather than being auctioned.  It may also be that there were too many issued, but since your baseline was free, there's little incentive to reduce emissions anyway.

Illinois joins CCX

here is a press release that confirms when a state joins the CCX it only covers state run facilities and other 'opt in' options, and not, say the number of private cars a new transportation project takes off the road