March 8 – 9, 2021
TRACK A: ENERGY UTILITY ENVIRONMENT POLICY, REGULATIONS, STRATEGIES & MANAGEMENT
First of EUEC Speaker Series of ten (10) monthly mini-conferences will be held Virtually on March 8 and 9, 2021 at 7 am to 5 pm (Pacific Standard Time). Listed below are the scheduled speakers who will make 20-minute LIVE PowerPoint presentations followed by 10 minutes of Q&A with delegates.
A1.2 Utility Transformations in Climate of Cyber Threats
(7:30 am – 8 am PST)
A1.2 Transformation of Utilities in the Changing Climate of Cyber Threats
With the future being driven by a changing climate, cyber threats and the digitization of everything, utilities must transform. This is because the electric grid was built for a different purpose than what we need today. During this presentation, Terry will focus on what utilities should be doing now to be prepared for tomorrow and how ComEd has done this through innovation and smart investments.
QUESTIONS
1. How have smart grid investments impacted ComEd’s customer costs and electric reliability?
2. What is the greatest challenge ComEd has faced as the utility has worked to modernize the grid?
3. Looking to the future, what additional improvements is ComEd planning to make to the grid?
A1.3 EPA Power Sector Update
(8 am – 8:30 am PST)
A1.3 EPA Power Sector Update
This presentation will provide an overview of EPA’s current rulemaking efforts that affect the power sector, including the Revised Cross-State Air Pollution Rule Update, slated for finalization in mid-March 2021. The presentation will also provide updated information on recent EGU emissions trends and an update on developments in EPA’s modeling capabilities and tools to help sources comply with our regulations, access our data and understand and inform our analyses.
QUESTIONS
1. How have emissions changed in the power sector since 1995?
2. What resources does EPA provide to the public and stakeholders to understand emissions trends?
3. What’s the status of EPA’s effort to update its emissions monitoring and allowance software programs?
A1.6 The Transitioning Electric Power Sector
(9:30 am – 10 am PST)
A1.6 The Transitioning Electric Power Sector
This presentation will overview the many factors influencing the transitioning electric power sector, including clean air issues at the federal and state level (environmental policies and regulations, legislation and judicial decisions), evolving power generation sources and technology advances, fuels issues, energy efficiency, electrification, permitting, and more.
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A2.1 Air Regulatory Challenges Facing the Nation’s Electric Cooperatives
(10 am – 10:30 am PST)
A2.1 Air Regulatory Challenges Facing the Nation's Electric Cooperatives
This session will provide a timely update on the perspectives of not-for-profit rural electric cooperatives on current air regulatory developments including NRECA’s active engagement in the ongoing efforts to implement the Affordable Clean Energy (ACE) Rule and development of a new document, Guidance on Implementing the Affordable Clean Energy Rule: Engineering, Operations and Compliance Considerations.
A2.2 Utility Level Adaptation in a Post-mitigation Environment
(10:30 am – 11 am PST)
A2.2 Utility Level Adaptation in a Post-mitigation Environment
The answer to the policy question “adaptation vs. mitigation” is complex and best framed by the challenges and outcomes associated with each policy action. The move to a federally driven ACE-based framework reflects a return from market driven tools and impact mitigation to the long history of command and control to balance societal needs and cost-effective adaptation at the utility level. This presentation provides: an overview of the issues of mitigation and adaptation, a historic perspective of the evolution of policy in the context of the trend in policy migration from adaptative measures to the aggressive focus on mitigation of utility-related impacts, selected historic policy-level adaptation measures used to meet previous challenges that were managed and a discussion of the emerging challenges and the application of the historic suite of measures. Lastly, this presentation considers the unique issue of sustainability of California’s management of utility-scale measures framed against the federal change in intent, particularly in the context of California industrial rate base erosion.
A2.3 POST ACE Rule Development & Experiences
(11 am – 11:30 am PST)
A2.3 Lessons Learned from Real ACE Rule Compliance Plan Development Experiences
The ACE rule requires states to develop plans to limit CO2 emission levels at coal-fired electric generating units. The plans are based on the evaluation and applicable use of seven EPA-specified candidate heat rate improvement (HRI) measures. States establish unit-specific “standards of performance” that are CO2 emission limitations in the form of CO2 pounds per MWh based on a reduction of “baseline” emissions through the evaluated application of the seven HRI.
States have taken a variety of approaches from submitting data request to utilities, to requesting an ACE compliance plan, or simply taking the “wait and see” approach. Uncertainty is not a desirable word when planning for consistent and confident compliance with regulatory requirements. Taking a proactive approach helps ensure your facility continues to comply with regulations in an ever-changing compliance world while at the same time being responsive to the growing need for operational flexibility in the rapidly changing power market. Compliance flexibility is achievable if one proactively develops a range of baseline, HRI evaluation, and compliance calculation approaches to build the best plan for you and for the state. POWER Engineers has been assisting many facilities to proactively react to the ACE rule and has developed key strategic approaches which have been communicated to multiple agencies. Based on this experience here are six things to consider when developing your ACE compliance plan submittal.
Co-Author: Steve Babler, POWER Engineers
A2.4 Decommissioning & Demolition for Power Plants
(11:30 am – 12 pm PST)
A2.4 Planning and Implementation of Decommissioning & Demolition for Power Plants
With the impending closure of fossil fuel-fired power plants around the country due to cheaper natural gas and environmental regulations, utilities are planning for decommissioning & demolition (D&D) of these plants. The D&D process presents a unique challenge to utilities to conduct the work safely, minimizing cost and concluding with a potentially reusable site.
Planning and implementation of the D&D of these facilities requires upfront planning and coordination with utilities’ operations, environmental, security, safety, management and other stakeholders to successfully complete the project. Upfront identification of permitting issues involving waste disposal, working within a floodplain, demolition permitting, asbestos abatement and isolation of common services at the plant prior to demolition is imperative to manage project expectations and minimize change orders due to technical requirements of any required permits.
This presentation provides a description of some of the key items required to plan and implement D&D process. Several recent project examples will be summarized identifying the actual activities undertaken and the resulting lessons learned.
A2.5 Natural Gas Utility Energy Efficiency Trends
(12 pm – 12:30 pm PST)
A2.5 Natural Gas Utility Energy Efficiency Trends
This session will reveal changes in the overall natural gas energy efficiency industry in the United States over the past ten years (2010-2019) based on data from over 100 natural gas utilities and other efficiency program administrators.
The talk will highlight findings from the ‘2020 State of the Efficiency Program Industry Report’, which presents data on natural gas and electric ratepayer-funded efficiency and conservation programs to provide insights into several industry trends.
Energy efficiency can be a practical resource for individuals, communities, and states to reduce the costs of energy, provide essential energy services, improve energy reliability and resilience, boost the economy, and reduce the environmental footprint of energy use. Many natural gas utility companies have long performing efficiency programs. Based on experience and expertise, and shaped by regulatory oversight and partner engagement, natural gas utilities continue to invest in new strategies to extend energy efficiency options to customers and their communities and to accelerate progress towards realizing a clean energy future.
The report’s findings illustrate utility investment in energy efficiency and demand response programs that work with their customer’s needs of increasing cost savings while reducing emissions and simultaneously advancing other goals, such as better serving low-income communities.
Co-Author: Jayne Piepenburg, Consortium for Energy Efficiency (CEE)
QUESTIONS
1. How are the US Natural Gas Utility programs changing and adapting to the new energy needs?
2. How have the NG utilities been engaged with EE programs?
3. Are there regional differences that vary widely in NG Utility EE program spending?
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A3.1 Subpart YYYY – NESHAP for Stationary Combustion Turbines – Risk and Technology Review Update
(2 pm – 2:30 pm PST)
A3.1 Subpart YYYY – NESHAP for Stationary Combustion Turbines - Risk and Technology Review Update
The Stationary Combustion Turbine National Emissions Standard for Hazardous Air Pollutants (NESHAP), 40 CFR 63, Subpart YYYY was finalized in March 2004. A few months later, Subpart YYYY was “stayed” for several sub-categories and essentially has not be in effect since. Fast forward to 2017 when a consent decree set out a schedule for EPA to complete missed Risk and Technology Reviews (RTRs) for 20 different NESHAP categories. The Stationary Combustion Turbine NESHAP was one of the 20. This presentation will summarize the RTR process, the outcome, the “stay”, the revived delisting petition effort, and the anticipated timing and impact to stationary combustion turbine users.
QUESTIONS
1. Does subpart YYYY apply to my turbine?
2. What is the status of the delist petition?
3. Is the stay still in effect?
A3.2 Redefining Good Neighbor Obligations & Potential Implications
(2:30 pm – 3 pm PST)
A3.2 Redefining Good Neighbor Obligations & Potential Implications
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A3.3 Integrating Renewable Energy Solutions to Reach Business and Sustainability Goals
(3 pm – 3:30 pm PST)
A3.3 Integrating Renewable Energy Solutions to Reach Business and Sustainability Goals
As renewable forms of energy production, like solar, become more widespread and accessible, customers are increasingly exploring these options for their energy mix and implementing sustainability standards that meet energy demands with little environmental impact. However, resource limitations such as financing and/or physical space often impede progress or halt it altogether.
With expertise in the strategic integration of innovative and sustainable energy solutions, Ben Chadwick, Executive Director of Renewables Origination at Constellation, can provide insight on the importance of adopting renewable offerings that meet sustainability benchmarks and sourcing alternative pathways while working around resource constraints.
Ben can share best practices for incorporating renewable solutions in commercial and industrial spaces that reduce overall costs, create price stability, provide resiliency and reduce carbon emissions. Based on his vast experience with renewable projects, Ben can detail how specific, customizable energy solutions can be incorporated through clear, easy-to-implement programs, and how these offerings are addressing changes within the energy industry at large.
QUESTIONS
1. What projects or initiatives is Constellation working on that exemplify the business case for integrating renewable solutions?
2. What trends are you seeing from customers around sustainability? How do you see renewables impacting the energy industry in the next five years?
3. What would you recommend professionals convey to their organizations on the value of adopting renewable solutions?
A3.4 SO2 Data Requirements Rule: It’s Not Over Yet
(3:30 pm – 4 pm PST)
A3.4 The SO2 Data Requirements Rule: It's Not Over Yet
Most initial attainment versus nonattainment designations for the 1-hour SO2 NAAQS have been completed. However, the SO2 Data Requirements Rule (DRR) also includes lesser known ongoing requirements. For areas in which AERMOD modeling served as the basis for initial designations, an annual requirement to report annual actual SO2 emissions for each source is included for reviewing agencies. Based on changes to actual emissions reported by sources, EPA could require re-modeling of an area. This presentation will provide a summary of these ongoing requirements and a discussion of the potential implications for sources previously included in DRR modeling analyses.
A3.5 Consortium of Energy Efficiency
(4:00 pm – 4:30 pm PST)
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A4.1 Appeal of the Ameren Case
(7 am – 7:30 am PST)
A4.1 Appeal of the Ameren Case
The U.S. Environmental Protection Agency (EPA) prevailed in its NSR enforcement action against Ameren Missouri, where the U.S. District Court for the eastern District of Missouri ruled in January 2017 that the Company triggered preconstruction requirements for two projects at the Rush Island Power Plant in the mid-2000s. After a remedy trial in early 2019, the court ordered Ameren to install scrubbers at Rush Island and to install other controls at another power plant, though not at issue in the enforcement action, ostensibly to remedy the environmental effects of “excess emissions” from Rush island. The court has now largely stayed its remedy pending Ameren’s appeal. Briefing in the case will occur in the first quarter of 2020. This presentation will report on this case.
A4.2 Continued Evolution of NSR Reforms Under New Administration
(7:30 am – 8 am PST)
A4.2 The Continued Evolution of NSR Reforms Under the Trump Administration
As the Trump Administration nears the end of it’s first term, EPA continues to push forward a number of reforms to streamline New Source Review procedures and regulatory requirements. This presentation will provide an update to those efforts over the past year and what we might expect in the coming months.
A4.3 A Further Dive into EPA’s Source Specific Actions: Trends
(8 am – 8:30 am PST)
A4.3 A Further Dive into EPA's Source Specific Actions: Trends
This session takes a deeper dive into the current Administration’s approach to New Source Review issues by focusing on recently issued source-specific determinations and what they tell us about the future direction of the NSR program. Already, changes can be seen under Administrator Wheeler that differ from Administrator Pruitt. These trends will be examined for their durability and impact on facility planning for the future.
A4.4 Complying with New CEQ Regulations Using a Modified NEPA Approach
(8:30 am – 9 am PST)
A4.4 Complying with the New CEQ Regulations Using a Modified NEPA Approach
Conducting an EIS review for a power project is often affected by chronic problems with the EIS process that can result in significant delays. The reasons for these problems are inherent in the typical workflow of an EIS project. In its revised NEPA regulations, promulgated on July 15, 2020, the Council of Environmental Quality has required shortened timeframes for EIS projects and more concise documents. Other changes in the CEQ rules enhance the ability to conduct EISs more efficiently. In this presentation the author describes a modified approach for conducting future EISs that provides solutions for the chronic problems with the EIS process and enables compliance with the new CEQ requirements.
AVAILABLE
(9 am – 9:30 am PST)
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A5.1 Race to the Finish! Second Decadal Review for the Regional Haze Rule
(10 am – 10:30 am PST)
A5.1 Race to the Finish! Second Decadal Review for the Regional Haze Rule
Activities involved with the second decadal review for the Regional Haze Rule (RHR) will be result in new State Implementation Plans (SIPs) this summer. By the time of this presentation, each state will likely have conducted the following activities:
a) they determined which sources need to conduct a 4-factor analysis to determine candidate emission controls;
b) they reviewed the 4-factor analyses (possibly with Federal Land Manager review) and worked with the sources involved to finalize these analyses;
c) they proposed the emission controls needed to fulfill the requirements of the Regional Haze Rule; and
d) they drafted their SIPs and provided those for public comment and review.
This presentation will provide advice to affected emission sources regarding how to comment on the draft SIPs. Photochemical grid modeling to determine the expected visibility benefits of candidate control options will be important. Although the modeling alone cannot be used to disqualify control options, it can be used in conjunction with the projected cost to inform the states regarding the cost-benefit effectiveness. Also, the affected sources should review the state’s activities with regard to adjustments to the natural conditions endpoint to assure that this very important endpoint is more realistic than the original endpoint used in the first decadal review.
QUESTIONS
1. What is different about the Second Decadal Review vs. the first one?
Answer: There are some good and bad changes. The good changes are adoption of lessons learned from the first review. They are a) acknowledging that some haze is uncontrollable (e.g., naturally-caused by wildfires and internationally-caused haze); b) a correction in the glide path is needed to accommodate the international haze; c) new modeling tools will help to mitigate conservative features of the tools used earlier; and d) states have more deference in their decision making. One unfortunate change is the omission of a visibility benefit as a mandatory review factor in the decision-making process.
2. What is the role of states for this review?
Answer: The states are given more deference by the 2019 RHR guidance compared to the first decadal review. This remains to be seen with the Biden EPA. Each state may change the URP to natural conditions, and may use different metrics for determining which sources to control.
3. What is the role of visibility modeling?
Answer: Photochemical grid modeling can be used to inform states about the visibility impacts of various sources, as well as revised glidepath goals. Once all states select potential additional controls, modeling can be used to inform the projected haze levels in 2028 relative to URP goals.
A5.2 Litigious Issues for the Regional Haze Second Planning Period
(10:30 am – 11 am PST)
A5.2 Litigious Issues for the Regional Haze Second Planning Period
Drawing upon personal experience in more than a dozen states and company experience in all 50 states, Mr. Jewell will describe several issues that are likely to become key factors in SIP decisions and potential litigation over SIPs related to regional haze second planning period reasonable progress analyses.
A5.3 Lessons Learned from Four Factor Analyses
(11 am – 11:30 am PST)
A5.3 Lessons Learned from Four Factor Analyses
State and local agencies are required to submit implementation plans by mid-2021 to show reasonable progress in meeting natural visibility conditions at Class I areas (i.e., national parks) by 2064. “Round 2” may require power plants to install additional PM, SO2, NOx, VOC, and/or ammonia controls pursuant to a four-factor analysis that is described in EPA’s 2019 guidance. This presentation will provide a walk through the four-factor analysis (costs, timing, and other impacts of controls as well as useful remaining life of the source itself), highlight key aspects of the analysis, provide steps and tactics that will support an optimized assessment of emissions controls, and summarize lessons learned based on work completed to date for facilities across multiple industries and states.
A5.4 Is EPA Making Modeling Easier?
(11:30 am – 12 pm PST)
A5.4 Is EPA Making Modeling Easier?
While EPA has made few changes in modeling guidance over the last year, there are some changes that are helpful to the modeler and the applicant. These will be reviewed. They include the final MERPS document, the definition of ambient air and decisions about modeling updates and special responses that help.
AVAILABLE
(12 pm – 12:30 pm PST)
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A6.1 When Energy Customers Go Off-Grid, Will Utilities be Left in the Dark?
(2 pm – 2:30 pm PST)
A6.1 When Energy Customers Go Off-Grid, Will Utilities be Left in the Dark?
The energy industry is transforming. The pace of change is accelerating faster than most expected. The countdown is on to when the utilities sector reaches three critical milestones – tipping points on a journey to a fundamentally different energy system. Until recently, these milestones were on a journey to a very different energy system predicting vague future events. However, EY together with one of the world’s leading global analyst houses, has calculated the interaction and amplification of 10 convergent technological trends to determine when these tipping points will be reached. During this session, we will review the tipping points for the major US geographies.
A6.2 Taking the CAA into the 21st Century
(2:30 pm – 3 pm PST)
A6.2 Taking the CAA into the 21st Century
Over-regulation and regulation over-complexity is hurting efficiency and hurts U.S. economic competitiveness. This article proposes an alternate solution of simplification and modernization of the CAA. Recommended changes to the CAA are a “New” CAA, which incorporate a new Stationary Source Control (“SSC”) Chapter. This chapter would combine current NAAQS, Toxics, Acid Rain, and Permits. A key feature of the SSC Chapter would be centered on a GHG, Criteria and HAPs Pollutant Cap-and-Trade mechanism:
• Companies would each be responsible for a 1.5% reduction per year for each of the pollutant categories for each year of the 10-year “SSC” chapter authorization period
• GHGs would be added as a regulated pollutant
• Beyond the 1.5% reduction by category, no specific control measure would be required
• Each year companies would submit a report to the state agency regarding their annual emission reduction progress
• A nationwide, market-based Cap-and-Trade system would be established for each of the pollutant categories
• The C/T system would cover emission growth, failure to attain the mandated reductions, and other contingencies
• Companies would also be able to trade and buy interpollutant unless prohibited by the state agency
• The SSC Chapter would have to be reauthorized in 10 years by Congress or the Act’s mandated reductions would continue.
A6.3 California Air Quality Regulations in2021: What You Need to Know
(3 pm – 3:30 pm PST)
A6.3 California Air Quality Regulations in 2021: What You Need to Know
BlueScape will present a 2021 update to companies doing business in California, on how changing air quality regulations will impact their business. The presentation will provide the California air regulatory update by agency jurisdiction (federal EPA, state, and local), program area, and by selected regions and industries. Corporate and facility environmental managers, attorneys, pollution equipment vendors, and consultants will benefit from understanding what regulatory developments have occured in 2020, and will learn about what is coming to be prepared for 2021.
A6.4 Don’t Fear the Reaper: Marrying Renewable Energy and Superfund Sites
(3:30 pm – 4 pm PST)
A6.4 Don't Fear the Reaper: Marrying Renewable Energy and Superfund Sites
Superfund is universally recognized curse word even for non-environmental experts. For many, the presence or even just the fear of Superfund liability will not just chill but completely kill a potential real estate transaction or development project. This has resulted in large swaths of land across the country sitting not just polluted, but idled with few prospects for economic revitalization as some potentially responsible parties lack the funds to sustain a prolonged remediation. The massive expansion of renewable energy and battery storage projects presents numerous opportunities to find low-cost sites with sufficient acreage to deploy solar or wind farms. Although Superfund can impose strict liability on current site owners and tenants for pollution resulting from legacy operations, there are numerous legal protections available to renewable energy developers that can make a Superfund site more attractive. Developers have the option of obtaining bona fide prospective purchaser protection available under the Superfund statute. In addition, Congress recently clarified the protections available to tenants under the 2018 Build Act. Whether considering an outright purchase of a contaminated property or just a lease, a renewable energy developer’s protections can also be enhanced via contractual safeguards and risk mitigation with respect to structuring the transaction. Depending on the facts of a specific site, the environmental risks can be managed.
A6.5 LCFS Verification & Validation
(4 pm – 4:30 pm PST)
A6.5 LCFS Verification & Validation
On January 4, 2019, the amended Low Carbon Fuel Standard (“LCFS”) regulation, published by California Air Resource Board (“CARB”), came into effect. This regulation outlined a new validation and verification requirement for fuel pathway holders and fuel reporting entities. Weaver is an accredited validation and verification body by CARB.
B1.1 EPA Signs New Rule Affecting Stationary
In 2019, the DC Circuit dealt a major setback to EPA’s efforts to resolve and close-out interstate air quality issues under the 2008 ozone standard without further NOx reductions from power plants. In doing so, the court may have breathed new life into state petitions to EPA demanding more stringent NOx limits for plants in numerous states. This presentation will review these recent decisions, the state petitions seeking NOx reductions in downwind states, and discuss the potential implications for industry.
A3
NSR | Permits | Compliance | Regulations
Permitting Risks in Carbon Capture and Sequestration (CCS) Projects (INVITED)
A2.2 Managing Permitting Risks in Carbon Capture and Sequestration (CCS) Projects
Matthew Dobbins – Vinson & Elkins
Despite promulgating rules for carbon capture and sequestration facilities in 2010, only a handful of states have obtained primacy from the U.S. Environmental Protection Agency to issue Class VI permit’s under the federal Safe Drinking Water Act’s Underground Injection Control Program. EPA as the permitting authority raises a number of permitting risks, from delays to additional opportunities for third parties to challenge permits. EPA as the permitting authority also the potential to trigger additional federal environmental reviews that otherwise would not be required if the state agency issued the permit. Moreover, even with several states (e.g., Wyoming, North Dakota) obtaining primacy, the differing approaches taken by these states raise potential permitting risks and project constraints. This presentation will navigate the various federal and state permitting issues that can arise when developing CCS facilities, and identify opportunities to decrease regulatory risks and spur project development.
Embracing Digital Transformation for Proactive Environmental Compliance (INVITED)
A3.4 Embracing Digital Transformation for Proactive Environmental Compliance
The journey to Proactive Environmental Compliance maturity is often riddled by uncertainty, but it doesn’t have to be. After this session with Encamp’s CEO and Co-founder, Luke Jacobs, to enterprises and leading EHS teams participating in the event will gain actionable insights on how to transform their environmental compliance programs with digital technology and expert support:
- Building a strong foundation for compliance data
- Maintaining continuous data collection
- Automating regulatory updates and notifications
- Automating compliance reporting
- Building a unified data-system across all their compliance program areas
3 Short Questions:
- What steps should you take?
- Which program area should you focus on?
- How do I get buy-in from leadership?
Natural Gas Utilities In A Clean Energy Future (INVITED)
A1.3 The Role For Natural Gas Utilities In A Clean Energy Future
Sapna Gheewala – AGA
The presentation will address a pathway forward for natural gas, which maximizes environmental benefits and supports renewable resources to realize emissions reductions in a low carbon future. Energy efficiency, RNG, and Hydrogen are featured tools to leverage our existing infrastructure into the future of net-zero emissions.
NSR Issues and Recent Developments (INVITED)
A3.1 NSR Issues and Recent Developments
Gurinder Saini – RTP
New Source Review (NSR) is one of the most contentious Clean Air Act program and has been subject of several recent developments. These developments include administration changes that affected or will affect program elements and court challenges. In addition, there are efforts at State level to address program implementation. NSR permitting (which includes nonattainment major NSR permitting, Prevention of Significant Deterioration (PSD) permitting, and minor NSR permitting) continues to be affected by U.S. Environmental Protection Agency (EPA) policy and court decisions regarding implementation of the programs, and other issues. With the new administration, several major NSR policy shifts are likely to come into the picture. I plan to discuss major developments in NSR, point out ways that facility operations could be affected by these developments, indicate what lay ahead, and identify issues that remain unsettled.