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The Magazine for Environmental Managers July 2016

Reducing Carbon from Power Generation

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Table of Contents

em • The Magazine for Environmental Managers • A&WMA • July 2016

Carbon Trading Underthe Clean Power Planby Ashley Lawson, Centerfor Climate and EnergySolutions

The Nuclear Option for Meeting the GrandChallenges of the 21st Centuryby Andrew Sowder, ElectricPower Research Institute

Going all the Way: Options and Innovationto Solve Climate Changeby Armond Cohen, CleanAir Task Force

The Case for Science-Based Emissions Targetsby Mark Chadwick, Carbon Clear; and AliciaGodlove, FirstCarbon SolutionsAn overview of the movement toward setting science-based targets for the reduction of carbondioxide emissions.

Highlights from the Coordinating ResearchCouncil’s 2016 Air Quality Research NeedsWorkshop: Top 11 Research Needsby Susan Collet, Toyota; Randall Guensler, GeorgiaInstitute of Technology; Megan Beardsley and RohitMathur, U.S. Environmental Protection Agency; andShaokai Gao, Phillips 66 Research Center

Features Other Features

Columns

Asian Connections: City CertificationProgram: An Innovative Approachto Urban Air Qualityby Robyn Garner

Association News

Message from the President: The Freedom of the Neutral Forumby Brad Waldron

Departments

Washington Report

News Focus

Canadian Report

Calendar of Events

JA&WMA Table of Contents Vol. 66, No. 7

Reducing Carbon from Power GenerationThis issue of EM considers aspects of interim and long-term strategies for reducing and eventually eliminating the major contribution of power generation to U.S. and global carbon (carbon dioxide equivalent) emissions. The power generationsector is the largest contributor to carbon emissions in the United States and globally.

Don't Miss…

Issue Coordinator John Bachmann provides a

unique take on this month's issue topic with an

EM exclusive music video editorial. The video

is available via the A&WMA App or online at

www.awma.org/publications/em-magazine.

BRIDGINGENVIRONMENT, ENERGY & HEALTH

A&WMA 110th Annual Conference & Exhibition

June 5-8, 2017Pittsburgh

PA

The connections that link environment, energy and healthare as historic and direct as the 446 bridges that crisscrossPittsburgh, the city with more bridges than anywhereelse in the country. The 2017 Air & Waste ManagementAssociation’s Annual Conference & Exhibition (ACE) willexamine how leaders in industry, government, academia,and non-governmental citizen groups work together toimprove community health and protect the environment.The Pittsburgh area is a great example of the amazingimprovements in environmental quality and health that canoccur when these groups are bridged together. Industryin this region has evolved to a diverse portfolio of energysuppliers, manufacturing plants, medical facilities andtechnology companies that are harnessing energy insustainable and innovative ways.

Come join us as we advance the science of air andwaste management and recognize the many bridges to environment, energy and health.

A&WMA's 110th AnnnualConference & Exhibition

JUNE 5-8, 2017Pittsburgh, Pennsylvania

Bridging Environment, Energy & Health

SaveTheDate

Message from the President


Each year, as the Fourth of July rolls past and fireworksburst in the sky, I can’t help but think about everything thatgoes along with that—emissions, noise, and waste. Ironically,the celebration of America’s Independence Day includes anumber of the things most of us are trained to prevent.

That said, it is a celebration of the freedom sought by theearly settlers who moved here and the resulting conflict withthose who wanted control. My mother’s ancestors first cameto this land on the Mayflower (my first name may be a hintfor history scholars) seeking freedom from persecution. Myfather’s ancestors came here to profit as mercenaries protectingcolonists and trade routes back to Europe from the colonies.Ever since then, our country has worked to preserve the freedom we have come to enjoy, oftentimes with conflict andforce. Both are in our nature, handed down for generations.

Our experience at A&WMA’s Annual Conference embodiesthat freedom and that conflict. Walking the halls, sitting in thesession rooms, mingling at the networking events, everywherethere is intelligent discourse. Each attendee is free to presentand defend their point of view on a given matter. Another attendee provides an equally well-formed rebuttal or counter-point. It is rare for those discussions to become heated, but itis common for each participant to walk away with a new perspective or understanding of a particular issue. A&WMAembraces the freedom of our members to develop and formtheir own opinions and to respectfully interact with otherswho may feel differently. We support the freedom and the conflict.

Over the years, within the highest levels of A&WMA, therehave been ongoing debates about whether or not the Associ-ation should play a political role and take formal positions onmatters. While it is likely unfair for me to use this column as a podium, I’m going to enjoy a moment as President tospeak without immediate opposition. I have been consistentlyagainst this organization taking a hard stance on any matteror becoming involved politically. And the reason is simple: intelligent debate, investigation, and dialogue are the greatestmechanisms of learning.

Honestly, I can’t remember the last time I learned somethingby listening to someone repeat an opinion to me which I share.Learning is based on broadening horizons and consideringnew ideas. Long before A&WMA, the very foundations ofscience were based on rhetoric between great minds. Silly asit sounds, I truly believe that our organization embodies thattoday with the strength of our neutral forum and the abilityto interact and learn from one another.

The concepts of freedom and conflict are built into each ofus. We may not embrace their positive attributes as often aswe can, but we shouldn’t shy away from them or forget thatthey exist. The Annual Conference was a great time to involveourselves in such discussions and learning opportunities. Asmembers, we owe it to ourselves, and all of those with whomwe may not necessarily see eye to eye, to share our experi-ences. Who knows what we may learn. em

The Freedomof the NeutralForumby Brad Waldron » [email protected]

Cover Story by John Bachmann


“The future of the utility industry is bright.” Elon Musk, 2015

“… I gotta wear shades.” Timbuk 3

Reducing Carbon from Power Generation

This issue of EM considers aspects of interim and long-termstrategies for reducing and eventually eliminating the majorcontribution of power generation to U.S. and global carbon(carbon dioxide equivalent) emissions. Focusing on this sectoris appropriate in part because power generation is the largestcontributor to carbon emissions in the United States andglobally. As Elon Musk, co-founder, CEO, and product architectof Tesla Motors, notes, low carbon power also is essential forenabling low carbon electric vehicles, which would result inincreased electricity demand.

While uncertainties exist in predicting the timing and extent ofserious effects such as sea-level rise, melting glaciers, alteredfood and water supply, and weather extremes, the DecemberParis Agreement reflects an unprecedented global consensusto take action to mitigate them.1 On April 22, 175 nationssigned the Paris Agreement, and must now take steps to ratify the treaty as well as to flesh out and actually implementtheir first “nationally determined contributions” (NDC) for reducing carbon. Here, we take a look at the near- and long-term challenges and opportunities for meeting these nationaland international commitments as they relate to the powersector, as well as for meeting the far more difficult goals oflimiting temperature increases to “well below” 2 oC, with efforts to limit it to 1.5 oC.

The U.S. Environmental Protection Agency’s Clean PowerPlan (CPP)2 represents a major component of the U.S. NDCreduction target for 2025. Following the U.S. Supreme Court stay in February, the D.C. Circuit Court of Appeals hasannounced that the full court will review the consolidated

challenges to the rule, scheduling oral arguments for the endof September. Their ruling on the case, much less any subse-quent consideration by the Supreme Court, is highly unlikelythis year.

While developments this fall will play a major part in the ultimate fate of the CPP and the U.S. NDC, it is worth notingthe recently updated Energy Information Administration (EIA)forecasts, which assume the plan is implemented.3 Figure 1shows a breakdown of past and forecast sources of electricpower with and without the CPP. The CPP would add to thecontinuing increase in renewable energy and gas at the expense of a further reduction in coal use. As shown in Figure 2, carbon dioxide emissions from the sector havebeen decreasing since 2005, but with no CPP, would drift up after 2020 to about 19 percent below 2005 levels. TheCPP would result in a 35-percent reduction from 2005 by2030, with little change thereafter.

Combined with other initiatives, including greenhouse gasrules for mobile sources and additional methane reductions,implementation of the full suite of U.S. carbon rules wouldproduce impressive reductions over the next 20 years. Asnoted by our authors this month, however, they are notenough, either to meet the initial U.S. NDC or to effect thekind of continued emissions reductions the United Statesneeds to contribute for the world to come close to avoiding a 2 oC increase in this century.

The three articles that follow provide an overview of strategiesand technologies that would be needed now and for the rest



Figure 1: The Clean Power Plan (CPP) would accelerate the shift to lower-carbon options for electricity generation, led by growth in renewables and gas-fired generation.3 This EIA 2016 reference case assumes the CPP under a mass-basedregional trading option and maintaining current nuclear capacity through the period. Coal generation declines by 32 percent under the CPP.

Source: EIA, Annual Energy Outlook 2016



of the century to approach the ambitions of the Paris Agree-ment. All three agree that a central requirement for movingforward is to put a price on carbon. Ashley Lawson, a Senior Fellow at the Center for Climate and Energy Solutions,summarizes the economic benefits of carbon trading and argues that the power sector will be best position for a carbon-constrained future if it embraces carbon pricing in the nearterm. Despite the success of the acid rain program, in recentyears the term “cap-and-trade” has taken on a sinister tonefor some. By contrast, Lawson draws on analyses showingthat the widest possible trading under the CPP results in least-cost as well as providing incentives for improved technologiesthat reduce carbon in the future. Some economists favor acarbon tax. That would require legislation, which was not anoption for the CPP. You can examine short summaries of themerits of the two carbon pricing mechanisms elsewhere.4,5

In making the case for maintaining a significant contributionfrom nuclear power in a carbon constrained future, AndrewSowder, a Principal Technical Leader in Advanced NuclearTechnology for the Electric Power Research Institute, also supports a price on carbon. He cautions that unless the

licenses for much of the current fleet are renewed, the nucleargeneration levels assumed in Figure 2 cannot be maintainedafter 2030. He outlines the need for maintaining and expandinga significant zero carbon base-load capacity to counterbalancethe increased use of intermittent renewable energy and dis-tributed generation as coal and gas are phased out. Sowderrecognizes economic, waste, and security concerns about nuclear power, providing links to expanded discussions, andalso provides a useful primer on current and advanced nuclear generation design concepts that provide increased efficiency, safety, security, and economics.

Armond Cohen, Executive Director of the Clean Air TaskForce, examines the big picture. He provides an overview ofthe need for prompt action as well as alternative approachesto reduce carbon in the power sector in the long run. High-lighting the staggering challenge of transforming a still rapidlygrowing global energy system to substantially curtail carbonemissions, he outlines strategies for four major technologygroups: energy efficiency, carbon capture and storage, renewables, and nuclear. Ultimately, he concludes that wemust have a diverse approach that avoids overreliance on

Figure 2: Electric sector CO2 emissions forecast.3 Carbon emissions from the sector declined after 2009 largely due tolower gas prices, as well as an increase renewable generation. The CPP would continue the decline through 2030.

Source: EIA, Annual Energy Outlook 2016

All three authors agree that a central

requirement for moving forward is

to put a price on carbon.



John Bachmann is principal of Vision Air Consulting, LLC, and a long-time member of EM’s Editorial Advisory Committee (EAC).Until 2007, Bachmann was associate director for science/policy and new programs for the U.S. Environmental Protection Agency’s(EPA) air office.

any single approach. Further, because all of these technolo-gies have significant limitations that must be overcome, heargues that relentless innovation is crucial to meeting thelong-term goals for climate programs.

A recent essay in Foreign Affairs expands on Cohen’s lattertheme.6 A price on carbon would certainly spur more privatesector investment, but U.S. leadership in both basic researchand development and public/private partnerships is neededto demonstrate that the new technologies work in the realworld. The Paris meeting featured two relevant developments:(1) Bill Gates introduced the Breakthrough Energy Coalition,7

a group of more than 20 billionaires who have agreed to invest in innovative clean energy to accelerate progress; and(2) President Obama announced Mission Innovation,8 anagreement among 20 countries—including the United States,China, and India—to double public funding for clean energyresearch and development to $20 billion annually by 2020.

The actions taken over the next decade will go a long way indetermining how bright the future for climate is for the restof the century. For a somewhat different take, take a look atthe accompanying video online at www.awma.org/publications/em-magazine. em

References1. Insights from COP-21; EM, May 2016.2. The Clean Power Pause; EM, January/February 2016. 3. Annual Energy Outlook 2016 Early Release: Annotated Summary of Two Cases; Energy Information Administration, May 17, 2016; available online at

http://www.eia.gov/forecasts/aeo/er/pdf/ 0383er%282016%29.pdf.4. Lewis, B.; Twidale, S. Carbon tax or trade? Debate loses steam as world embraces both; Reuters, U.S. Edition, May 2015; available online at

http://www.reuters.com/article/eu-carbon-tax-idUSL5N0YF0HU20150527.5. Gollier, C.; Tirole, J. Making climate agreements work; The Economist, June 2015; available online at

http://www.economist.com/blogs/freeexchange/2015/06/united-nations-climate-conference.6. Sivaram, V.; Norris, T. The Clean Energy Revolution. Fighting Climate Change with Innovation; Foreign Affairs, May/June, 2016; available online at

https://www.foreignaffairs.com/articles/united-states/2016-04-18/clean-energy-revolution.7. Breakthough Energy Coalition. See http://www.breakthroughenergycoalition.com/en/index.html.8. Mission Innovation: Accelerating the Clean Energy Revolution. See http://mission-innovation.net.

Photo courtesy of Apache Corp

Sessions include:

• Air Toxic Measurements/Field Studies• PM Measurements/Speciation• Advanced Optical Monitoring• Air Sensor Measurements• Near Road Monitoring• Greenhouse Gas/Criteria Pollutants• Vapor Intrusion• Source Measurements• Oil and Gas Measurements

Four key industry partners . . . one encompassing event

Power Plant Pollutant Control and Carbon Management “MEGA” SymposiumAugust 16-18, 2016 • Marriott Waterfront, Baltimore, MDCo-sponsored by: The Electric Power Research Institute (EPRI), the U.S. Environmental Protection Agency (EPA), the U.S. Department of Energy (DOE), and the Air & Waste Management Association (A&WMA)

Platform and poster presentations cover successes and challenges of complying with regulations for fossil-fueled electric generating units and provide technology options for compliance with the Clean Power Plan. Topics include:

Don’t miss the Air Pollution Control Fundamentals Workshop on Monday, Aug. 15 and Opening Session “The Role for Coal Research in Today’s and Tomorrow’s Electric Generation Environment” by Shannon Angielski, Executive Director, CURC, on Tuesday.

Register now and view the Preliminary Program online at http://megasymposium.org.

• SO2 Capture Processes • CO2 and NOx Reduction

• MATS Compliance• Integrated Environmental Controls

• ELG Technologies • Particulate Controls

Carbon Trading Under the Clean Power Plan by Ashley Lawson


This article summarizes the economic benefits of carbon trading.

Carbon TradingUnder the Clean Power Plan



The Clean Power Plan gives states the option to include carbon trading provisions in their state implementation plans.This carbon trading can come in many “flavors”—mass-based,rate-based, intrastate, interstate, or even economy-wide. Regulators are still examining this complex landscape of options to understand the compliance approach that minimizesconsumer costs while delivering the required emission reduc-tions. This article summarizes the economic benefits of carbontrading, examines key differences between rate-based andmass-based compliance, and argues that the electricity sectorwill be best positioned for a carbon-constrained future if itembraces carbon pricing in the near-term.

Leading economists say that the most efficient, cost-effectiveway to reduce climate-altering emissions is to put a price oncarbon through a cap-and-trade program, a carbon tax, orsome other method. A price on carbon means we’re accuratelyreflecting the real costs of carbon emissions—the climatechange impacts such as more extreme heat waves, more intense downpours, sea level rise, and ocean acidification thatwe’re already experiencing. Give companies a clear economicincentive to cut their emissions, and they’ll find the cheapestway to do it.

The Clean Power Plan recognizes the benefits of carbon pricingand provides multiple pathways for states to use it in theirimplementation plans, but the carbon trading options havereceived most of the attention. Although a U.S. SupremeCourt stay of the plan means that immediate compliancedeadlines will not be enforced, many states, utilities, regula-tors, and others continue to examine the potential for carbontrading. The Center for Climate and Energy Solutions (C2ES)is facilitating these conversations so that states can be pre-pared to design smart implementation plans under the CleanPower Plan—or whatever power sector carbon regulation isultimately enforced.

Carbon Pricing under the Clean Power PlanThe Clean Power Plan’s approach to carbon pricing is consistentwith the role that environmental markets play in other U.S.Clean Air Act regulations. The most notable example is thesulfur dioxide cap-and-trade program established in Title IVof the Clean Air Act. This program created a market for theright to emit sulfur dioxide, the main cause of acid rain. Wedon’t hear much about acid rain today because power plantssignificantly cut sulfur dioxide emissions through a cap-and-trade program created by a bipartisan Congress. Emissions were

Initial Emissions Total = 30 tons Allowable Limit (Cap) Cap Total = 15 tons

Potential transfer of two allowances at $80-$120 each.

Figure 1: EPA figure showing hypothetical environmental regulation where carbon trading lowers overall compliancecosts compared to a command-and-control regulation.



reduced about twice as fast as predicted—and at a fraction ofthe expected cost.1

A pollutant like carbon dioxide is well suited to a market-based regulation because the environmental harm (namely,climate change) depends upon the total global concentrationand not its specific location of origin. The environmental benefitfrom preventing the emission of one ton of carbon dioxide isidentical, regardless of where the prevention (abatement) occurs. However, the economic cost varies considerably fromone source to another. When the costs of abatement vary bya large degree—as is the case for the U.S. power sector—thenthere can be large economic benefits to trading. A sourcethat has low-cost abatement potential can “overcomply,” thusallowing another source to “undercomply.” The second source would pay the first source for the extra reductions itachieves, up to the point where the second source couldachieve the same reductions at the same price.

The U.S. Environmental Protection Agency (EPA) has constructed a useful, simplified illustration to demonstrate theeconomic benefits of trading (see Figure 1).2 In this example,there are three sources that initially emit 10 tons of pollutanteach, for a total of 30 tons of emissions. A cap is then set at15 tons overall—a 50 percent cut. Under a traditional command-and-control regulation, each source would need to reduce itsemissions to 5 tons. The cost of compliance would equal eachsource’s abatement cost times the number of tons it reduces.For a command-and-control regulation in this example, thiswould be $1,500, or ($100/ton * 5 tons) + ($80/ton * 5 tons)+ ($120/ton * 5 tons).

When trading is allowed, the source with the lowest abatementcost can reduce more and trade those reductions to the sourcewith higher abatement cost. As shown in the figure, Plant Bcan reduce its emissions by 7 tons while Plant C has to reduceits emissions by 3 tons to bring the whole sector into compli-ance. The overall cost of compliance when trading is allowedbecomes $1,420, or ($100/ton * 5 tons) + ($80/ton * 7 tons)+ ($120/ton * 3 tons). In this simplified example, trading lowers the overall compliance costs by 5 percent.

In the Clean Power Plan, unlike this example, tradable creditscan be given to non-emitting electricity generators and demand-side energy efficiency projects, in recognition of the reductionsthey provide to the electricity system overall. These sourcesoften have costs much lower than heat-rate improvements orother on-site reduction options, so they are expected to playa major role in Clean Power Plan compliance where trading is allowed.

Economic IncentivesPricing CarbonBy limiting the amount of carbon dioxide that can be emitted,in either absolute terms (mass-based trading) or intensity terms(rate-based trading), the Clean Power Plan allows the marketto form a price on carbon. This price incentivizes a sector-wideswitch to lower-emitting sources in two distinct ways.

First, the electricity from high-emitting fuels becomes moreexpensive and, therefore, less profitable. The exact mechanismby which this economic incentive changes the amount ofelectricity generated from high-emitting fuels depends uponthe structure of the electricity market. But in both competitiveand regulated markets, the end result is that existing high-emitting generating units are run less.

Second, a price on carbon makes low-emitting fuels moreprofitable. Non-emitting sources (e.g., renewable, hydro, andnuclear) will see an increased profit margin when a carbonprice is introduced. Non-emitting sources are already cheaperthan fossil fuel-fired sources to operate because their fuelcosts are lower, so the carbon price doesn’t affect how muchthe existing non-emitting sources generate. It does, however,encourage more of these generators to be built, so that thegeneration from these sources increases over time. The sameincentive applies, though to a lesser degree, to efficient natural gas-fired units.

The Clean Power Plan also allows states to implement a carbontax on power plants if they so choose. A tax puts a price oncarbon, so the same electricity market changes occur, as described above. However, since emitters could theoreticallypay the tax to be in compliance with their state Clean PowerPlan rules, yet still exceed the limits set in the Clean PowerPlan, EPA requires a back-up plan that would ensure theemissions limits are met. States overall appear to be leaningtoward carbon trading programs to price carbon rather thanuse a carbon tax for Clean Power Plan compliance.

Experience on the ground shows that the economic incentivesfrom carbon pricing work. Carbon trading has been put inplace in jurisdictions around the world, and through morethan 10 years of experience, we have numerous examples of its success. In the United States, 10 states that are home toa quarter of the population currently have a price on carbon.Emissions from sources covered by California’s cap-and-tradeprogram were 3 percent lower in 2014 than they were in2012, the year before the program started.3 The nine North-east and Mid-Atlantic states in the Regional Greenhouse GasInitiative (RGGI), another cap-and-trade program, have cut



carbon emissions from power plants by 40 percent since 2005.These reductions are more than what would be expectedthrough other market and policy drivers (e.g., low natural gasprices, renewable portfolio standards) alone.4

Rate vs. MassAs states examine compliance options under the Clean PowerPlan, a central question is whether to implement a rate-basedstandard or a mass-based standard. In our assessment,5 bothapproaches incentivize energy efficiency and new non-emittingelectricity generation through the creation of a carbon pricethat increases the cost of generation from high-emittingsources and improves the economics of new non-emittingsources. The details regarding emissions reductions and lossof electricity market share for existing high-emitting sourceswill vary depending on the existing electricity portfolio.

Models find only small differences in the environmental outcome of the two approaches, supporting the idea that theyprovide the same incentives. For example, the Center forStrategic & International Studies and Rhodium Group foundthat a scenario of rate-based compliance reduced cumulative2020–2030 power sector emissions by 4,415 million tons(Mt) from a reference case, while a mass-based compliancescenario saw 4,285 Mt of cumulative reductions.6

Auction RevenueThe Clean Power Plan allows states with a mass-based plan todetermine the method used to distribute (allocate) allowancesto the generating units that need them for compliance. Themethod of allocation does not change the environmental outcome, because the number of allowances in circulation isdetermined by the Clean Power Plan, and every ton of emis-sions must be covered by an allowance to show compliance.One option is to give all or a portion for free to generatingunits or other entities in the power sector such as distributionutilities. This approach minimizes costs to consumers becausegenerating units only have to pay to cover emissions in excess of their allocation. Another approach is auctioning:The state sells allowances, and generating units buy theamount they need to cover their emissions.

Auctioning allowances instead of giving them away givescash-strapped states revenue they can use in a wide varietyof ways to help achieve the goal of reducing emissions. A statecould use auction revenue to directly subsidize innovative

technologies like battery storage, microgrids, or carbon captureand storage. It could return the revenue to customers to reduce inequities, for example, through bill rebates for low-income consumers who spend a larger share of their budgetson necessities like electricity. The revenue could even offsetstate taxes. Research into the pros and cons of each choice is widely available, and the choice is ultimately a political one.State legislatures would likely want to weigh in on the appro-priate use of auction revenue. In some cases, the regulatoryagency tasked with implementing the Clean Power Plan mayalso need legislative authority to conduct allowance auctionsat all.

The 10 states with carbon cap-and-trade programs today alluse auctions as the primary means of allocating allowances,but they have made different choices about how to spend therevenue. In California, state case law dictates that all revenuesbe invested in projects that reduce greenhouse emissions,and a state law specifies that a quarter of state revenue mustbe directed to disadvantaged communities. For example,more than $20 million will go to install solar panels in disad-vantaged neighborhoods for free, saving each household asmuch as $1,000 a year in energy costs.7 The states in RGGIspend the large majority of their $1 billion in auction revenueon energy efficiency programs8—upgrading appliances, lighting,insulation, and heating and air conditioning units. Connecticutuses a portion of its auction revenue to fund its Green Bank,an effort that leverages public funds to encourage private investment in clean technologies in the state.

Benefits of Broad Interstate TradingThe economic benefits of trading are greatest when emittershave very different costs for reducing emissions. In carbonmarkets, bigger is generally better. A national trading marketwould be expected to have greater economic benefit thanmultiple regional trading markets, and a regional trading

Experience on the ground

shows that the economic incen-

tives from carbon pricing work.



market would be better than single-state markets. Moreover,a uniform national trading program would remove some ofthe concerns that stakeholders have about individual stateprograms, namely leakage. Leakage is when a source ofemissions moves from a regulated jurisdiction to an unregu-lated jurisdiction to avoid paying the cost of emissions, resultingin lowered environmental benefits of the program. If all statesare in a single market with a uniform carbon price, the risk of leakage between states is very small.

The Clean Power Plan does not require a single nationwidemarket, though it does offer a streamlined path for states tocollaboratively develop one via trading-ready state plans. Theuse of common definitions, measurement and verificationprocesses, and compatible tracking systems allows companies in trading-ready states to trade credits or allowances acrossborders.

In EPA’s analysis of a mass-based approach,9 it found that carbon allowance prices would range from $0/ton to $26/ton(all in nominal 2011 dollars) in the year 2030. This modelscenario shows there are likely large economic benefits to berealized if states all implement trading-ready plans under theClean Power Plan and allow their affected units to buy (orsell) tradable units.

Costs in the EPA projections varied within geographic regions,showing the potential value of nationwide trading. For example,seven states in the model had allowance prices of $0/ton,and they were in the Northeast and Northwest. Eight statesin the model had allowance prices of $20/ton or greater, andthey were in the West and Midwest. A linked market of trading-ready state plans in each of these regions would allow the fulleconomic benefit of trading to be realized. A state with a lowallowance price in the model is likely to have units that couldcheaply overcomply. A state with a high price, in contrast, islikely to have units that would prefer to buy allowances orcredits on the market.

The economic benefits for the buyer are clear—it can complywith the rule at a lower cost by purchasing an allowance orcredit on the market instead of undertaking expensive

reductions. But the seller also benefits because the “extra” reduction that it generates is paid for by the buyer. Like anymarket, the actual price will be influenced by a number ofnon-fundamental factors, but in theory, the seller’s extra reductions would be fully compensated for by the carbonprice. Society overall benefits because the buyer’s more expensive reductions would not be required. This keeps theoverall costs of compliance down, just as in the simplified example discussed above.

States have the option of implementing a “trading-ready”plan that would give their affected units the flexibility of participating in a market. States also have the option of implementing rate- or mass-based approaches. Under theClean Power Plan, trading between these two types of plansis not allowed. Based on our conversations with stakeholdersacross the country, it appears likely that most states prefer atrading-ready plan, but they are split on their preference between rate and mass. Given this, it appears unlikely thatstates will implement plans that would result in a single national trading program.

A likely scenario for Clean Power Plan implementation, basedon the final rule as it is today, is a patchwork of state plans, orat the very least, one set of mass-based trading-ready plansand one set of rate-based trading-ready plans. This scenario is sub-optimal in the sense that overall costs to U.S. consumerswould likely be higher than under a scenario of a single trading-ready approach implemented in all states. But the CleanPower Plan encourages states to do what they do best—innovate—and more examples of state success on the groundcan inform a potential national approach to pricing carbon in the future.

Consideration of Other PoliciesThe Clean Power Plan is just one regulation in a large universeof policies and rules aimed at reducing greenhouse gas emissions. It is useful to consider not just how carbon tradingunder the Clean Power Plan can lower compliance costs, butalso how it relates to other (existing and future) policies.

At the local level, cities and counties across the country are

Promoting carbon pricing in the

near term is a wise long-term strategy

for electricity companies.



taking action to reduce greenhouse gas emissions. City effortsto promote energy efficiency in residential and commercialbuildings and to boost renewable energy purchases have direct implications for future trajectories of electricity sectoremissions. The trading mechanisms included in the Clean PowerPlan could become a tool for advancing these city effortswhile simultaneously bringing utilities into compliance.

Taking the long-term view, policies to mitigate climate changewill be necessary moving forward. The United States hascommitted to reduce national greenhouse gas emissions 26–28 percent below 2005 levels by 2025 under the inter-national Paris Agreement agreed to at the COP-21 meetingin December 2015. The strong support that U.S. cities, states,businesses, and others give to this agreement indicate strongpolitical pressure to achieve this goal. Worryingly, several independent modeling studies have estimated the CleanPower Plan and other existing policies will not be sufficient to achieve the target.

Setting a price on carbon can create business opportunitiesout of the necessity to reduce emissions further, and help address this gap. Companies that can find low-cost ways toreduce emissions can sell these reductions to others. Successfulimplementation of carbon pricing programs under the CleanPower Plan would also position the power sector to benefitfrom future policies that will be needed to meet the nation’slong-term climate goals. Assuming these future policieswould utilize carbon pricing (to take advantage of the reducedcosts described above), this would extend the number of potential buyers for power sector reductions. Moreover,

the non-emitting electricity technologies that a carbon pricepromotes can provide energy to other sectors like transportationand industry that do not currently widely use electricity as an energy source.

Promoting carbon pricing in the near term is a wise long-termstrategy for electricity companies. Successful implementationof carbon pricing under the Clean Power Plan can demon-strate the advantages of these policies and build support for anational program. This will create competitive advantages forthose electricity companies that adapt their business practicesnow for a carbon-constrained future.

ConclusionCarbon trading under the Clean Power Plan can deliver therequired reductions in power sector carbon emissions at the least cost, while simultaneously incentivizing new cleanenergy deployment. EPA has included carbon pricing as anoption for implementation plans, but it is up to states to decide to what extent pricing will be used to achieve theClean Power Plan goals. Successful experience with tradingprograms under the Clean Power Plan will benefit the electricitysector if and when future carbon pricing policies are put inplace. C2ES believes that these policies are inevitable giventhe strong pressure from local governments and businessesto act on climate change. When thinking about long-term climate policy goals, a greater reliance upon carbon-free electricity is likely. The faster the sector can decarbonize, the greater will be its position to support other policies thatwould enhance carbon-free electrification of the economy.Carbon pricing is the best tool to achieve this aim. em

Ashley Lawson is a Senior Fellow at the Center for Climate and Energy Solutions (C2ES), Arlington, VA, where one of her researchareas is U.S. climate policy. E-mail: [email protected].

References1. Siikamäki, J.; Burtraw, D.; Maher, J.; Munnings, C. The U.S. Environmental Protection Agency’s Acid Rain Program; Resources for the Future, 2012; available

online at http://www.rff.org/files/sharepoint/ WorkImages/Download/RFF-Bck-AcidRainProgram.pdf (accessed April 8, 2016).2. Tools of the Trade: A Guide to Designing and Operating a Cap and Trade Program for Pollution Control; EPA430-B-03-002; U.S. Environmental Protection

Agency, 2003; available online at https://www.epa.gov/sites/production/files/2015-06/documents/tools.pdf (accessed March 20, 2016).3. 2014 GHG Emissions Data; California Air Resources Board, 2015. See http://www.arb.ca.gov/cc/

reporting/ghg-rep/reported-data/ghg-reports.htm (accessed May 16, 2016).4. Murray, B.C.; Maniloff, P.T.; Murray, E.V. Why Have Greenhouse Emissions in RGGI States Declined? An Econometric Attribution to Economic, Energy Market,

and Policy Factors; Nicholas Institute for Environmental Policy Solutions, 2014; available online at https://sites.nicholasinstitute.duke.edu/environmentaleconomics/files/2014/05/RGGI_final.pdf (accessed May 13, 2016).

5. Rate-based Compliance Under the Clean Power Plan; Center for Climate and Energy Solutions, , 2016. See http://www.c2es.org/docUploads/rate-based-compliance-under-clean-power-plan.pdf (accessed March 21, 2016).

6. Larsen, J.; Ladislaw, S.O.; Melton, M.; Herndon, W. Assessing the Final Clean Power Plan: Emissions Outcomes; Center for Strategic & International Studies,2016; available online at https://csis-prod.s3. amazonaws.com/s3fs-public/legacy_files/files/publication/160106_Larsen_AssessingCleanPowerPlan2_Web.pdf (accessed March 24, 2016).

7. Annual Report to the Legislature on California Climate Investments Using Cap-and-Trade Auction Proceeds; California Air Resources Board: Sacramento, CA,2016; available online at http://arb.ca.gov/cc/capandtrade/ auctionproceeds/cci_annual_report_2016_final.pdf (accessed May 13, 2016).

8. Investment of RGGI Proceeds Through 2013; The Regional Greenhouse Gas Initiative (RGGI), 2015. See https://www.rggi.org/docs/ProceedsReport/Investment-RGGI-Proceeds-Through-2013.pdf (accessed April 11, 2016).

9. Analysis of the Clean Power Plan: Supplemental Documentation; U.S. Environmental Protection Agency, 2015. See https://www.epa.gov/airmarkets/analysis-clean-power-plan (accessed April 11, 2016).

This article considers the role of nuclear technology in the 21st century for

meeting energy needs and addressing environmental and resource concerns

in the United States.

The

Nuclear Optionfor Meeting the Grand Challenges

of the 21st Century

The Nuclear Option by Andrew Sowder




Access to reliable and affordable electricity is a hallmark of the developed world and is all too often taken for grantedwhen reaching for the light switch at nightfall, adjusting thethermostat downward in summer, or powering the expandingcollection of consumer electronic devices that have becomeessential to daily life. Today, nuclear power plays an importantrole in the generation and delivery of reliable electricity in the United States and other nations.

With extremely high energy density, nuclear plants only requirepartial refueling at 18–24-month intervals. With best-in-classavailability, nuclear power offers on-demand power 24 hoursa day, 7 days a week. As a result, nuclear power can provideboth the energy and capacity to support and stabilize electricitygrids grappling with intermittent generation sources andevolving consumer needs that are driving peak demand andsupply further out of phase with one another.

Most importantly for climate programs, nuclear power generation is essentially carbon free,1 accounting for almosttwo-thirds of the carbon-free electricity generation in the

United States.2 Together, this combination of scalable energyand favorable environmental footprint is unique and valuableamong energy options as society faces the collision of increasing populations, increasing energy demand, and increasing pressures on limited natural resources.

Forecasts and modeling from many independent entitiestend to converge around a common theme—climate changemitigation goals cannot be met without a comparable if notexpanded role for nuclear power. A clear path to societal carbon emission reductions exists through decarbonizationof the economy. But decarbonizing the electricity sectoralone is not sufficient given the significant contributions from non-electric sectors. The fossil fuel-reliant transportation sector alone represents 37 percent of the total energy use inthe United States and offers a ripe target for decarbonizationthrough electrification or fuel substitution. Challenges become even more daunting and the potential role for nuclear increases if important technologies like grid-scale energy storage and carbon capture and sequestration do not come to fruition.

Coming to Terms with TerminologyAs will all technical subjects, discussion of nuclear technology includes many specialized terms and jargon that will be foreignto outsiders. It is worthwhile introducing and defining some of the more essential terms.

Light Water Reactors (LWRs): LWRs are reactors that use ordinary water to slow down (moderate) neutrons and to removeheat from the reactor core. The U.S. nuclear fleet is comprised exclusively of this type of reactor in one of two forms: boilingwater reactors (BWRs), in which water is allowed to boil and steam is produced directly in the main or primary circuit of the reactor; and pressurized water reactors (PWRs), in which boiling is suppressed and steam is produced outside of the primarysystem of the reactor.

Advanced Light Water Reactors (ALWRs): ALWRs are LWRs that incorporate evolutionary design improvements for safety-and performance-based technology improvements, contemporary regulatory requirements, increased expectations fromowner-operators, and more than five decades of operational experience. ALWRs belong to Generation III of the nuclear familytree and comprise the majority of nuclear plants under construction today.

Small Modular Reactors (SMRs): SMRs are reactors that have been designed with lower power output and smaller physicaldimensions to realize benefits of lower unit costs, factory-based manufacturing, and modular transportation and construction.The more mature SMR designs are generally scaled-down and simplified versions of PWR technology and are leading the wayto commercial deployment. Used alone, the term SMR generally refers these small modular LWRs. However, since “small” and “modular” are not technology specific, SMR can also encompass other reactors designs, such as more advanced Generation IV reactors.

Advanced Reactors: Advanced reactors are reactors that employ fuel, coolants, and technologies that generally extend beyondreactor designs that are currently operating. Recognizing that the term advanced can also refer to LWRs and SMRs, here theterm is used in a more restrictive sense. Advanced reactors also offer substantial improvements in natural resource utilization,inherent safety, economics, proliferation resistance, and security. In this regard, the terms “advanced reactor” and GenerationIV (GEN IV) are often used interchangeably. Most advanced reactor concepts employ coolants/heat transfer fluids other thanliquid water for improved design and performance benefits such as higher operating temperatures and lower (even ambient)operating pressures.



With over a half-century of nuclear power generation behindus and a slate of challenges and potential options before us,what is the role of nuclear technology in the 21st century formeeting energy needs and addressing environmental and resource concerns in the United States? Is nuclear destined tosuccumb to mounting economic challenges and ever presentwaste, security, and proliferation concerns? Or is a newgolden age just around the corner?

Nuclear GenealogyThe family tree for fission-based commercial nuclear powerreactors can be grouped into generations. Instead of BabyBoomers, Gen-Xers, and Millennials, reactor generations aredesignated numerically based on historical timeframe andtechnology, as shown in Figure 1.

Generation I encompasses the earliest period of commercialnuclear power.3 Generation II comprises the nuclear plantdesigns constructed during a period of rapid expansion ofnuclear power and increasing power levels of reactors spanningthe late 1960s and through the 1990s, with the crowd of earlyconcepts thinning to a handful of designs dominated by LWRtechnology derived largely from naval propulsion program in the United States.

With poor nuclear plant performance and the Three Mile Island accident in 1979, nuclear plant owner-operators drove

the nuclear market toward a new generation of designs emphasizing safety and economics through greater simplicity,standardization, and regulatory pre-approval of designs.4

These Generation III nuclear reactors incorporate evolutionarydesign improvements on prior commercial technologies basedon five decades of experience and include large advancedlight water reactors (ALWRs) and small modular light waterreactors (SMRs).

Generation IV (GEN IV) advanced fission reactors generallyoffer significant improvements with respect to current nucleartechnologies in terms of potential for enhanced resource utilization, inherent safety, economics and proliferation resistance and security.5

Table 1 presents key properties and features of the GEN IVconcepts that illustrate the wide range of attributes offered bythe next generation of reactor technologies. Use of coolantsother than water can offer a number of features such as reduced corrosion and much larger safety margins due tohigher boiling temperatures and higher heat capacities thanwater. Higher outlet temperatures can permit potentiallyhigher electrical generation efficiency and access to new markets and missions, such as combined heat and powerand sale of high value steam to petroleum and chemical refiners. Lower pressures can mean less costly reactor com-ponents and significantly enhanced safety. Reactors that

Figure 1: Evolution and description of commercial nuclear power reactors by technology generation.Source: Generation IV International Forum, 2015; https://www.gen-4.org/ (accessed September 2015).



employ more energetic (or fast) neutrons open the door tofuel resource amplification by effectively creating more fuelthan consumed via the process known as “breeding”.

The Role of Nuclear in the United States TodayNuclear provides one-fifth of electricity generation in theUnited States today (see Figure 2 inset) from 100 reactors at61 sites.6 Nuclear also plays a broader, albeit less visible, rolein the U.S. power system as it currently represents almost two-thirds of non-carbon-emitting generation.7 Further, nuclearpower provides the inertia and energy density needed to stabilize operation of the complex network of wires andtransformers that supply electricity to customers, known collectively as “the grid”, as the penetration of intermittent renewables and distributed generation increases.

The current 20-percent contribution from nuclear power alsobelies a remarkable story of improvement and performance.The number of U.S. operating plants peaked in 1990 at 112around the same time nuclear first reached its one-fifth shareand has since declined somewhat due to retirements. Yet absolute nuclear electricity generation has increased substan-tially over the past 25 years following the end of nuclearplant construction in the United States (Figure 2 black solidline, left-hand axis).

This counterintuitive trend is the result of an industry “doingmore and better with less.” Increased oversight and improved

maintenance of the U.S. nuclear fleet post-Three Mile Islandresulted in dramatic improvements in both plant safety andperformance, allowing utilities to squeeze more electrical out-put from a smaller fleet through a combination of regulator-approved increases in power output from individual reactorsknown as power uprates and increases in the fraction of timereactors actually generated electricity in a year (i.e., the capacityfactor; Figure 2 blue dotted line, right-hand axis).

What Happened to the U.S. Nuclear Renaissance?A decade or so ago, the words “nuclear” and “renaissance”were frequently found together in print and in conversation.Expectations had been raised in the industry and among thepublic of a new fleet of ALWRs built to meet increasing electricity demand, while also addressing climate change concerns through avoidance of continued growth in carbondioxide emissions.

Over a three-year period from 2007 to 2009, the U.S. NuclearRegulatory Commission (NRC) received applications for construction and operation of 28 new reactors.8 But the arrivalof cheap shale gas, a lack of carbon pricing, and historic globaleconomic downturn soured the economics for nuclear gener-ation in many parts of the United States, especially deregulatedelectricity markets.9 A third of the applications were subse-quently withdrawn, leaving 19 units officially listed as underactive NRC review. Of these, four ALWRs are under con-struction and nearing completion in Georgia and South Car-

Table 1. The Six Advanced Reactor Concepts Recognized by the Generation IV International Forum.

Reactor Coolant Outlet Pressure Neutron SpectrumConcept Temperature (oC)

Gas-cooled fast Helium 850 High Fastreactor (GFR)

Lead-cooled fast Lead (metal) or 500–800 Low Fastreactor (LFR) Lead-Bismuth (eutectic)

Molten salt Fluoride salts 700–1,000 Low Fast or Thermalreactor (MSR)

Sodium-cooled Sodium (metal) 500–550 Low Fastfast reactor (SFR)

Supercritical- Watera 500–625 Very High Fast or Thermalwater-cooled reactor (SCWR)

Very-high- Helium 700–1,000 High Thermaltemperature reactor (VHTR)

Note: aWater exits reactor in a super-critical (i.e., more gas-like) state.



olina. Meanwhile, previously halted nuclear plant constructionon Watts Bar 2 in Tennessee was resumed and finally com-pleted in 2015.

Punctuating these adverse developments, the accident atFukushima Daiichi in Japan in March 2011 marked the endof global nuclear exuberance, as several European countriesreinstated nuclear phase outs and moratoriums; nuclear operators implemented costly enhancements based on thelessons learned from the event; and Japan saw one third ofits electricity supply go offline for an extended period of uncertain length.

Yet, in spite of economic challenges and the aftermath ofFukushima Daiichi, construction of new large LWRs has continued, primarily in the China and other Asian countries,along some non-LWR designs (see Figure 3). Development of smaller, more affordable light-water SMR designs continuesas well, although investment and market interest has beentempered in the post-2008-recession period. Two SMRs arecurrently under construction, one in Argentina (CAREM-25)

and one twin unit in Russia (KLT- 40S).

In the United States, NuScale Power is on track to submit itsintegral pressurized water SMR design to the NRC in late2016 as a key step toward commercial deployment.9b

Meanwhile, western U.S. utility consortium, Utah AssociatedMunicipal Power Systems, is moving ahead with plans tobuild the first-of-a-kind multi-unit NuScale power plant on a site at the Idaho National Laboratory to supply power tothe grid for its customers.9c

The Quest for OptionsIncreasing industry and government interest in advanced,non-LWR reactors has coincided with unprecedented influxof private investment exceeding $1 billion in a growing field ofentrepreneurial developers.10,11 A primary driver for renewedinterest in advanced reactor technology among utilities is thedesire for scalable generation options in the 2030–2050timeframe to address the looming retirement of traditionalbaseload capacity (especially coal and nuclear), while meetingfuture energy demand and hedging against uncertainty

Figure 2: U.S. nuclear utilities have maintained a 20-percent nuclear electricity share (inset) and increased net electricitygeneration (left axis) even as the number of nuclear units has decreased slightly from the peak through power upratesand increased plant availability.



resulting from policy, regulatory, and market changes. Whileelectric power utilities are generally considered to be a veryconservative bunch influenced heavily by near-term factorssuch as fuel costs and electricity prices, they also are driven to look out in the future to balance longer range strategic interests against shorter term business imperatives in theform of integrated resource planning. Given costs in the billions of dollars and lead times of a decade or more, financ-ing, siting, licensing, and construction of new infrastructurelike plants and transmission lines requires advanced planningto enable allocation of resources.

When utilities look to the future now, they see a dauntingcollection of challenges for supplying safe, reliable, affordable,and environmentally responsible electricity enveloped in agathering storm of uncertainty related to carbon emissionpolicy, natural gas prices, penetration of distributed, intermittentrenewable generation, the availability (or lack) of viable grid-scale energy storage, electricity market reform, and other unknown changes to markets, regulation, and policy. Anyone of these factors can have a major disruptive effect on theviability of a specific electricity generation resources, as evidencedwith the introduction and rapid dominance of shale gas.

As a result of shifting market, regulatory, and policy conditions,nuclear and coal find themselves at odds with the new order.Over the last decade, the contribution of coal to electricitygeneration in the United States dropped from one half to onethird, due, in large part, to price competition from other sourcesand tightening environmental regulation (see Figure 4). Thisdecrease has been largely offset by increases in natural gas

generation and, to a lesser degree, increased penetration ofrenewables from 2 percent to 7 percent.

The Future Role of Nuclear GenerationProjections of increasing global electricity demand associatedwith economic growth and proposed large-scale decarboniza-tion of industrialized economies for climate change mitigationindicate continuing growth in nuclear generation throughoutthe 21st century. The Organization for Economic Cooperationand Development (OECD) issued a nuclear technologyroadmap that proposed a “2DS” scenario for limiting globalwarming to 2 °C through decarbonization of all energy sectors.12 The roadmap calls attention to the anticipated needfor nuclear generation capacity that more than doubles fromjust under 400 GWe in 2015 to approximately 930 GWe in 2050.

In March 2015, the United States submitted its target reduc-tions for emissions of greenhouse gases (GHGs) to the UnitedNations Framework Convention on Climate Change (UNFCCC)ahead of the 2015 Paris Climate Conference (COP-21). Thisvoluntary pledge, known as the Intended Nationally DeterminedContribution (INDC), calls for reductions of U.S. net GHGemissions by 26–28 percent below 2005 levels by the year2025 and an aggressive goal of an 80-percent reduction inGHG emissions over the entire U.S. economy by 2050.13Apath to this 80-percent economy-wide reduction is difficult ifnot impossible to imagine without a substantial increase inelectrification and fuel substitution supported by substantialgrowth in nuclear energy in the 2030–2050 timeframe.

Figure 3: Global picture of new commercial nuclear reactors under construction by country (left) and by type (right). Data from IAEA PRIS Database (updated May 16, 2016).Notes: PHWR = pressurized heavy water reactor; HTGR = high-temperature gas-cooled reactor; FBR = fast breeder reactor; BWR = boiling water reactor; PWR = pressurized water reactor.

Energy supply forecasts and planning, including the U.S.INDC and the Clean Power Plan, generally assume continuedcontribution of nuclear power generation at current levels for the foreseeable future. Yet, as illustrated in Figure 5, thisassumption is itself questionable as the current 60-year operat-ing licenses will need to be extended to prolong the operationof the U.S. nuclear fleet to prevent a precipitous decline inthis non-GHG emitting capacity (red line). Moreover, evenfor the case where operation of current reactors is extendedto 80-years (blue line), new nuclear capacity or acceleratedgrowth in other GHG-free energy sources by 2050 will berequired to meet current U.S. climate emissions targets.

Internationally, increasing nuclear generation capacity is projected for markets in China, India, the Middle East, andRussia. Nuclear growth in the OECD countries (including theUnited States and European Union) will remain flat in thenear-term. Importantly, flat growth in developed economieswill still involve substantial installation of new nuclear capacityto keep pace with retirements.

The scale of investment needed to replace aging energy infrastructure is immense, measured in trillions of dollars. Investment need for energy infrastructure in general in theUnited States is projected to be on the order of $3 trillionover next 10 years. Globally, the figure is an estimated $1.6 trillion per year. The International Energy Agency (IEA) concluded in its 2014 special report, World Energy Investment Outlook, that $48 trillion in global investment isneeded through 2035 to meet projected energy needs, ofthis total nuclear represents $1 trillion.14 While nuclear repre-sents a small fraction of the total world’s energy infrastructureinvestment, the absolute sums involved are substantial. The

IEA projection of 930 GWe of installed global nuclear capacityby 2050 for its 2DS (i.e., limiting global warming to 2 ºC Celsius temperature increase by 2050) climate stabilizationscenario corresponds to new investment in nuclear of $4.4 trillion.15

The opportunities and timeframes associated with nucleargrowth in the United States include the following potentialtimelines and roles for nuclear out to 2050 and beyond (Figure 5):

• In the near-term (i.e., within the next decade), options forthe introduction of new nuclear capacity are likely limitedto life extension of the operating fleet and modest additionsof large GWe-class Generation III LWRs like those nearingcompletion in Georgia and South Carolina.

• Over the medium-term (2020s), expanding constructionof SMRs for applications where small modular aspects arecompelling and large ALWRs are not practical or economic.

• Longer-term (2030s and beyond) could see the introductionof advanced GEN IV design concepts deployed as non-emitting energy alternatives to the use of fossil fuels inboth stationary and transportation applications.

• Beyond the 2050s, the widespread introduction of fast reactors and a supporting U.S. infrastructure would enablevirtually unlimited extension of natural uranium (and thorium)fuel resources via continuous recycling of nuclear fuel. Uranium resources are currently not limiting.16

Opportunities and need for all nuclear (ALWRs, SMRs, andGEN IV) increase substantially if decarbonization of industrialand transportation sectors is seriously pursued via economy-



Figure 4: Shift in U.S. electricity generation from coal to natural gas from 2005 to 2015.



wide electrification and fuel substitution (e.g., hydrogen forpetroleum). Both SMRs and GEN IV reactors offer uniquefeatures and attributes, including substantial increases in safety,to support new applications and disruptive business casesthrough greater operational, deployment, and product flexibilitynot available from current technology.17

What About Waste?Management of used nuclear fuel and other long-lived radioactive wastes associated with nuclear energy productionis often portrayed as an intractable problem that precludesconsideration of nuclear energy as an environmentally responsible and sustainable technology option. However,such assertions run counter to a solid international consensusbuilt on six decades of scientific and engineering study onthe appropriateness and capability of deep geologic disposalfor providing the long-term protection of humans and thebiosphere from the hazards of used fuel and high-level radioactive wastes.18

All forms of energy generation are burdened with life-cycleimpacts and environmental footprints, and the current challenge of climate change mitigation is the result of energy

choices that failed to internalize the costs and impacts of by-products. In this respect, nuclear energy uniquely offersthe opportunity to capture and manage its by-products andwastes in a very compact and manageable form. On a per-unitenergy basis, this ends up being the inescapable “no freelunch” dilemma—one has to choose between dilute wasteslike carbon dioxide, large physical and lifecycle footprints associated with low-density energy sources like wind andsolar, or concentrated radioactive wastes from nuclear.

Security and Proliferation ConcernsAs with the nuclear waste issue, the security and proliferationconcerns associated represent an important aspect of nuclearenergy that must be addressed. While much is often made ofthe ability of new technologies to solve the problem of securingnuclear material and technology and discouraging developmentof new state-sponsored weapons programs and diversion ofthe same material and technology for use by non-state actors,there is no “silver bullet.”19 All nuclear programs, materials,and technologies require competent management, adequateprotection, and effective oversight in the form of nationalregulation and international institutions and safeguardsregimes.20

Figure 5: Projected U.S. net nuclear electricity generation capacity (GWe) for the current fleet operating to 60 years (redline) and to 80 years (blue line). In addition, the figure illustrates what doubling of U.S. nuclear electricity capacity lookslike relative to the existing fleet to meet greenhouse gas emission reduction targets. The generation gap widens betweenoperating plants and future targets if new capacity from large ALWRs, SMRs, and eventually advanced reactors is notadded in a timely fashion.



Navigating Uncertainty for Developing and Maintaining Nuclear Energy OptionsDeveloping a meaningful strategic vision for nuclear energy’srole in the 21st century energy mix requires acceptance oflarge uncertainties and reconciliation of disparate and oftenconflicting trends. In the United States, one trend finds safe,reliable, non-emitting nuclear plants struggling for survival inmarkets with low electricity prices, limited demand growth,and inadequate valuation of ancillary services like grid stabi-lization. With this trend comes the risk of early plant closuresand limited life extensions beyond 60-years for the currentoperating fleet and a pessimistic outlook for construction ofnew nuclear capacity.

A second important and opposing trend indicates an increasingneed for reliable, dispatchable, high-quality electricity to

counterbalance the mounting effects of increasing penetrationof intermittent renewables and distributed generation. Whenpaired with aggressive proposals for wholesale decarbonizationof the U.S. economy via electrification or fuel substitution(e.g., with hydrogen), this second trend makes a future energyportfolio dependent on sustained contributions from nuclearenergy—more so if other enabling technologies such as carboncapture and sequestration and grid-scale energy storage failto materialize. In the face of such uncertainty, existing andadvanced nuclear technologies offer utilities and other stake-holders perhaps the most valuable of all commodities for thefuture: options. However, such options must be developedand maintained through adequate planning and investment to ensure they are ready when and at the scale needed.Whether this occurs is perhaps the biggest uncertainty of all. em

Andrew G. Sowder, Ph.D., CHP, is a Principal Technical Leader in Advanced Nuclear Technology at the Electric Power ResearchInstitute (EPRI) in Charlotte, NC. He leads EPRI’s strategic research program on advanced (GEN IV) nuclear energy systems. E-mail: [email protected].

Notes and References1. A generation technology is only carbon free to the extent that all aspects of it life-cycle, including manufacturing, construction, transportation, and fuel cycle

activities, are carbon free.2. The Nuclear Energy Institute (NEI) reports a 63-percent nuclear share of U.S. carbon-free electricity generation based on 2014 U.S. Energy Information

Agency (EIA) data.3. The first nuclear electricity was generated by a sodium-cooled fast reactor (EBR-I, 1951), and the first truly commercial nuclear power plant was a gas-cooled,

graphite-moderated reactor in the UK (Calder Hall 1, 1956).4. Two Generation-III reactors, advanced boiling water reactors, were built and operated at the Kashiwazaki-Kariwa nuclear plant in Japan; four are nearing completion

in the United States; and many more are under construction in China, Finland, France, South Korea, and the United Arab Emirates.5. Strictly speaking, the term Generation IV refers to the six advanced reactor design classes designated under the Generation IV International Forum (GIF).

See A Technology Roadmap for Generation IV Nuclear Energy Systems; GIF-002-00, 2002.6. Of these 100 reactors, 66 are PWRs and 34 are BWRs. This total includes Watts Bar 2, a Generation II PWR completed, commissioned and licensed to operate

in 2015, and grid-connected in June 2016.7. 62.9 percent in 2014 according to Nuclear Energy Institute and U.S. Energy Information Agency data.8. Source: Combined License Applications for New Plants; U.S. Nuclear Regulatory Commission, Updated February 2016 (accessed April 2016); available online

at http://www.nrc.gov/reactors/new-reactors/col.html.9. The United States is not a single electricity market, but rather comprises multiple regional markets in which prices are set via competitive or cost-of-service or

competitive model.9b. Source: Pre-Application Review of the NuScale Design; U.S. Nuclear Regulatory Commission, Updated June 2015 (accessed June 2016); available online at

http://www.nrc.gov/reactors/advanced/nuscale/review.html.9c. Source: Department of Energy Continues Commitment to the Development of Innovation Small Modular Reactors; U.S. Department of Energy; February 18,

2016; available online at http://www.energy.gov/ne/articles/ department-energy-continues-commitment-development-innovative-small-modular-reactors.10. How Startups Can Save Nuclear; Fortune.com, July 6, 2015; available online at http://fortune.com/ 2015/07/06/how-startups-can-save-nuclear-tech/.11. Brinton. S. Introducing the Advanced Nuclear Energy Industry; Third Way: Washington, DC, 2015.12. Technology Roadmap: Nuclear Energy; 2015 Edition; OECD Nuclear Energy Agency (NEA) and International Energy Agency (IEA).13. FACT SHEET: U.S. Reports its 2025 Emissions Target to the UNFCCC; The White House, March 31, 2015.14. World Energy Investment Outlook; International Energy Agency, 2014; available online at http://www.iea.org/publications/freepublications/publication/WEIO2014.pdf.15. Technology Roadmap: Nuclear Energy; 2015 Edition; OECD Nuclear Energy Agency (NEA) and International Energy Agency (IEA).16. The “NEA/IAEA Redbook” - Uranium 2014: Resources, Production, and Demand. A Joint Report by the OECD Nuclear Energy Agency and the International

Atomic Energy Agency; NEA Report No. 7209, 2014.17. Sowder, A.; Burkhardt, B.; Krahn, S.; Irvin, N. Expanding the Concept of Flexibility for Evaluating Advanced Nuclear Energy Systems as Future Commercial

Options. Presented at the 2016 International Congress on the Advances in Nuclear Power Plants, April 17-20, 2016, San Francisco, CA.18. Sowder, A.; Kessler, J.; Apted, M.; Kozak, M. What Now for Permanent Disposal of Used Nuclear Fuel and HLW in the United States?; Radwaste Solutions,

January-April 2013.19. Bathke, B. The Attractiveness of Materials in Advanced Nuclear Fuel Cycles for Various Proliferation and Theft Scenarios. In Proceedings of Global 2009, Paris,

France, September 6-11, 2009.20. For example, conclusions from a recent comprehensive, U.S. Department of Energy-sponsored nuclear fuel cycle options evaluation found that security and

proliferation resistance criteria do not provide meaningful discrimination among technology options, all present vulnerabilities and risks that require appropriateintrinsic and extrinsic controls. See Nuclear Fuel Cycle Evaluation and Screening – Final Report; FCRD-FCO-2014-000106; U.S. Department of Energy, October 8, 2014.

This article highlights the need for prompt action as well as alternative

approaches to reduce carbon in the power sector.

Going all the Way:Options and Innovation to Solve Climate Change

Going all the Way:Options and Innovation to Solve Climate Change

Options to Solve Climate Change by Armond Cohen




In December 2015, 195 nations agreed in Paris under theauspices of the United Nations to take action to limit globalwarming to 2 degrees Celsius above pre-industrial levels, with afurther aspiration to contain warming to 1.5 degrees.1 Isolatedscientific doubters remain, but the evidence is overwhelmingthat unscrubbed fossil fuel emissions have the potential topush the planet into unknown and dangerous territory.

The challenge ahead is bounded by two stark realities. First,carbon dioxide, unlike many other pollutants, effectively accu-mulates in the atmosphere like water in a bathtub with a verysmall drain and warms the planet for centuries. So, in order tomeet the Paris targets, the world will need to drive its energysystems to near-zero carbon emissions (that is, stop addingwater to the bathtub) sometime after 2050 (see Figure 1).2

Second, the world needs to virtually zero out carbon at thesame time global energy demand is predicted to grow by asmuch as 50 percent to 20403—as developing economiesgrow, and the billions of people on the planet with little or no electricity gain access to modern electrical services.

How do we grow a world energy system to one and one half times its present size or more and eliminate nearly all thecarbon emissions from fossil fuels—and do it all at a cost thatis affordable, and in a short period equal to the time between

the beginning of the Reagan administration and today?

Dozens of studies by the world’s energy experts have weighedin on this topic. Their bottom line conclusions will be familiarto the leaders of any large business enterprise. First, we musthave a diversified strategy that avoids overreliance on anyone approach; more options are better than fewer. Second,we must innovate relentlessly to improve the performanceand cost-effectiveness our options to ensure success.

Strategies for Success in the Electricity SectorThe themes of diversity and innovation are illustrated moststarkly in the electricity sector, which accounts for more thanone third of global energy carbon emissions and is expectedto account for a greater share as energy consumption shiftsto electricity. Here, there are at least four strategies that could,in principle, drive fossil fuel carbon emissions in the atmos-phere to zero.

First, we can improve energy efficiency—that is, get moreeconomic productivity out of every unit of energy. Second,we can directly scrub carbon dioxide out of fossil fuels, in aprocess known as carbon capture and sequestration (CCS).Third, we can generate electric power from carbon-freeweather-variable sources, such as wind and solar energy

Figure 1: Meeting the Paris 1.5-2 °Celsius target will likely require zeroing out greenhouse gas emissions early in thesecond half of the present century. Current pledges, even extrapolated, are not enough to get the world on this path. Source: PBL, The Netherlands, 2015; http://infographics.pbl.nl/indc.



(burning plants and trees can produce low-carbon energy,but most studies indicate that the carbon savings attributedto bioenergy tend to be uncertain, long-delayed, and difficultto sustain as the practice scales to industrial levels4). Fourth,we can use nuclear energy to displace coal, oil, and gas. Fifth,although not strictly speaking an electrical strategy, we canremove carbon directly from the atmosphere through naturalor artificial means (i.e., plants or carbon removal machinery).

Each of these strategies has substantial promise, but eachalso has significant challenges today.

Energy EfficiencyEnergy efficiency has improved significantly since the 1970s,but the estimate of substantially increased energy demandsto 2040 and beyond already includes an assumption that wewill improve substantially on our historical rate of efficiencygains. As billions of people move into middle class consumptionlevels, we can lower their demands at the margin, but wecannot bend the curve. While many studies of decarbonizationhave posited essentially flat global energy demand due to efficiency gains, they assume annual end use efficiency improvement rates of 3–4 percent per year; actual globalend use efficiency improvement since 1990 has hovered at around 1 percent per year.5

Carbon Capture and StorageCarbon capture has been commercially implemented ongasified coal, and also in the petrochemical and oil sector for

decades, and its application to electric power at commercialscale is now underway. A good example of carbon captureretrofit on an existing source is Boundary Dam Unit 3 at aCanadian coal plant owned by Saskpower, with the capabilityto capture up to 90 percent of the carbon dioxide emissionsfrom the 45-year old 110-MW pulverized coal unit;6 new NorthAmerican projects include the Petra Nova project in Texasand the Kemper project in Mississippi. But the technology iscurrently limited by geography to the extent that pipelines totake the captured carbon dioxide to sequestration in enhancedoil recovery operations or saline sequestration operations donot exist throughout the United States.7 More importantly,because it will take time to develop carbon dioxide pipelinetransportation and sequestration infrastructure, full applicationof CCS will take decades to fully scale even though, as withsulfur scrubbing, a regulatory push will help.8

Furthermore, current technology also imposes capital costs as well as the costs of additional energy required to powercarbon separation and underground injection; these are highrelative to what they will be once deployment drives learningand innovation. Considered on the basis a cost per ton ofcarbon dioxide, current CCS costs can still be competitive withthe costs of achieving carbon reductions incurred utilizingother zero carbon energy sources,9 and transitional use ofcaptured carbon for enhanced oil recovery during the scale-upperiod for CCS can help offset those costs. But as long ascarbon emissions generally remain unpriced,10 and CCS remains “above market” in cost, CCS will face challenges

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

G

SURPLUS = 900,000 MWH

BALANCING = 11 million MWH

43 GWCONVENTIONAL CAPACITY

0

Figure 2a: The German grid modeled for October 2050 (at projected reduced demand due to efficiency) with 80-percent annual electricity from renewables.Source: Clean Air Task Force analysis, using German grid data for demand and wind and solar production, scaled to Germany 2050 official policy goals for demand and supply.



to scale. Finally, the possibility of citizen opposition to siting of CCS storage, as well as pipeline infrastructure, cannot be excluded.

RenewablesA lot of progress has been made on wind and solar energy,with more than $260 billion spent on these sources in 2015,and thus surpassing fossil energy in new installed generatingcapacity.11 Moreover, solar energy costs have dropped

substantially in recent years. But partly because wind andsolar annual output per unit of installed capacity is muchlower than equivalent non-renewable plants, after decades of effort, these sources still provide less than 5 percent of the planet’s electricity.

A variety of studies, from Google to the UK’s Energy ResearchPartnership, to the National Oceanic and Atmospheric Administration,12 have shown that, even with the availability

0

10

20

30

40

50

60

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

GW

GW

Figure 2b: The difference in firm capacity required throughout the year with and without energy storage.Source: Clean Air Task Force analysis, using German grid data for demand and wind and solar production, scaled to Germany 2050 official policy goals for demand and supply.

IT3

HWC



of low-cost daily energy storage, electrical systems will con-tinue to require firm, dispatchable energy for the weeks andeven months when wind and solar are not available at scale—and to meet our climate targets, those energies will need tobe carbon-free. This parallel system of firm capacity will addsubstantially to costs, as well as storage. At moderate renew-able energy penetration levels, this problem is manageable;at much higher levels, it becomes quite challenging.

An illustration of this challenge can be seen by modeling the German grid for 2050, assuming that sufficient wind andsolar is built in that year to meet 80 percent of annual demand(see Figure 2a). In the month of October, when solar andwind output is low, the surplus generated (900,000 MWH) iswell below the amount of balancing energy needed beyondrenewables (11 million MWH). Even with perfect storage thatcould capture and release all of the surplus in that month, thisdifference must be met by some kind of firm, dispatchableenergy source. In that one month, 43 GW of firm capacity

would be required to meet this demand—close to the monthlypeak of just over 50 GW. As can be seen in Figure 2b, energystorage to accommodate the surplus mitigates the firm capacityrequirement throughout the year, but does not come close toeliminating it, due to the seasonal fluctuations of wind and solar.

As with storage, transmission interconnections can somewhatmitigate the firm capacity burden through non-correlatedwind, but there is a striking level of correlation of daily andhourly wind availability even at continental scale.13 Demand-response can also be a tool to manage wind and solar variability on an occasional daily basis, but on a weekly orseasonal basis, its utility is far less clear; existing demand-response programs have had to call on customers to curtaildemand only for small numbers of hours very infrequentlythroughout the year.14

Finally, the build out of renewable energy systems can bedaunting, especially where they become the dominant, let

Table 1. Energy sources required for 100 percent U.S. wind, water, and solar energy.

Energy source

Offshore wind

Onshore wind

Wave machines

Central solar PV plants

Utility CSP plants

Solar thermal plants

Installed capacity (MW)

780,900

1,701,000

27,040

2,326,000

227,300

469,000

Scale equivalent

72 offshore wind farms per coastal state (including theGreat Lakes states), each the size of the as yet un-builtCape Wind plant

50 large wind firms per state, each the size of California’s Tehachapi wind farm–in total, nearly two timesall U.S. electric installed generating capacity today

Equivalent to 25 large nuclear plants–no commercial wavemachines exist today

1,200 times more than exists today–equal to more thantwo times all U.S. electric generating capacity installed

10 Ivanpah-sized plants for every state

Roughly 150 percent of installed U.S. coal capacity

How do we grow a world energy

system to one and one half times its

present size or more and eliminate

nearly all the carbon emissions from

fossil fuels?



Figure 3: Illustrative low carbon energy mix.Source: IPCC Working AR5 Group III (2014), https://www.ipcc.ch/report/ar5/wg3/.

In Next Month’s Issue…

DISCOVER-AQ UpdateThe August issue will provide an update on the Denver DISCOVER-AQ project. Thisissue will focus on FRM/FEM evaluations for ozone, NO2, and NOy; remote sensingmethods; small sensor technology evaluation; citizen science; and fine-scale model-ing.

Also look for…EtceteraEPA Research HighlightsIT Insight

alone sole source, of electricity. To illustrate, one recent studypositing a 100-percent wind, solar, and hydroelectric supply15

includes the generation requirements shown in Table 1.While this kind of study is a useful thought experiment intechnical potential, the scale and siting challenges associatedwith realizing even half of such a scenario suggests why diversification would be prudent.

Nuclear EnergyNuclear energy provides 11 percent of the world’s electricity,and 20 percent of America’s, two thirds of our carbon-freeelectricity. Moreover, a rapid build-out of nuclear energy inthe 1970s and 1980s allowed France to create a nearly 80-percent carbon-free electric grid over two decades. But for avariety of reasons that are well documented, repeating thiskind of scale-up with current nuclear technology is unlikely.

Current generation light water nuclear technology is typicallymore expensive than the least expensive fossil fuel generation,making it a tough choice for firm power in developing coun-tries with access to coal, as well as in the United States whichcurrently has cheap abundant natural gas. Current light waternuclear designs are also slow to build, with an average con-struction period of 4–8 years in recent years, even in Asia.16

In addition, light water nuclear technology poses safety risksthat many find unacceptable; use of water as a coolant wasthe common denominator of the Chernobyl, Three Mile Island, and Fukushima accidents. Finally, nuclear wastes fromcurrent technology have proven to be a very difficult problemto solve, and the current fuel cycle presents potential risks ofdiversion of fuel for nuclear weapons.



Reasons to Diversify and InnovateAll of this is not reason to despair. It is a reason to diversifyand innovate.

Diversification is fundamental. Because of the challenges ofeach of these options, as discussed earlier, it would be unwiseto restrict ourselves to any one or two. As the Intergovern-mental Panel on Climate Change (IPCC) concluded in its recent 2014 mitigation report, “No single mitigation optionin the energy supply sector will be sufficient. [...] Achievingdeep cuts [in emissions] will require more intensive use oflow-GHG technologies such as renewable energy, nuclearenergy, and CCS.”17 The IPCC’s illustrative mix of generatingsources to achieve deep carbon reductions, as shown in Figure 3, further underscores this principle.

Innovation is equally crucial. Energy efficiency improvementrates can double, perhaps by a factor of two, as new materialsand processes are invented. Promising new fossil power cycles

with carbon capture are being demonstrated today that may bring carbon-free gas or coal power to parity with unscrubbed gas and coal.18 Higher capacity and lower costwind and solar technology is emerging, and storage, whilenot a total solution to wind and solar weather-dependence,can help. And, as discussed by Sowder elsewhere in thisissue, a new generation of nuclear innovators, rooted inNorth America, are developing advanced designs that aim at being less expensive, safer, and faster to build, with substantially smaller and less risky wastes.19

If we pursue a smart, diversified, and innovation-focusedstrategy in the next decade, we greatly improve our chancesof meeting the zero-carbon challenge and avoiding the risksof failure or under-performance on a single pathway. Policy-makers, business leaders, and civil society must come together to embrace and implement a multi-channel approach. em

Armond Cohen is Executive Director of the Clean Air Task Force, a nonprofit organization dedicated to protecting the earth’s atmosphere through research, public education, and collaboration with the private sector. E-mail: [email protected].

Notes and References1. Adoption of the Paris Agreement; United Nations Framework Convention on Climate Change, Conference of the Parties, 21st Session; December12, 2015;

available online at https://unfccc.int/resource/docs/2015/cop21/eng/l09r01.pdf.2. Fawcett, A.A., et al. Can Paris pledges avert severe climate change? Science 2015, 350.6265, 1168-1169.3. World Energy Outlook 2015; International Energy Agency, Washington, DC; p.584.4. See Agostina, A.; Guintoli, J.; Boulamanti, A. Carbon accounting of forest bioenergy: Conclusions and recommendations from a critical literature review; Technical Report;

EUR 25354 EN; European Commission Joint Research Centre, Institute for Energy, and Transport, 2013; McKechnie, J.; Colombo, S.; Chen, J.; Mabee, W.;MacLean, H.L. Forest bioenergy or forest carbon? Assessing trade-offs in greenhouse gas mitigation with wood-based fuels; Environ. Sci. Technol. 2011, 45,789-795; Searchinger, T.; Heimlich, R. Avoiding Bioenergy Competition for Food Crops and Land; Working Paper, Installment 9 of Creating a SustainableFood Future; World Resources Institute, Washington, DC, 2015.

5. See Loftus, P.; Cohen, A.; Long, J.; Jenkins, J. A critical review of global decarbonization scenarios: What do they tell us about feasibility?; Wiley Interdisciplinary Reviews: Climate Change; DOI: 10.1002/wcc.32; Jenkins, J.; Cohen, A. The Role of Energy Intensity in Global Decarbonization Efforts: How fast? Is it Possible;CATF Research Note (March 2, 2015); available online at http://www.catf.us/resources/factsheets/files/Energy%20Intensity%20-%20How%20Fast.pdf.

6. See http://saskpowerccs.com.7. The U.S. Environmental Protection Agency (EPA) has noted that, of the 500 largest point sources of CO2 in the United States, 95 percent are within 50 miles

of a potential storage reservoir.8. The U.S. Environmental Protection Agency (EPA) indeed is now relying on CCS as the ‘best system of emission reduction’ for new coal plants, and enabling CCS

to be useful for compliance with the existing source performance standards in the Clean Power Plan. Net costs of CCS may be also be mitigated to a certain extentthrough the creation of emissions reductions credits under the Clean Power Plan.

9. Comparison of CO2 Abatement Costs in the United States for Various Low and No Carbon Resources; Clean Air Task Force; available online at http://www.catf.us/resources/factsheets/files/CO2_Abatement_cost_comparison.pdf.

10. The Clean Power Plan is a good first step toward creating an implicit price for CO2 from one industry.11. Global Trends in Renewable Energy Investment; Frankfurt School, FS-UNEP Collaborating Centre for Climate and Sustainable Energy Finance, 2016.12. See, e.g., Clean Energy Innovation; Google.org (http://www.google.org/energyinnovation/); Boston, A.; Thomas, H. Managing Flexibility Whilst Decarbonising

the GB Electricity System; Research Energy Partnership, United Kingdom (http://erpuk.org/project/managing-flexibility-of-the-electricity-system/); MacDonald,A., et al. Future cost-competitive electricity systems and their impact on U.S. CO2 emissions; Nature Clim. Change, http://dx.doi.org/10.1038/nclimate2921L3;Brick, S.; Thernstrom, S. Renewables and decarbonization: Studies of California, Wisconsin, and Germany; The Electricity Journal April 2016;doi:10.1016/j.tej.2016.03.001; CCS and the Electricity Market: Modeling the lowest-cost route to decarbonizing European power; Zero Emissions Platform,November 2015 (http://www.zeroemissionsplatform.eu/library/publication/258-ccsforindustry.html).

13. See, e.g., The European Power System in 2030: Flexibility Challenges and Integration Benefits; Fraunhofer IWES June 2015; page 7, Figure S2.14. For example, the PJM grid, during the years 2009–2015, curtailed customers for an annual average of 14 hours, only four incidents per year, with an average

curtailment of 4 times per year for 3.5 hours, for a collective yield of 1 percent of peak. See Summary of PJM-Initiated Load Management Events:http://www.pjm.com/~/media/planning/res-adeq/load-forecast/alm-history.ashx.

15. Jacobson, M., et al., 100% clean and renewable wind, water and sunlight (WWS) all-sector energy roadmaps for the 50 United States; Energy Environ. Sci.2015, 8, 2093.

16. World Energy Outlook 2014; International Energy Agency, Washington, DC; Figure 10.7.17. IPCC Working Group III. Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change; Cambridge University

Press, Cambridge, United Kingdom and New York, NY, USA, 2014.18. See, e.g., https://netpower.com.19. See The Nuclear Decarbonization Option: Profiles of Selected Advanced Reactor Technologies; Clean Air Task Force, 2012; available online at

http://www.catf.us/resources/publications/view/164.

An overview of the movement toward setting science-based targets

for the reduction of carbon dioxide emissions.

Science-Based The Case for

Emissions Targets

The Case for Science-Based Emissions Targets by Mark Chadwick and Alicia Godlove




Corporate impact on climate change has become increasinglyrelevant to global investors looking to protect long-term investments. It’s also important to consumers who care abouthow the brands and partners they choose affect the environ-ment. As a result, more public and private companies are taking steps to reduce their carbon footprints and to reportthose efforts in a structured way.1

The question is: how much is enough? How can a companyset a goal that is both meaningful and achievable? And is one without the other even worth the effort? Despite the introduction of climate change mandates by governmentsand measures by industry, total human-caused greenhousegas (GHG) emissions are continuing to increase.2 Clearly,window-dressing is not enough.

These concerns have launched a movement toward settingscience-based targets for carbon dioxide reduction. Science-based targets are those goals that are aligned with what scientists agree could prevent the worst effects of climatechange.3 The most progressive and committed organizationsare already using those benchmarks to guide corporate policy and change.

Why Science-Based Targets?Science-based targets (SBTs) are carbon emissions targetsconsistent with the level of decarbonization required to limitglobal warming to less than 2 °C compared to pre-industrialtemperatures. Climate scientists calculate that this ceiling mayblunt the worst climate change impacts, and it forms the basisfor the COP-21 agreement reached in Paris last December.

The Science Based Targets Initiative4 is also a joint initiative ofCDP (formerly the Carbon Disclosure Project), the UN Global

Compact, the World Resources Institute, and the WorldWildlife Fund. The initiative is devoted to increasing corporateambition on climate action and demonstrating the businesscase for ambitious target setting.

Many organizations have taken a “do what we can” approachup to this point, taking only carbon reduction measures thatrepresent low-hanging fruit. But with global temperaturescontinuing to rise, most would argue it’s time to raise the bar.Targets that align with science do exactly that, in a way that isrational and meaningful. Why SBTs? The technology is available,the return on investment has data behind it, and with theright strategy and approach to buy-in and action, the goalsare within reach.

Selling Science—Why Disclosing Emissions Is Good for BusinessCDP has estimated a payback from carbon reduction effortsof more than 30 percent based on a combination of cost savings, resource efficiency, and productivity gains related tooutcomes such as reduced employee churn.5 Sustainabilitymeasures also drive innovation and increase a company’s resilience to new climate regulation and policies. Disclosure itself generates positive brand associations for investors andcustomers, and it benefits the bottom line through lowercosts and higher profitability.

As an example, simply installing commercial LED-lighting hasan estimated payback period of less than one year, accordingto CDP data.6 Economies of scale are driving down costs forother energy efficiency technologies, and the U.S. InternationalEnergy Agency estimates that each $1 spent on energy efficiency brings $2–$4 in lifetime cost savings and energysecurity.7

Four Ways to Safeguard Future ProfitabilityCompanies that set SBTs build long-term business value and safeguard future profitability in four fundamental ways.

1. Accelerating innovationThe transition to a low-carbon economy will speed developmentof new technologies and operational practices. The companiesthat set ambitious targets now will lead innovation and trans-formation tomorrow.

2. Saving money and increasing competitivenessSetting ambitious targets now ensures a lean, efficient, anddurable company as resources and raw materials become morescarce and expensive. In addition, companies increasingly wantto do business with suppliers taking climate change seriouslyso they can reduce GHG exposure in the value chain.

3. Building credibility and reputationCompanies taking a leadership position on climate bolstercredibility with investors, customers, employees, policy-makers, and environmental groups.

4. Reducing riskTaking ambitious action now helps companies stay ahead of future policies and regulations to limit GHG emissions.Companies seen as leaders are better able to influence policy makers and shape developing legislation

Key StrategiesThe business case is there, and proven methodologies areavailable for calculating and setting SBTs. These methods rangefrom an open-source model called “sectoral decarbonisation”to what’s called “the 3% solution” to GHG emissions per unitof value added (GEVA). Many companies use a combinedapproach to meet their unique needs. But establishing andapplying the right methodology is just one piece of a complexpuzzle.

Actually landing ambitious SBTs demands a well-organizedand strategic approach to gaining buy-in at every level of thecompany, from employees to board members. Programevangelists must present SBTs not only as necessary and beneficial, but also as realistic. Promotors must carefully framethe rationale for why targets are achievable and lay out a specific game plan; point out past successes that were initiallydaunting, and reinforce the truth that legislative and marketdrivers will force the changes eventually. Better to do it onyour own terms and timelines than under the gun.

One smart strategy available to any energy-intensive businessesis to use partner momentum (specifically in the power sector)

to both engage stakeholders and gain traction. As the powersector is forced to shift to lower-carbon fuels and technologies,there are many organizations who can accelerate their ownprogress toward ambitious footprint reductions simply by riding the wave.

The most savvy will not merely free-load off energy sector reductions, however, but will instead actively contribute momentum with concurrent efforts at demand reduction anda pivot to renewables. They will also build resiliency into theirpower structures to prepare for reliability issues as the energysector moves away from fossil fuels.

[Editor’s Note: See this month’s cover story feature articles onreducing carbon emissions from the power sector.]

Best Practices for Landing SBTsFor many organizations, simply identifying carbon sources is one of the largest challenges to disclosure and mitigationprograms. Sources can be obscure and widely distributed.Where are refrigerants or propane used? Where are the energy sinks within your manufacturing processes? Howmuch do your employees travel? How will you calculate the



Leading Companies Set SBTs

Coca-Cola Enterprises Inc. has committed to reducing absoluteGHG emissions from core business operations 50 percent by2020 and to reduce the GHG emissions from their beverageproducts 33 percent by 2020 (using 2007 as a base year).

Dell Inc. has committed to reducing GHG emissions from facilities and logistics operations 50 percent by 2020 (2010base-year) and to reducing the energy intensity of its products80 percent by 2020 (2011 base-year).

General Mills has committed to reducing emissions 28 percentacross its entire value chain from farm to fork to landfill by2025 (2010 base-year).

Kellogg Company has committed to a 15-percent reductionin emissions intensity by 2020 from a 2015 base-year and toa long-term target of a 65 percent absolute reduction inemissions by 2050.

Pfizer Inc., in addition to its own SBT operational goals, hascommitted that 100 percent of its key suppliers will manageenvironmental impacts, including GHG emissions, througheffective sustainability programs.



carbon implications of your products at end-of-life?

Gathering even basic information, such as utility invoices fromglobal facilities, can be daunting. Companies must createconsistent and standardized processes for getting all facilitiesto contribute data in a manageable and efficient way. Theymust also establish a streamlined and cohesive process forconverting global data into a common energy metric and ultimately to carbon dioxide equivalents.

Basic steps for collecting and standardizing data for sustain-ability initiatives such as SBTs include:

• Analyzing company structure, organizational boundaries,and current operations to gain executive buy-in and engage all stakeholders;

• Setting a base year by identifying carbon sources, calculatingcurrent emissions, and analyzing previous years’ data (ifavailable);

• Identifying the appropriate methodology based on SBTs by setting long- and medium-term targets and short-termmilestones and setting up a strategy for meeting targets;and

• Mapping long-term expected growth, and adjusting strategies and targets as and when needed to reflect actualperformance and changes to the business.

Who Is Taking Action?Most companies today have set emissions reduction targets,and a few have set SBTs. According to the Science Based Targets Initiative, more than 120 companies have signed theorganization’s call to action and have set SBTs.8 Many of thelargest signatories have adapted hybrid versions of the standard calculation methodologies to align with complexglobal operations and supply chains.

Clearly, all businesses must develop a strategy for operatingin a post-COP-21 economic climate where more stringentregulations are inevitable. And the goals of those strategiesmust be based on science to be meaningful and arguable.

Committing to SBTs early will help companies gain resiliencein the face of energy uncertainty, streamline costs, and leadin innovation. Those businesses will also have an advantageover competitors who wait to comply with stricter regulationson emissions once COP-21-driven legislation kicks in. em

Mark Chadwick is chief executive officer of Carbon Clear, an organization with a proven track record of helping large global businesses improve performance by effectively managing and reducing their carbon emissions.

Alicia Godlove is a project manager on the Environmental, Social, and Governance (ESG)/Sustainability team for FirstCarbon Solutions, a leader in advancing sustainable practices around the world and helping organizations grow and operate responsibly.

2017 Awards: • Frank A. Chambers Excellence in Air Pollution Control Award

• Fellow Grade of Membership

• S. Smith Griswold Outstanding Air Pollution Control O�cial Award

• Charles W. Gruber Association Leadership Award

• Honorary A&WMA Membership

• Richard Beatty Mellon Environmental Stewardship Award

• Outstanding Young Professional Award

• Lyman A. Ripperton Environmental Educator Award

• Richard C. Scherr Award of Industrial Environmental Excellence

• Richard I. Stessel Waste Management Award

Go to www.awma.org/about-awma/honors-awards for descriptions and criteria.

Give Credit Where Credit is Due Nominate Someone for A&WMA’s Honors and Awards

Nomination deadline: November 1, 2016

The Coordinating Research Council (CRC) conducted an Air Quality Research

Needs Workshop on February 9–10, 2016, at the Georgia Institute of Technology,

in Atlanta, GA. The workshop brought together researchers from academia,

government, and industry to brainstorm and prioritize a short-list of high-priority

research needs in the areas of mobile source emissions modeling, regional air

quality modeling, and secondary pollutant formation. Highlights from the

workshop are presented below; detailed results and conclusions are available

via the CRC website (http://crcao.org/workshops/2016%20A-98%20AQMRN

%20Workshop/A-98index2016.html).

Top 11 Research NeedsHighlights from the Coordinating Research Council’s 2016 Air Quality Research Needs Workshop:

Highlights from CRC’s 2016 Workshop by S. Collet, R. Guensler, M. Beardsley, R. Mathur, and S. Gao


Regional air quality models are employed in developingand implementing the National Ambient Air Quality Standards(NAAQS) and related regulations, and evaluating and selectingcost-effective emissions control policies. For the past 25 years,regional air quality models have been designed, developed,and continually improved. For instance, the U.S. EnvironmentalProtection Agency’s (EPA) Community Multiscale Air Quality(CMAQ)1 modeling system is designed using interactions ofatmospheric chemistry and physics. CMAQ is an Eulerian(i.e., three-dimensional gridded) transport and atmosphericchemistry modeling system, which simulates ambientconcentrations of ozone, particulate matter (PM), and toxicair contaminants throughout the troposphere.2 The chemicaland physical processes are represented by state-of-the-artmodules, which calculate initial aerosol concentrations(primary organic aerosols, or POAs) and subsequent aerosolconcentrations (secondary organic aerosols, or SOAs). Tosimulate the complex atmospheric processes, CMAQ requiresmeteorological information and emission rates from sourcesof emissions that affect air quality in time and space. Hence,CMAQ relies on emissions modules to provide pollutantinput estimates (magnitude, chemical speciation, location,and temporal variability of pollution sources). Input emissionrates for CMAQ are estimated using the Sparse MatrixOperator Kernel Emissions (SMOKE)3 System, where SMOKE

uses EPA’s Motor Vehicle Emissions Simulator (MOVES)4 toestimate mobile source emissions. Figure 1 illustrates thebuilding of regional air quality estimates.

To help identify the most critical modeling processes or modeling data inputs that could be improved, CRC sponsoredthe Air Quality Research Needs Workshop. The workshopwas attended by 50 invited technical experts on mobilesource emissions and air quality simulation models. The mainobjective of the workshop was to generate a list of priority research needs.

Held over one-and-one-half days, the workshop began withan invited presentation for each of the three areas: regionalair quality modeling, MOVES and emissions inventories, andsecondary pollutant formation. These three speakers summa-rized the state of the science, identified ongoing research,and suggested initial areas where improvements could bemade. The workshop participants were then separated intothe three breakout groups to brainstorm research needs fortheir area. After the brainstorming, each group worked toclarify and consolidate the ideas and voted on their breakoutgroup’s top 10 priorities. The three groups developed 30 research needs statements. The process is illustrated in Figure 2. The next morning, all workshop participants met



Figure 1: Building Regional Air Quality Estimates. Information from MOVES goes into SMOKE, which goes intoair quality models.

together to discuss the top 10 priorities from each group andparticipants voted to identify the overall top 10 priorities forthe workshop. The overall top 11 priorities are presentedbelow. Two of the final top 10 were very similar—and thuscombined for this write up—and three tied for tenth place.

Top Research Needs1. Improved Spatial and Temporal Allocation of Emissions (This is a combination of two top 10 priority items; fromMOVES and Regional topics.)Spatial and temporal allocation of on-road and non-road mobile emissions is critically important to achieving accuracyof emission inventories and air quality model results. Currently,mobile source and nonroad emissions are distributed to countiesusing activity data and then to air quality model grid cells usingspatial surrogates. Spatial allocation and activity distributionneed improvement because modeling is being performedmore frequently at finer scales, such as 4 km and 1 km.Presently, disparate data sources are used to develop vehicleactivity data. In addition, vehicle miles traveled and vehiclepopulation data are not developed consistently throughoutthe country in such a way that meshes with MOVES sourcetype and road type definitions. The start and end of tripsshould also be considered as it is important to properly allocate off-network emissions.

The proposed research would develop sources of data thattrack the movement of vehicles throughout each day (e.g.,using GPS systems). Onroad mobile sources could be moreproperly spatially allocated using these data. Locations of tripstarts could be identified, along with the movement of vehiclesbetween counties. Means of identifying short- and long-haul

trucks versus passenger vehicles should be considered. Truckstop locations and time spent at those stops could be identified.Similarly, nonroad engine use would be monitored and allocated. Methods to develop spatial surrogates for very finegrids and irregular grids should be developed. These newand enhanced data sources should be applicable nationwide.

2. Enhance the Use of Measurements to Evaluate EmissionInventories and Models (MOVES Topic)Several recent studies5,6 have claimed that one of the primarysources of bias between modeled and measured air pollutionconcentrations is inaccuracies in the emission inventories, particularly for mobile sources. Because there are manysources of inherent uncertainty in emission inventory devel-opment and air quality model formulation, it is often difficultto confidently attribute the magnitude and sources of error.As such, it is important that emissions rates are evaluated ona regular basis using methods that can remove the additionaluncertainty introduced by chemical transport models.

Real-world emission measurements (including on-road, roadside, plume sampling, and tunnel studies) are needed toevaluate MOVES onroad vehicle emission rates on a regularbasis. Each type of measurement has strengths and weaknessesin capturing the full range of real-world emissions from thewide diversity of vehicles on the road, so emission evaluationsneed to consider information from multiple studies.7 Com-parisons should account for transformation and losses ofemissions in the near-road environment (such as PM and reactive nitrogen compounds). Additional work is needed toevaluate real-world emission rates other than on-road runningemissions, such as starts, extended idling, evaporative, and



Figure 2: Workshop day 1, prioritization process.

brake and tire wear emissions and emissions from nonroadequipment. This emission data should be collected in waysthat can be used to inform updates to MOVES and otheremission inventory models.

3. Understand the Influence of NOx on SOA/PM Formationand Ozone (Secondary Pollutants Topic)The formation of secondary pollutants (e.g., ozone, SOA) ishighly dependent on oxidation chemistry in the atmosphere.Reductions in oxides of nitrogen (NOx) emissions throughemerging control technologies will push ambient NOx levelslower. These future reductions will challenge the ability ofcurrent chemical models to estimate changes in relative SOA formation from precursor volatile organic compounds(VOCs) in an increasingly peroxide-rich environment. Further,NOx–VOC interactions can lead to additional secondaryproducts (e.g., organic nitrates), which directly influence ambient NOx loadings and secondary pollutant formation.

Additionally, reactions between nitrogen dioxide (NO2) andatmospheric ozone produce nitrate radicals, which are alsoinvolved in VOC oxidation and secondary aerosol formation.Research is needed to evaluate the ability of the chemicalmechanism to properly predict changes in secondary pollutantformation at lower NOx concentrations. Applicable researchshould: (1) evaluate ozone and SOA formation under currentand future VOC–NOx conditions; (2) identify the importanceof daytime and nighttime nitrate radical oxidation; (3) evaluatethe fate of organic nitrates and their impacts on NOx cyclingand ozone formation; (4) update predictive models for SOAand ozone formation as a function of ambient NOx levels;and (5) use chamber studies to test chemical mechanismsand evaluate relative reduction factors.

4. Undertake Air Quality and Emission Trend Analysis (Regional Topic)Emissions are in a declining trend in the United States, butman-made emissions in East and South Asia have increased.Ambient data analyses8 show that mid-tropospheric ozoneconcentrations in remote areas, within the United States andglobally, have been increasing over the past two decades.Therefore, it is necessary to assess air quality trends at loca-tions that are not directly influenced by local anthropogenicemissions and evaluate the implication of global emissions on future air quality and environmental policies.

Long-term trend analysis of ozone and other photooxidantsis needed at locations such as global background sites, upstream of urbanized areas, over the ocean, and at remotemountain sites. In addition to spatial variability, the analysisshould consider temporal variation. Satellite-retrieved data,long-term ground-based measurements, and radiosonde

data at background sites can be utilized for this work. Theanalysis should include concentration and emission trends,and identify mechanisms that drive these trends. Separatemeteorological effect, such as inter-annual and inter-decadalvariations, is desirable so that the impact of human activitiesassociated with the trends can be isolated and extrapolatedto future scenarios.

Ultimately, the analyzed trends should be applied to futureprojections by utilizing a meteorology–emission–chemicaltransport modeling platform. While projecting future trends ishighly uncertain, various climate change mitigation strategiesand clean-technology deployment options could be accom-modated in scenario development. Additionally, it would beuseful to revisit traffic growth projections used to develop airquality management, transportation and state implementationplans. While such projections have been made for a wide-range of applications, there has been little effort to revisit theprojections developed in the past and assess the accuracy byutilizing available data.

5. Characterize Emissions and Composition of SecondaryPollutant Precursors from Gasoline and Diesel NonroadSources (Secondary Pollutants Topic)A significant number of mobile sources, powered by gasolineand diesel engines, are operated off highways and local roads.These non-road sources contribute significantly to NOx andPM emissions. As a result of less-stringent regulations com-pared to those applied to motor vehicles, and the absence of emissions controls systems for many engines, non-roadsources have much higher emissions rates per unit activity forprecursors of ozone and SOAs. Further research is needed tobetter characterize precursors and formation processes forsecondary pollutants from non-road sources.

Research also is needed to identify and better quantify thecontributions of non-road sources to the atmospheric forma-tion of ozone and SOAs. For the non-road sector, researchoutcomes are needed for: (1) chemically-resolved emissionsprofiles that include the most important ozone and SOA precursors; (2) ozone-forming potential and mass yields forSOA formation; and (3) experimentally-constrained mecha-nisms and/or parameterizations to model secondary pollutantformation in regional/global air quality and chemical trans-port models.

6. Improve Big (and Small) Data for Nonroad Activity(MOVES Topic)Non-road engines such as lawn maintenance equipment,farm equipment, marine, aircraft, and construction equipmentcontribute significantly to the overall emissions inventory. Thiscontribution is growing as emissions from other sources





decline. Unlike on-road vehicles, which are registered andcommonly monitored on the road, non-road engine popula-tions, emissions, and activity for non-road engines are noteasily determined.

Research is needed to update, improve, or generate non-roadengine activity for use with MOVES. This would entail inven-torying engine populations, performing and obtaining surveydata on equipment use patterns, and developing alternativemethods to collect or generate data. Research needs also include performing instrumented activity and emissions datacollection to measure relevant activity, such as fuel use or engine-hours of operation per day.

7. Address Transfer Line and Chamber Wall Losses (Secondary Pollutants Topic)Laboratory “smog chambers” often provide the fundamentaldata for understanding and predicting SOA formation. Onemajor challenge in translating results from chamber experimentsto robust parameterizations for models is evaluating the various wall effects on SOA formation and mass yields. Whileparticles lost to chamber walls are often accounted for, thereis limited understanding regarding the loss of organic vapors,reactive intermediates, and oxidants to chamber walls, whichcould lead to substantial underestimation of SOA formation.It is critical to thoroughly evaluate vapor wall loss in experi-mental setups to ensure the SOA yield parameterizations derived from laboratory experiments are robust and relevantto atmospheric conditions, where there are no wall effects.

Additional organic vapor-surface interactions during transferof exhaust through constant volume sampling (CVS) andsampling lines may also bias measured PM emission rates andexhaust gas composition. Research is needed to investigatethe effects of vapor loss in different parts of the emissionmeasurement system, including the transfer lines, the CVS,and associated sampling lines. Research would include a systematic evaluation of organic vapor loss to environmentalchambers to evaluate wall loss for organic vapors formedfrom different VOCs under various oxidation conditions. Theextent of reversible vapor-wall partitioning should also be examined. In terms of chamber walls, experiments shouldalso be designed to probe the effects of chamber use historyon vapor wall loss.

8. Assess the Role of Water on SOA (Secondary Pollutants Topic)The presence of water influences atmospheric reactions andmechanisms and therefore impacts the formation, evolution,and fate of secondary pollutants. Water modifies the reactionpathway for small molecules contributing to SOAs throughheterogeneous chemistry. Water also modifies particle physical

states and subsequent interactions of aerosols with clouds. Wateruptake of secondary aerosol is complex and contributes significant uncertainty to our understanding of visibility, fogs,and clouds. The role of water in the atmosphere is not wellunderstood and thus rarely incorporated in current air qualitymeasurement and modeling schemes. New data and modelsare needed to constrain the impact of ambient relative humidity(RH) for secondary pollutant formation, evolution, and fate.

Research is needed to fill scientific gaps to help enhance ourscientific understanding of the role of water in the atmosphere,specifically to: (1) quantify differences in secondary pollutantformation due to changes in relative humidity; (2) collect newdata on the hygroscopicity of secondary pollutants and theability of secondary pollutant to act as seeds for cold andwarm clouds; (3) model interactions of secondary pollutants inaerosol-cloud interactions and cloud processes; (4) investigatedry and wet deposition; and (5) assess the role of water onHenry’s law constants for highly oxidized compounds.

9. (3-way tie) Improve Future Emissions Inventory Projections (MOVES Topic)MOVES relies on the data from the U.S. Energy InformationAdministration (EIA) annual publication, Annual Energy Outlook, to establish many of the future year on-road vehicleactivity and fuel use projections. These input data are not updated with each Outlook release, and the default MOVESmodel assumptions for future projections can become out ofdate. There is a need for regular, periodic updates to the national-level future activity projections of the MOVES modelthat are more frequent than official MOVES model releases.

Research is needed to develop guidance for the implementationof periodic updates to future-year vehicle activity projectionsincorporating regularly published resources. Updates to projection data include vehicle miles traveled (VMT), vehicleclass sales/populations, vehicle technology implementation,and activity among fuel type. In addition, because future-yearactivity data for air quality modeling is required at the countylevel, research is needed to develop methods to forecast differential activity growth that varies geographically, withhigher vehicle activity growth in areas with higher than average human population growth.

9. (3-way tie) Condensation Rules for Chemical Mechanisms (Regional topic)Air quality models typically use chemical mechanisms to represent the wide variety of atmospheric constituents andtheir interactions. These equations can vary depending onthe model application, which will dictate how complex themechanism needs to be. For example, regulatory modelingmay have different needs than research applications; similarly,



it may be practical to model more detailed chemistry whenmodeling only a few grid cells than when modeling thousandsof cells.

Chemical mechanisms are updated to incorporate new infor-mation and understanding of atmospheric chemical reactionssuch as NOx cycling, marine effects, and the impacts ofnighttime meteorology and chemistry. Current tools do notsupport easy updates to the mechanisms, and condensingfrom explicit mechanisms to ones suitable for practical useand specific purposes can be difficult. Research is needed toinvestigate options to develop an automated approach forupdating chemical mechanisms. This research could includea better approach to linked gas-aqueous-aerosol phase chemistryand integration with SOA and heterogeneous chemistry.

9. (3-way tie) Fires: Wild and Prescribed (Regional topic)Fires are a significant contributor to PM emissions in theUnited States, accounting for 35 percent of PM2.5 mass inthe 2011 National Emissions Inventory.9 Historically, national-level information has been used to estimate emissions fromfires, but information at the state, regional, and local level canimprove emissions inventories. Unlike other anthropogenicsources, fire emissions vary widely from year to year, makingthem difficult to model and especially difficult to project forthe future.10 Research would be helpful to resolve questionssuch as the magnitude and speciation of fire emissions, their

spatial and temporal allocation, plume rise, in-plume chemistry,relation of emissions to fuel types and burning stage, and theprediction of fire activity using soil moisture, satellite data andweather. Research is also needed on the interaction of fireemissions with emissions from other sources (e.g., fires nearroadways).

ConclusionThere are many opportunities for improving air quality modelingthrough research. This list of prioritized needs compiled fromthe 2016 Air Quality Research Needs Workshop can serve asa guide for agencies that are considering funding or conductingair quality modeling research. A total of 30 research need topicswere identified and discussed at the workshop, and they canbe found on the CRC website (http://crcao.org/workshops/2016%20A-98%20AQMRN%20Workshop/A-98index2016.html).. Universities and graduate students are encour-aged to review the longer list to identify research topics forintegration into unsolicited research proposals and disserta-tion work. By identifying this short list of research needs, theconference attendees hope to better focus resources towardimproving the models that are used in air quality planning ef-forts. In some cases, data do not exist and new methods areneeded to obtain the data. In other cases, data exist and newstrategies are needed to analyze the data. In any case, theproposed research projects would help evolve air qualitymodeling over the next five years. em

Susan Collet is an executive engineer with Toyota Motor Engineering and Manufacturing, North America Inc. Randall Guensler isa professor in the Georgia Institute of Technology School of Civil and Environmental Engineering. Megan Beardsley is a scientistwith the Office of Transportation and Air Quality, U.S. Environmental Protection Agency. Rohit Mathur is a scientist with the Na-tional Exposure Research Laboratory, Office of Research and Development, U.S. Environmental Protection Agency. Shaokai Gao is a scientist with Phillips 66 Research Center. All are members of the Coordinating Research Council (CRC).

References1. Byun, D.; Schere, K.L. Review of the governing equations, computational algorithms, and other components of the Models-3 Community Multiscale Air Quality

(CMAQ) modeling system; Appl. Mech. Rev. 2006, 59, 51-77.2. Community Multiscale Air Quality (CMAQ) Version 5.0 (February 2010 release) OGD. See http://www.airqualitymodeling.org/cmaqwiki/index.php?title=

CMAQ_version_5.0_(February_2010_release)_OGD (accessed February 15, 2016).3. Sparse Matrix Operator Kernel Emissions (SMOKE), Modeling System; University of North Carolina, Carolina Environmental Programs, Research Triangle Park,

North Carolina, 2003.4. 2005d MOVES (Motor Vehicle Emissions Simulator); U.S. Environmental Protection Agency, Office of Transportation and Air Quality. See http://www3.epa.gov/

otaq/models/moves/ (accessed February 15, 2016).5. Anderson, D.C.; Loughner, C.P.; Diskin, G.; Weinheimer, A.; Canty, T.P.; Salawitch, R.J.; Worden, H.M.; Fried, A.; Mikoviny, T.; Wisthaler, A.; Dickerson, R. Measured

and modeled CO and NOy in DISCOVER-AQ: An evaluation of emissions and chemistry over the eastern U.S.; Atmos. Environ. 2014, 96, 78-87.6. Kota, S.H.; Ying, Q.; Zhang, H.: Schade, G.W. Evaluation of CO and NOx Emissions from MOVES and MOBILE6.2 in Southeast Texas Using Source-Oriented

CMAQ Model; Paper #13-5187. Presented at the Transportation Research Board Annual Meeting, February 5, 2013.7. Choi, D.; Koupal, J. MOVES Validation. Presented at the MOVES Workshop, June 14, 2011; available at https://www3.epa.gov/otaq/models/moves/conference2011/

validation-moves-2011.pdf.8. Xing, J.; Mathur, R.; Pleim, J.; Hogrefe, C.; Gan, C.-M.; Wong, D.C.; Wei, C.; Gilliam, R.; Pouliot, G. Observations and modeling of air quality trends over

1990–2010 across the Northern Hemisphere: China, the United States, and Europe; Atmos. Chem. Phys. 2015, 15, 2723-2747; doi:10.5194/acp-15-2723-2015; www.atmos-chem-phys.net/15/2723/2015/.

9. Larkin, S.; Raffuse, S. 2014 NEI for Wildland Fire. Presented at EPA’s 2015 Emission Inventory Conference, April 13, 2015; available at https://www.epa.gov/sites/production/files/2015-09/documents/intro.pdf.

10. Tian, D.; Zeng, T.; Boylan, J. Georgia Wildland Fire Emissions and Their Air Quality Impacts. Presented at the 2015 Emissions Inventory Conference, San Diego,CA, April 15, 2015; available at https://www3.epa.gov/ttn/chief/conference/ei21/session5/tian_pres.pdf..

Asian Connections


by Robyn Garner, Clean Air Asia

Clean Air Asia’s Cities Clean Air Partnership is introducing the bronze-level

actions for its innovative City Certification Program in August, providing cities

around the globe with a roadmap and incentives to enable them to improve

their long-term air-pollution management capacity and overall air quality.

City Certification ProgramAn Innovative Approach to Urban Air Quality

Iloilo » Philippines

Asian Connections


Air pollution now ranks as the world’s leading environmentalhealth risk, responsible for millions of premature deaths eachyear. The health impacts are myriad, ranging from neonatalconditions, asthma, strokes, and cancer to respiratory and cardiovascular diseases. In 2012 alone, exposure to air pollutionclaimed the lives of an estimated 7 million people, or one ineight of all deaths globally.1

According to the World Health Organization (WHO), air pollution readings frequently exceed recommended levels inalmost all parts of the world.2 Of particular concern for citiesand the rapidly growing number of people living in urbanareas, is ambient (outdoor) air pollution. Ambient air pollution,which the WHO has deemed carcinogenic to humans,3

primarily emanates from the burning of fossil fuels, such asoil, coal, and natural gas, which at present represent approxi-mately 80 percent of the world’s energy supply. Fossil fuelburning also contributes to global carbon dioxide emissions,which are forecast to rise by 57 percent by 2030.4 Cities, inparticular, are responsible for up to 70 percent of globalgreenhouse gases.5

Presently, more than 50 percent of the world’s population resides in urban areas; by 2050, that figure is expected torise to 66 percent.6 Sustainably accommodating the indus-trial, energy, and transportation needs of such expandingurban populations while maintaining air quality are challengesfacing city authorities around the world.

To help cities meet those challenges, Clean Air Asia’s CitiesClean Air Partnership (CCAP) is introducing the bronze-levelactions for its innovative City Certification Program in August,providing cities with both a roadmap and incentives to enablethem to improve their air-pollution management capacity andoverall air quality. The program is designed to ensure that citiesare continuously moving forward in achieving clean air targets.

City Certification ProgramCity certification is a means for international recognition.Bronze-level certification can be awarded to cities that makedemonstrable progress toward improving their capacity tomanage the critical sources of air pollution. Unlike other eco-certification schemes operating in municipalities, countries,

The Cities Clean Air Partnership

The Cities Clean Air Partnership (CCAP) is an initiative of Clean Air Asia that providesconcrete support to move cities progressively toward cleaner air. Launched in August2014 by Clean Air Asia, Environmental Protection Administration Taiwan (EPAT), andU.S. Environmental Protection Agency (EPA), the key elements of CCAP are: city certifi-cation; city-to-city cooperation; and knowledge platform with a database of experts.

CCAP is an initiative supported by the International Environmental Partnership (IEP), anenvironmental collaboration program established by EPAT and EPA aimed at assistingenvironmental agencies and organizations around the globe to strengthen their capac-ity to manage the environment and protect human health.

CCAP—a comprehensive community platform for cities to cooperate and jointly addressair-quality challenges—promotes city-level action as the foundation upon which to address the issues posed by air pollution and its im-pact on public health. CCAP recognizes that managing air pollution and greenhousegas emissions is a complex task that requires long-term commitment and multi-stake-holder action at the city level. It builds on Clean Air Asia’s more than 10 years of workwith cities, supported by development partners, such as the Asian Development Bank,World Bank, USAID, GIZ and Sida, among others.

CCAP aims to provide cities with incentives, direct support, and technical assistance toreach clean air targets, with a goal of setting 200 cities across Asia on the pathway toachieving improvements in air quality by 2020.

Asian Connections


and regions throughout the world, the City Certification Program is global in its scope and reach (with initial imple-mentation in Asia), is results-based and outcomes-oriented,and encourages multifaceted, multisector support for city authorities in improving their air quality management capacity.

At this writing, five cities—Baguio, Iloilo, and Santa Rosa in thePhilippines; Kathmandu in Nepal; and Malang in Indonesia—have signed up for the program’s bronze-level certificationpilot phase in 2016, each of which will receive technical advice in implementing a series of requisite actions, will participate in international cooperation for focused city-to-city learning, and will develop their air quality managementtechnical capacity.

The prescribed bronze-level core actions—to be developed inconsultation with, and endorsed by, international experts andleading stakeholders—are focused on three key areas: gover-nance, involving such components as policy developmentand air quality management staffing; assessment, involvingthe compilation and review of air-quality data, the developmentof monitoring criteria for pollutants of concern, and the conducting of an emissions inventory of air pollution sources;and control measures and mitigation, involving the developmentof a clean air action plan inclusive of the actual implementation

of at least one mitigation measure for the city’s main sourcesof pollution (categorized as mobile sources, stationarysources, area sources and power-generation sources).

To guide cities in their endeavors, each certification action isaccompanied by peer-reviewed action descriptions (suppliedboth directly to cities and available online) featuring informationon the steps that need to be taken to complete the action, including who should be involved, project costs, and resourceneeds. Specialists interested in being involved in the peer-review process can do so via CCAP’s Experts’ database(www.cleanairasia.org/ccap/experts/howitworks), which features a list of experts from around the world who specializein solutions for better air quality.

On completion of the certification actions, cities are requiredto submit supporting documentation for third-party verifica-tion. Working Groups, comprised of air quality specialists andrepresentatives from city associations, national environmentalagencies, nongovernmental organizations, and developmentorganizations, will assess implementation progress and theresults achieved and will determine if the actions have beencompleted. Achievement of the standard required will resultin automatic certification. Feedback will be provided wherethe standard is not met.

CCAP City Certification Program Proposed Governance Structure

Working Groups: Headed by leading experts in their field, their role is to propose and develop certification actions,prepare action descriptions, review the documentation submitted by cities, and determine if an action has been completed.

Certification Committee: Drawn from the Working Groups, its role is to agree with the certification requirementsthat cities need to achieve.

Clean Air Asia Board of Trustees: The Board of Trustees approves members of the Certification Committee andoversees operations.

Secretariat: The Secretariat is responsible for the day-to-day operations of the City Certification Program and supportsthe Certification Committee.

For More Information

City Certification Program: www.cleanairasia.org/ccap/certification.

Clean Air Asia: www.cleanairasia.og.

Clean Air Asia’s Better 9th Better Air Quality conference and IUAPPA’s 17th World Clean Air Congress: www.cleanairforcities.org.

Asian Connections


Certification offers multiple benefits to cities. It is internationalrecognition of cities’ willingness and commitment to improvecity-level air quality management systems and processes, itwill result in tangible improvements in urban air quality andcommensurate gains in the health and wellbeing of urbanpopulations, and it will lead to the development of cleanertransportation and power-generation technologies. In addition,cities will have access to CCAP’s online Knowledge Platform,which includes technical resources (lectures, trainings, work-shops) and the Experts’ database, members of which can assist cities in such areas as emissions reduction and improvedair-quality management. Certification also bolsters cities’ publicand business image and marketability, positioning them atthe forefront of sustainable, green development.

In a regional context, the City Certification Program will helpcities develop the institutional capacity needed to achieve theobjectives of the “Long-Term Vision for Urban Air Quality inAsia,” which describes the desired state of urban air quality inAsian cities in 2030. Guided by the vision of healthy people inhealthy cities that put emphasis on prevention of air pollutionand implement effective and appropriate strategies for the

abatement of air pollution, it is envisioned that by 2030 theair quality in Asian cities will have made progress in meetingWHO air quality guideline values through the implementationof comprehensive air quality management strategies.

In a global context, the City Certification Program directlysupports the realization of the United Nations’ SustainableDevelopment Goals, notably Goal 11: Make cities inclusive,safe, resilient, and sustainable; and Goal 3: Ensure healthylives and promote well-being for all at all ages (Target: By 2030,substantially reduce the number of deaths and illnesses fromhazardous chemicals and air, water and soil pollution andcontamination).

Clean Air Asia is the region’s premier air quality network, and as such the City Certification Program will be a respected,trusted, and credible initiative utilizing the knowledge andsupport of leading experts in the field. The official launch ofthe bronze-level certification program (the pilot phase) willtake place during the 9th Clean Air Asia Better Air QualityConference and IUAPPA’s 17th World Clean Air Congress, to be held from August 29 to September 2 in Busan, South Korea. em

Asian Connections is sponsored by A&WMA’s International Affairs Committee. A&WMA has invited Clean Air Asia to contribute one column each quarter to highlight air quality and climate change issues in Asia. Clean Air Asia is an international nongovernmentalorganization that promotes better air quality and livable cities by translating knowledge to policies and actions that enable Asia’s1,000+ cities to reduce air pollution and greenhouse gas emissions from transport, energy, and other sectors. A&WMA has collaboratedand partnered with Clean Air Asia since 2006.

References1. 7 Million Premature Deaths Annually Linked to Air Pollution; World Health Organization, 2014; available at http://www.who.int/mediacentre/news/releases/

2014/air-pollution/en.2. Prüss-Ustün, A.; Wolf, J.; Corvalán, C.; Bos, R.; Neira, M. Preventing Disease through Healthy Environments—A Global Assessment of the Burden of Disease from

Environmental Risks; World Health Organization, Geneva, 2012; p. 60.3. Ambient (Outdoor) Air Quality and Health, Fact Sheet No. 313; World Health Organization, 2014; available at http://www.who.int/mediacentre/factsheets/fs313/en.4. World Energy Outlook Special Report: Southeast Asia Energy Outlook; International Energy Agency, 2013; available at http://www.iea.org/publications/f

reepublications/publication/weo-2013-special-report-southeast-asia-energy-outlook.html.5. Global Report on Human Settlement 2011; United Nations Habitat, 2011; available at http://mirror.unhabitat.org/downloads/docs/E_Hot_Cities.pdf.6. World Urbanization Prospects: The 2014 Revision, Highlights; United Nations, Department of Economic and Social Affairs, Population Division, 2014; p. 5.

Washington Report


Environmental advocates are urging the U.S. EnvironmentalProtection Agency (EPA) to speed up its required review ofthe federal air quality standards for particulate matter, whichis currently slated to run through 2021. EPA detailed theschedule for its periodic review of the national ambient airquality standards for particulate matter in a draft reviewplan currently out for public comment.

“They put out these timelines that confirm the obvious: thatbased on the meetings and work that occurred, that they’reonce again not on the schedule to meet the five-year statutorydeadline,” said John Walke, director of clean air programs atthe Natural Resources Defense Council.

The U.S. Clean Air Act requires EPA to review its various airquality standards every five years and, if necessary, make adjustments. EPA last updated the air quality standards forfine particular matter in January 2013, setting the annualstandard at 12 micrograms per cubic meter.

The plan offered by EPA would see the agency take eightyears to complete the required review, which officially beganwith a request for information in December 2014. Thoughenvironmental groups would like to see the EPA’s review accelerated, they have few options beyond suing the agencyonce it has officially missed that five-year statutory window,Walke said. em

EPA to Complete Particulate Matter Review in 2021

EPA Finding on Power Plant Mercury Standards Published

The U.S. Environmental Protection Agency (EPA) publishedits final supplemental finding on the need to regulate powerplant emissions of mercury and other hazardous pollutants.

The finding reaffirmed EPA’s determination that it is “appropriateand necessary” to regulate power plants under Section 112of the U.S. Clean Air Act. That determination, originally madein 2000, ultimately led to promulgation of the Mercury andAir Toxics Standards, a regulation that the agency estimatedto cost the power sector $9.6 billion per year while generatingsignificant public health benefits.

EPA’s supplemental finding was made necessary by a 2015U.S. Supreme Court decision that the agency erred when it

didn’t consider cost in its “appropriate and necessary” analysis(Michigan v. EPA, 135 S. Ct. 2699, 2015 BL 207163, 80ERC 1577 (2015)).

The supplemental finding took two distinct approaches toconsidering cost: a preferred approach that weighed four different cost metrics against prior conclusions about thehealth and environmental hazards related to power plantemissions; and a secondary approach that involved a fullcost-benefit analysis that showed the costs of the rule weredramatically outweighed by the as much as $90 billion in related benefits. em


Washington Report

The U.S. Federal Highway Administration (FHWA) has proposed new performance measures that transportationagencies will use to weigh progress in addressing traffic congestion, including a first-ever proposal to measure greenhouse gas emissions from on-road mobile sources.

The proposal would require states to “evaluate and reportmore effectively and consistently on transportation systemperformance, including travel time reliability, delay hours,peak-hour congestion, freight movement and on-road mobilesource emissions,” Federal Highway Administrator GregoryNadeau said in a blog post.

In addition, he said, the proposal “invites comment on thepotential to establish a performance measure to address reduction in greenhouse gas emissions.”

The proposal, required under the Moving Ahead for Progressin the 21st Century (MAP-21) Act, aims to help meet nationalgoals to reduce congestion, improve reliability of the surfacetransportation system and freight movement, and improveenvironmental sustainability.

The agency said the proposal also is a “down payment” onthe administration’s 21st Century Clean Transportation Plan, a budget proposal to reduce traffic and carbon intensity ofthe transportation sector. em

FHWA Traffic Measures May Include Greenhouse Gases

EPA May Revisit Methane Rule on New Oil, Gas Wells

The White House is reviewing a final U.S. EnvironmentalProtection Agency (EPA) rule that would set the first evermethane emissions limits for new oil and natural gas wells,but Administrator Gina McCarthy said the agency could takea second look at regulating additional facets of the industry in the future.

“We think there’s more information that indicates there aremore sources that we may not have addressed,” McCarthytold reporters. “But that does not mean that they’re not onthe table for us to look at and move forward on, but that willrequire a more extensive process.”

EPA sent its final rule setting limits on methane emissionsfrom new and modified oil and natural gas wells to the WhiteHouse Office of Management and Budget for interagency re-view. The rule would set the first ever new source perform-ance standards for methane emissions from the sector underSection 111(b) of the U.S. Clean Air Act. Finalizing that rulewill trigger a requirement to similarly regulate existing wellsunder Section 111(d) of the act.

EPA announced that it would solicit better data on the existingwells through an information collection request, the first steptoward issuing the rules long sought by environmental advocates. em

Washington Report

Fourteen states are asking the U.S. Environmental ProtectionAgency (EPA) for assistance as they prepare to comply withthe Clean Power Plan despite the rule being stayed by theU.S. Supreme Court.

“We recognize that the EPA must respect the stay of the CleanPower Plan regulations in providing additional informationand that this information would be subject to the outcome ofthe federal Clean Power Plan litigation,” the 14 states said ina letter sent to Janet McCabe, EPA’s acting assistant adminis-trator for air and radiation.

“We believe EPA can provide information helpful to statesconsistent with the stay.”

The states are encouraging EPA to provide model rules thatwould guide their compliance with the Clean Power Plan,which sets carbon dioxide standards for existing power

plants. The states said the guidance would be beneficial as theyprepare to implement updated ozone air quality standards.

The states also are asking EPA for additional guidance ontracking systems for emissions allowances; credits for tradingprograms; and methods to measure and verify energy efficiencygains. EPA has said it would continue to work with states,which are charged with implementing the carbon dioxidestandards, on a voluntary basis despite a Supreme Court decision halting the rule until it can be litigated (West Virginiav. EPA, U.S., No. 15A773, 2/9/16).

The letter was signed by environmental regulators in California,Colorado, Connecticut, Delaware, Maryland, Massachusetts,Minnesota, New Hampshire, New York, Oregon, Rhode Island,Vermont, Virginia, and Washington, all of which are support-ing EPA in its legal defense of the rule. em

14 States Seek Clean Power Plan Guidance Despite Stay


Washington Report is compiled by Jeremy Hunt, Bloomberg BNA (bna.com).

A&WMABuyers GuideTap into the incredible network of the Air & Waste Management Association with the A&WMA Buyers Guide. Powered by MultiView, the Guide is the premier search tool for environmental professionals. Find the suppliers you need, within the network of the association you trust.

Start your search today at awma.org.

News Focus


A preliminary injunction that suspended federal regulationson hydraulic fracturing was based on a variety of good reasonsand is likely to be a moot issue before an appeals court candecide on the legitimacy of the injunction, two industry groupstold the appeals court (Wyoming v. Interior, 10th Cir., No. 15-8126, 5/25/16).

The injunction is being appealed in the U.S. Court of Appealsfor the Tenth Circuit while the case against the underlying rulefrom the Bureau of Land Management (BLM) is being con-sidered in the U.S. District Court for the District of Wyoming.

“BLM continues to persist in this appeal, and to burden theresources of the parties and this Court, to challenge a prelimi-nary injunction virtually certain to be moot before this Courtcan decide this appeal,” said the Independent Petroleum Association of America and the Western Energy Alliance in a brief to the appeals court May 25.

“BLM persists despite the merits being fully briefed and sub-mitted to the district court for decision,” the two groups said.

The bureau also focused far too much of its appeal on thequestion of whether the agency had the statutory authority toissue its rule on hydraulic fracturing while failing to adequatelyaddress the many other reasons the district court cited for thepreliminary injunction, the groups said.

Laws, Potential Harm ArguedThe Obama administration told the appeals court in March thatnot only did the BLM have adequate authority under FederalLand Policy and Management Act and various mineral leasingstatutes but also that the plaintiffs—including industry, fourstates and an Indian tribe—failed to demonstrate they facedirreparable substantial harm in the absence of an injunction.

“BLM ignores that the final rule also fails on numerous countsas a matter of administrative law. The district court correctlydetermined that multiple independent bases undermine thevalidity of the final rule,” the industry associations told the appeals court.

“The district court determined that BLM lacked statutory

authority to issue the rule. But the district court also ruledthat, among other independent flaws, BLM failed to: (i) addressevidence in opposition to the conclusions BLM reached; (ii)explain meaningful changes in existing law and practice; (iii)investigate the costs the rule imposes; and (iv) justify the application of disparate treatment to functionally similar products,” the associations said.

As for the amount of potential harm needed to justify an injunction, the associations argued that not only was the government underestimating the potential for direct financialharm but it also was overlooking the potential harm from dis-closure of trade secrets, a reference to fracking fluid formulas.

States Defend InjunctionFour states told the district court the BLM was exceeding itsauthority in trying to regulate hydraulic fracturing on federalland, where fracking already is regulated by states, and thatwas a prominent argument cited when the district court issuedits injunction (Wyoming v. Interior, D. Wyo., No. 2:15-cv-43,9/30/15).

Three of the states, led by Wyoming, recapitulated their argument to the appeals court in defense of the injunction in a brief filed May 25.

The BLM based its rulemaking authority on statutes thatallow for the regulation of leasing on federal land but do notinclude the regulation of hydraulic fracturing or the protectionof groundwater as their purpose, the states said.

The argument before the appeals court consolidates two appeals—one from environmental activist intervenors (No. 15-8126) and one from the federal government (No. 15-8134).

For More InformationThe industry brief in Wyoming v. Interior in defense of a preliminary injunction is available at http://src.bna.com/fte.

The states’ brief in Wyoming v. Interior in defense of the preliminary injunction is available at http://src.bna.com/ftc.—By Alan Kovski, Bloomberg BNA

Industry, States Defend Fracking Rule Injunction

News Focus


The National Association of Clean Air Agencies released amodel rule to guide states as they prepare to implement theU.S. Environmental Protection Agency’s (EPA) Clean Power Plan.

The model plan maps out choices state regulators will needto make as they develop compliance plans to implement theEPA’s carbon dioxide standards for the power sector.

The model plan is meant to be “a comprehensive resourceintended to help states develop compliance plans,” Bill Becker,executive director of the National Association of Clean AirAgencies, told reporters June 1.

The options outlined in the model rule include whether to seta mass-based cap on total emissions from the power sectoror whether to pursue a rate-based system that sets a limit onthe amount of carbon dioxide that can be emitted permegawatt-hour of electricity generated.

The model rule also includes an option to include new naturalgas-fired units in order to prevent leakage—where utilities investin new natural gas units that have effectively less stringentemissions limits rather than controlling emissions at existingfossil fuel plants.

The model rule follows a “menu” of carbon dioxide emissionsreduction options that the National Association of Clean AirAgencies issued in 2015 to aid states in their preparations forthe Clean Power Plan.

EPA Developing Model RuleEPA is also developing a model rule that is intended to guidestates. EPA’s model is expected to be released this summer.

EPA’s Clean Power Plan (RIN:2060-AR33), which sets limits

on carbon dioxide emissions from the power sector, hasbeen stayed by the U.S. Supreme Court and is scheduled tobe argued before the full U.S. Court of Appeals for the Districtof Columbia Circuit in September (West Virginia v. EPA, D.C.Cir., No. 15-1363, 5/15/16).

Despite the stay, at least 14 states have asked EPA for addi-tional guidance on preparing for the rule should it eventuallybe upheld.

While the model rule was developed with input from the National Association of Regulatory Air Commissioners andthe National Association of State Energy Officials, Becker saidthe air regulators didn’t consult with EPA much beyond themeetings they held during the Clean Power Plan’s development.

Effort to Write Rule“When we got to writing and it came time to develop the language in our model, we stopped short of asking for theirinput for a few reasons,” Becker said. “One is we wanted tobe independent of EPA, and we want this to be a state modelapproach and not a state model approach in any way shapedby EPA. We were also mindful of the politics of some states wanting to keep more of an arm’s length from EPA, which we understood.”

While the Supreme Court’s stay has halted much of the states’work on the Clean Power Plan, the additional time providedby the litigation could prove to be a boon for regulators whocan conduct additional analysis, Becker said.

For More InformationThe National Association of Clean Air Agencies’ model CleanPower Plan rule is available at http://src.bna.com/fuv.—By Andrew Childers, Bloomberg BNA

States Offer Clean Power Plan Model Rule Despite Stay

News Focus


The U.S. Environmental Protection Agency’s (EPA) first-evermethane emission limits for new oil and gas wells will take effect Aug. 2, according to a final rule published in the Federal Register June 3.

The agency is regulating methane emissions from new andmodified wells as part of new source performance standards(RIN:2060-AS30) issued under Section 111(b) of the U.S.Clean Air Act.

With that, EPA also is publishing rules on aggregating oil and gas emissions sources for the purpose of permitting(RIN:2060-AS06), as well as a federal plan to manage somepermitting in Indian Territory (RIN:2060-AS27).

Methane is a short-lived greenhouse gas that is 25 times morepotent than carbon dioxide over a 100 year period, accordingto EPA. The new source performance standards require newand modified wells to develop leak monitoring plans and aninitial leak survey within a year or within 60 days of startupand twice annually after that. EPA informally released therules May 12.

Industry Considering LitigationHoward Feldman, senior director of regulatory and scientificaffairs at the American Petroleum Institute, said, “We will beconsidering all of our options” when asked if the trade association planned on pursuing litigation against themethane regulations.

Feldman referred to the new source performance standardsas “unnecessary,” contending the industry is already reducingmethane emissions without EPA regulations.

Felice Stadler at the Environmental Defense Fund also calledlitigation likely.

The petroleum industry estimates the new source performancestandards will affect “tens of thousands” of new wells eachyear. The industry’s more pressing concern is EPA’s upcomingstandards for existing sources, which could set emissions limits for 900,000 active wells.

Aggregation of Oil, Gas SourcesThe rules published June 3 also define when oil and gasemissions sources should be aggregated for the purposes ofClean Air Act permitting. Smaller emissions sources that areunder common control and are deemed “adjacent” can beaggregated for the purposes of prevention of significant deterioration, new source review and Title V permitting.

While smaller sources individually would be subject to minorsource permitting requirements, aggregating them can forcethem to comply with the more stringent major source provisions.

EPA’s final rule defines “adjacent” as equipment and activitiesthat are under common control and are on the same site orsites and within a quarter mile of each other.

For More InformationEPA’s new source performance standards rule is available athttp://src.bna.com/fxR.

EPA’s permitting aggregation rule is available athttp://src.bna.com/fxS.

EPA’s federal implementation plan is available athttp://src.bna.com/fye.—By Ben Remaly, Bloomberg BNA

EPA Publishes Methane Regulations for New Oil, Gas Wells

News Focus is compiled from the current edition of Environment Reporter, published by the Bureau of National Affairs Inc.(Bloomberg BNA). For more information, visit www.bna.com.

The regulation putting in place Ontario’s cap-and-tradeprogram for greenhouse gases formally takes effect July 1,2016. Emissions will be capped beginning January 1, 2017.The first compliance period will run through December 31,2020. Following that, regulated companies will have 11 monthsto deliver a mix of emission allowances and offset credits tocover their 2017–2020 emissions. Those who fail to do sowill bear a heavy cost.

Facilities that emit 25,000 tons or more of greenhouse gasequivalent (GHGe) per year are required to participate in thecap-and-trade program. Facilities that emit between 10,000and 25,000 tons of GHGe per year may choose to opt in as

voluntary participants. The province expects that the programwill affect 82 percent of Ontario’s carbon emissions.

Ontario’s carbon market will begin operation as an Ontario-only market, eventually integrating with the Western ClimateInitiative (currently, Quebec and California) when the programsof the three jurisdictions are sufficiently aligned. Ontario hasstated that it will follow the lead of the Western Climate Initia-tive, matching its floor price for allowances and raising thatfloor price year over year by the rate of inflation + 5 percent.At the most recent Western Climate Initiative auction, allowances sold at the floor price of $16.40. em

Ontario Government Puts a Price on Carbon

BC Proposes Revisions to Process for Identifying Contaminated SitesThe British Columbia (BC) Ministry of Environment has issuedan intentions paper identifying some of the ways it is proposingto change the way the province identifies contaminated sites.The proposed changes are based on a discussion paper issuedby the ministry in October 2014 and the resulting consultation.

The current regime for identifying contaminated sites is referredto as a “site profile process” and has been in effect since 1997.It is founded on a series of legal provisions set out in the Environmental Management Act and the Contaminated SitesRegulation (BC Reg. 375/96).

Problems with the current site profile process include a multi-step process, which is confusing, inefficient, and burdensomefor all involved; uncertainty and inconsistency due to variabilityin local government bylaws and permitting processes; and thefact that too many triggers can initiate the site profile process,many of them trivial.

Although the site profile process was intended to ensure thata parcel of land was investigated and remediated before its reuseor development, in practice the process is overly conservative,capturing too many sites where no land use change is beingplanned, requiring significant ministry resources to administer.

The new process, on the other hand, will be called a “siteidentification process” and is being created with the followingpriorities in mind: create a process for identifying contaminatedsites that is consistent across British Columbia; provide stake-holders with an automatic, predictable process; and writeclear requirements directly into the legislation.

The complete intentions paper, “Identification of ContaminatedSites,” is available online at http://www2.gov.bc.ca/assets/gov/environment/air-land-water/site-remediation/docs/requests-for-comments/site_id_intentions_paper.pdf. Comments willbe accepted until July 31, 2016. The Ministry will review allcomments received and propose legislative and regulatoryamendments some time in 2017, or possibly later. em

Canadian Report


Following findings from the Commission on HydraulicFracturing, the government of New Brunswick (NB) has announced it is extending indefinitely its moratorium on hydraulic fracturing (fracking) for shale gas.

In 2015, the government appointed members to the com-mission to study fracking and determine whether the fiveconditions set by the government can be met. The governmenthad said that the moratorium would not be lifted unlessthere is:

1. a social license;2. credible information about the impacts of fracking on public

health and the environment, allowing the government todevelop a regulatory regime with sufficient enforcementcapabilities;

3. a plan that mitigates the impacts on public infrastructureand addresses issues such as wastewater disposal;

4. a process to respect the duty of the government to consultwith First Nations; and

5. a mechanism to ensure that benefits are maximized forNew Brunswickers, including the development of a properroyalty structure.

Before the government can consider whether a fracking projectmeets the five conditions, it must implement the findingsfrom the commission, which include:

• creating an independent regulator mandated to strengthenNew Brunswick’s monitoring and evaluation of shale gasdevelopment in terms of understanding cumulative effects,including impact on human health and the environment;

• assigning adequate resources to properly plan for potentialpublic infrastructure impacts;

• determining short-term and long-term solutions to hydrauli-cally fractured wastewater before beginning commercialproduction; and

• working with Aboriginals in New Brunswick to adopt a nation-to-nation consultation process for fracking. em

NB Extends Moratorium on Fracking Following Commission Findings

BC Proposes Revisions to Process for Identifying Contaminated SitesThe British Columbia (BC) Ministry of Environment has issuedan intentions paper identifying some of the ways it is proposingto change the way the province identifies contaminated sites.The proposed changes are based on a discussion paper issuedby the ministry in October 2014 and the resulting consultation.

The current regime for identifying contaminated sites is referredto as a “site profile process” and has been in effect since 1997.It is founded on a series of legal provisions set out in the Environmental Management Act and the Contaminated SitesRegulation (BC Reg. 375/96).

Problems with the current site profile process include a multi-step process, which is confusing, inefficient, and burdensomefor all involved; uncertainty and inconsistency due to variabilityin local government bylaws and permitting processes; and thefact that too many triggers can initiate the site profile process,many of them trivial.

Although the site profile process was intended to ensure thata parcel of land was investigated and remediated before its reuseor development, in practice the process is overly conservative,capturing too many sites where no land use change is beingplanned, requiring significant ministry resources to administer.

The new process, on the other hand, will be called a “siteidentification process” and is being created with the followingpriorities in mind: create a process for identifying contaminatedsites that is consistent across British Columbia; provide stake-holders with an automatic, predictable process; and writeclear requirements directly into the legislation.

The complete intentions paper, “Identification of ContaminatedSites,” is available online at http://www2.gov.bc.ca/assets/gov/environment/air-land-water/site-remediation/docs/requests-for-comments/site_id_intentions_paper.pdf. Comments willbe accepted until July 31, 2016. The Ministry will review allcomments received and propose legislative and regulatoryamendments some time in 2017, or possibly later. em

Canadian Report


Canadian Report is compiled with excerpts from EcoLog News and the EcoCompliance.ca newsletter, both published by EcoLog Information Resources Group, a division of STP Publications LP. For more Canadian environmental information, visit www.ecolog.com.


2016 Calendar of Events

Events sponsored and cosponsored by the Air & Waste Management Association(A&WMA) are highlighted in bold. For more information, call A&WMA Member Services at 1-800-270-3444 or visit the A&WMA Events Website.To add your events to this calendar, send to: Calendar Listings, Air & WasteManagement Association, One Gateway Center, 3rd Floor, 420 Fort DuquesneBlvd., Pittsburgh, PA 15222-1435. Calendar listings are published on a space-available basis and should be received by A&WMA’s editorial offices at leastthree months in advance of publication.

AUGUST16–19 Power Plant Pollutant Control “MEGA” SymposiumBaltimore, MD

SEPTEMBER20–23 A&WMA Southern Section Annual Meeting & Technical ConferenceBiloxi, MS

27–30 Atmospheric Optics: Aerosols, Visibility, and the Radiative BalanceJackson Hole, WY

OCTOBER4–6 35th Annual International Conference on Thermal Treatment Technologies & Hazardous WasteCombustors (IT3/HWC)Baton Rouge, LA

5–7 A&WMA Pacific Northwest Section 56th International ConferenceJuneau, AK

25–26 A&WMA Ontario Section Air and Acoustic Monitoring ConferenceWaterloo, Ontario

DECEMBER7–8 Vapor Intrusion, Remediation, and Site ClosureSan Diego, CA

JOURNALListed here are the papers appearing in the July 2016 issueof EM’s sister publication, the Journal of the Air & WasteManagement Association (JA&WMA). Visit our website formore information.

July 2016 • Volume 66 • Number 7

Review PaperCarbon dioxide capture on γ-Al2O3 materials prepared by solution-combustion and ball-milling processes

Technical PapersTechnology selection for infectious medical waste treatmentusing the analytic hierarchy process

A biochar-based medium in the biofiltration system: Removal efficiency, microorganism prorogation, and mediumpenetration modeling

Permeability test and slope stability analysis of municipal solidwaste at the Jiangcungou Landfill, Shaanxi, China

Reaction behavior of sulfur dioxide in the sintering processwith flue gas recirculation

Adsorption of elemental mercury vapors from synthetic exhaust combustion gas onto HGR Carbon

The effect of aged litter materials on polyatomic ion concentrationsin fractionated suspended particulate matter from broiler house

Carbon dioxide and mercury emissions from the scale modelof open dairy lots

Evaluation of the IMPROVE equation for estimating aerosollight extinction

Keep informed about the latest research and sign up for newcontent e-mail alerts.

To order your print copies of JA&WMA, visit us online.

2016 EVENTSVISIT WWW.AWMA.ORG FOR MORE INFORMATION

Save the Dates:35th International Conference on Thermal Treatment Technologies and Hazardous Waste Combustors (IT3/HWC)October 4-6, 2016 • Baton Rouge, LA

IT3 provides a forum for the discussion of state-of-the-art technical information, regulations, and public policy on thermal treatment technologies and their relationship to air emissions, greenhouse gases, climate change, renewable energy or alternative energy production, and sustainability.

Find more details at http://it3.awma.org.

Vapor Intrusion, Remediation, and Site Closure December 7-8, 2016 • San Diego, CA

This conference addresses the important technical considerations involving the vapor intrusion (VI) pathway, site remediation, and advancing the process of site closure.

Visit the website at http://siteclosure.awma.org.

Online Learning A&WMA o�ers many individual and serieswebinars taught by professional experts on the latest topics including air quality and permitting, condensables, air emissions, combustion, compliance, NOx, PM2.5, and more.

See what you can learn at www.awma.org/events-webinars.

Become an A&WMA Member

A&WMA members receive discounts on all of our meetings, events, and webinars, pluspublications, sections and chapters, and networking opportunities to propel your career to new levels.

Discover the bene�ts and join today! Go to www.awma.org/membership for details.

2016 Annual Conference & Exhibition June 20-23, 2016New Orleans, LA

Come together to join over 1,500 leading environmental professionals to share knowledge and advance the industry at the most comprehensive conference on environmentaltechnology and regulation. Make your plans to attend now! Conference highlights include:

Keynote Speaker: A. Stanley Meiburg, Acting Deputy Administrator, U.S. EPA Critical Review: Emissions from Oil and Gas OperationsTechnical Sessions: Research, Compliance, Practical SolutionsMini Symposium: Industrial Growth and Environmental StewardshipNetworking: Exhibit Hall, Grand Reception, YP/Student Events Visit http://ace2016.awma.org for the latest information.

Power Plant Pollutant Control and Carbon Management “MEGA” SymposiumAugust 16-19, 2016 • Baltimore, MD

With a focus on industry response to new operational and environmental challenges for power plants, and a streamlined format, the MEGA Symposium returns in 2016 through the combined e�orts of four key industry players – the Electric Power Research Institute (EPRI), the U.S. Environmental Protection Agency (EPA), the U.S. Department of Energy (DOE), and the Air & Waste Management Association (A&WMA).

Conference topics include: MATS Controls, Carbon Management and CO2 Control, Managing Variable Load. Byproduct Discharge Management, and SOx/NOx Particulate Controls.

Visit http://megasymposium.org for details.

Atmospheric Optics: Aerosols, Visibility, and the Radiative BalanceSeptember 27-30, 2016Jackson Hole, WY

This international conference will provide a technical forum on advances in the scienti�c understanding of the e�ects of aerosols on urban, regional, continental, and global-scale haze and the radiative balance. The conference will take a multipronged approach by encouraging scienti�c submissions (e.g., related to measurements, modeling, etc.) as well as submissions addressing regulatory and policy issues.

Six professional development courses o�ered on Monday, Sept. 26.

This conference includes an excursion to Grand Teton National Park and a night sky program. Visit the website at http://visibility.awma.org.


A&WMA HeadquartersStephanie M. GlyptisExecutive DirectorAir & Waste Management AssociationOne Gateway Center, 3rd Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-14351-412-232-3444; 412-232-3450 (fax)[email protected]

AdvertisingMeredith [email protected]

EditorialLisa BucherManaging [email protected]

Editorial Advisory CommitteeJohn D. Kinsman, ChairEdison Electric InstituteTerm Ends: 2019

John D. BachmannVision Air ConsultingTerm Ends: 2017

Robert BaslEHS Technology GroupTerm Ends: 2019

Prakash Doraiswamy, Ph.D.RTI InternationalTerm Ends: 2017

Ali FarnoudRamboll EnvironTerm Ends: 2017

Steven P. Frysinger, Ph.D.James Madison UniversityTerm Ends: 2019

Keith GaydoshAffinity ConsultantsTerm Ends: 2018

C. Arthur Gray, IIICP Kelco-HuberTerm Ends: 2016

Mingming LuUniversity of CincinnatiTerm Ends: 2019

Dan L. Mueller, P.E.Environmental Defense FundTerm Ends: 2017

Brian Noel, P.E.SABICTerm Ends: 2017

Blair NorrisAshland Inc.Term Ends: 2017

Teresa RaineERMTerm Ends: 2017

Anthony J. Sadar, CCMAllegheny County Health DepartmentTerm Ends: 2018

Golam SarwarU.S. Environmental Protection AgencyTerm Ends: 2019

Susan S.G. WiermanMid-Atlantic Regional Air Management AssociationTerm Ends: 2018

James J. Winebrake, Ph.D.Rochester Institute of TechnologyTerm Ends: 2018

Layout and Design: Clay Communications, 1.412.704.7897

EM, a publication of the Air & Waste Management Association, is published monthly with editorial and executive offices at OneGateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435, USA. ©2016 Air & Waste Management Asso-ciation (www.awma.org). All rights reserved. Materials may not be reproduced, redistributed, or translated in any form withoutprior written permission of the Editor. A&WMA assumes no responsibility for statements and opinions advanced by contributorsto this publication. Views expressed in editorials are those of the author and do not necessarily represent an official position ofthe Association. A&WMA does not endorse any company, product, or service appearing in third-party advertising.

EM Magazine (Online) ISSN 2470-4741 » EM Magazine (Print) ISSN 1088-9981

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