Another Western Cap-and-Trade Domino

Posted by admin on December 14th, 2008 filed in Carbon Trading, Washington Rulemaking
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Yet another domino has fallen in the western governors’ inevitable march to universal cap-and-trade.  Acting in advance of the Western Climate Initiative (WCI) and before the Obama administration has had the opportunity to comment on a national program, Washington Governor Chris Gregoire has added another piece of cap-and-trade legislation to the pot.  A discussion of the proposal can be found in this excellent article by theMarten Law Group.

Why the rush to cap-and-trade?  Gregoire doesn’t even have the cover of a re-election effort as does Gov. Schwarzenegger – she is off a fresh win, bloodied but unbowed, over Dino Rossi in the November contest.  Cap-and-trade efforts are not simple – they require infrastructure, which will likely be provided by signing a contract with a third-party whose employees reside somewhere outside of Washington (can you see the taxpayer dollars going out of state) and will likely result in a program that will be fully formed only to be overridden by the federal program the Obama administration is likely to implement.

A cap-and-trade system for carbon emissions is not as easy as proponents think – they are dreaming of Acid Rain (Clean Air Act – Title IV) successes, when no clear cut technology exists to remove carbon from the utility stream.  Solutions in the carbon cap-and-trade markets will likely be state subsidized energy reduction programs (e.g., turning lights off at the HQ), which will be made doubly hard to account for with the recent economic slowdown (i.e., how much is a real savings and how much is due to reductions in economic activity).

Our Western states should have a place at the federal table and target 2011 implementation of a rational cap-and-trade system.

Oregon EQC Rubber Stamps GHG Reporting Rules

Posted by admin on October 23rd, 2008 filed in Oregon Rulemaking
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This morning the Oregon Environmental Quality Commission (EQC) placed its rubber stamp of approval on premature reporting rules proposed by Oregon DEQ well before receiving conflicting guidance from the Western Climate Initiative.

With the exception of emissions from the state’s wood-fired boilers at pulp/paper/wood products facilities, the Oregon reporting rules provide little information that could not be obtained directly from Oregon’s utilities (gas and electric). For the more than 400 covered facilities, they simply layer on additional reporting requirements and provide yet another opportunity for Oregon business to lose sensitive business information to competitors through inadvertent disclosures.

Oregon’s rush to reporting (without an underlying regulatory structure) makes little sense in today’s business climate.

GAO Report hits EPA Enforcement Efforts

Posted by admin on October 22nd, 2008 filed in GAO Reports
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Yesterday (10/21), the Government Accounting Office (GAO) released a report evaluating the EPA’s enforcement performance over the past 10 years.  The report found that the EPA’s mechanisms for reporting environmental violations overstates the value of penalties by reporting assessed penalties – not the final settlement amounts actually paid.  However, the GAO found that EPA understates the value of penalties by not including amount settled to the states in their calculations.

The report also assesses the EPA’s performance in assessing the amount of injunctive relief obtained and the amount of pollution reduced.  The GAO found a number of inconsistencies in reporting these as well and suggested improvements for increased transparency.

The report can be found here.

Welcome to Endeavour EHS!

Posted by admin on October 20th, 2008 filed in Uncategorized
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Since starting in business in November 2007, we’ve dreamed of having a great website with our own little electronic soapbox – and here we are.  Over the coming months, we hope you’ll visit the blog to learn about the latest in Process Safety Management issues, to see what we’re reading and reviewing, and even to see what we’re listening to.