Hi Diane,
Thank you for the opportunity to provide comments. We appreciate and support the work you’re doing to reach the governor’s goals for reducing Washington’s contribution to global warming. This email provides questions and technical comments t...↓
Applicability:
- For projects with little or no onsite combustion (such as some stores, schools, and offices), consider adding an exemption based on building square footage instead of requiring GHG calculations. Such calculations may be simple for environmental professionals but difficult for applicants unused to performing them. The attached spreadsheet demonstrates some of that complexity. An exemption based on square footage seems appropriate for projects where the majority of GHGs come from onsite electric use.
- Emergency generators – Emergency generators are ubiquitous throughout Washington. We understand the need to cover larger generators in the rule. However, smaller units would likely be exempt based on their emissions. For smaller units like those in retail stores, gas stations, and cell phone towers, consider an exemption based on engine horsepower to make it easier for applicants. The attached spreadsheet demonstrates some of the complexity applicants may run into.
o Please also consider whether there are any categories of emergency generators that would be exempt due to their essential nature. Potential examples include engines to power pumps for fire suppression and sewage lift stations.
o For other, larger, units consider additional guidance on how to calculate GHGs. Since many emergency generators don’t have permitted usage limits, it would be helpful to specify the hours/year of operation and engine load to use in calculations. (The attached spreadsheet for the Fred Meyer generator assumes 500 hr/yr operation since that’s what we traditionally think of as a realistic upper bound for emergency use.)
- Gas stations are some of the most commonly permitted facilities by air agencies like NWCAA. There are more than 200 stations in our jurisdiction alone. Each permit application requires SEPA review and would therefore require the corresponding GAP rule applicability review.
o Consider providing more information about how to calculate applicability (what’s considered and input and output) and mitigation. More specifically, since the output from the gas station is gasoline that enters a fuel tank, would a gas station need to calculate emissions from the fuel burned by on-road vehicles that filled up at the station? If yes, how should a new gas station estimate the amount of fuel it may sell in the future? For inputs, do the emissions from transporting fuel from the refinery to the gas station count? What about the emissions from refining the fuel? The attached spreadsheet demonstrates the complexity and summarizes emissions from both an average gas station in our area as well as a large (Fred Meyer) station.
o Some independent gas stations don’t have the technical knowledge to do applicability calculations, nor the financial backing to hire a consultant. In addition, English may be a second language, which provides an additional barrier. Consider building a workbook that station owners could fill out that would automatically calculate their emissions to ease the compliance burden.
- Consider a technical assistance program to provide small businesses like independent gas stations with hands-on help with GAP rule calculations. Numerous small businesses go through SEPA review each year and may benefit greatly from technical assistance.
- In general, and as noted for the gas station example, consider providing more information about what is (and isn’t) an “input” and an “output” for rule applicability.
Funding:
- SEPA lead agencies are frequently Cities and Counties without GHG expertise. In our experience, lead agencies may reach out to technical experts like NWCAA to help review GHG calculations. NWCAA agrees with our City and County partners that we are the obvious technical expert to ask and we are certainly willing to assist. Each local Clean Air Agency in this position will likely need to identify the appropriate funding source for this work – which may take the form of a fee. Similar comments apply to the GHG mitigation verification should that fall to the local CAAs. We are happy to do the work, but know that it has to be funded through an adequate and appropriate mechanism.
Mitigation:
- Mitigation - As noted in Table 2 of the Framework, the 10,000 metric ton threshold will capture projects with gas-fired boilers and heaters that meet or exceed 21.2 MMBtu/hr. Units in this size range are used in a variety of operations throughout Washington. Examples include wood products, milk processing, and hospitals. Applicants for some of these projects may not have the level of GHG expertise that’s available for larger projects like the Tacoma LNG facility. For small to medium projects, consider providing a simplified formula based on the size of the boiler/heater to determine how much to mitigate instead of the full mitigation calculations required for larger projects.
- Mitigation cost - The GAP rule encourages mitigation within Washington. However, GHG is a global pollutant and in-state mitigation may be more costly than out-of-state mitigation. Consider adding a mechanism to evaluate the cost of mitigation to encourage projects that provide the greatest reductions for the lowest cost.
- Mitigation baseline emission calculations – As seen in major source (PSD) permit reviews, there are many different ways to calculate baselines. Consider providing more specificity on how to perform calculations to avoid questions down the road.
- Mitigation Verification – Consider adding a mechanism for how multi-year mitigation will be verified, including who will perform the verification. Verification may be outside the technical expertise of many SEPA lead agencies.
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