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RGGI Draft Model Rule Offset Comments from Environment Northeast

RGGI Draft Model Rule Offset Comments from Environment Northeast. Regional Greenhouse Gas Initiative Stakeholder Meeting Hartford, CT May 2, 2006 Derek Murrow Director, Policy Analysis. Offsets Issue 1 Afforestation – Permanence.

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RGGI Draft Model Rule Offset Comments from Environment Northeast

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  1. RGGI Draft Model RuleOffset Comments from Environment Northeast Regional Greenhouse Gas Initiative Stakeholder Meeting Hartford, CT May 2, 2006 Derek Murrow Director, Policy Analysis

  2. Offsets Issue 1 Afforestation – Permanence • Issue: Conservation easements are flexible and should include language specific to carbon retention, with a particular focus on timber harvesting • Goal: Maintain a constant level of carbon sequestration after offsets project monitoring has ceased • Recommendation: • The Conservation Easement should state that no significant timber harvest should be allowed, or if timber is harvested, a management plan should be developed with a % stocking or carbon based requirement to keep the same quantity of timber (carbon) on the property as was present during the last offset monitoring and verification audit • Concept Proposal (needs input from others): Drop the 20% discount if the developer purchases a state approved insurance policy to cover natural disturbances over a set period (i.e. 100 years) that includes monitoring (allow for new technology advances like remote sensing); the insurance company would have to retire allowances equal to carbon loses on a regular monitoring and reporting schedule (i.e. five years) RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

  3. Offsets Issue 2 Afforestation – SFI and FSC Certification • Issue: SFI and FSC are designed to accredit forests that are actively managed for timber harvesting • Goal: Avoid negative environmental impacts • Recommendation: The easement should state that forestlands should not be commercially harvested unless they achieve SFI or FSC certification (no certification required if harvesting does not occur) RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

  4. Offsets Issue 3Energy Efficiency – Additionality • Issue: Projects that receive public financing in whole or in part are not likely to be additional (a detailed assessment would be required of each project and would be quite burdensome) and the Model Rule should address financing sources in addition to system benefit funds • Goal: Promote new efficiency projects that would not otherwise occur • Recommendation: • A bright line test should be in place that excludes all state, federal, or utility sponsored grants (SBC, utility programs, weatherization, DOE funded state grants to commercial entities, etc), which would avoid a complicated financial review and ensure that offset money promotes new investments in efficiency • Consider a review of this requirement after a set number of years with consideration of a standardized financial additionality test if the project also receives state or federal support RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

  5. Offsets Issue 4Energy Efficiency – Additionality (2) • Issue: The rule is not clear and explicit (within the formulas) about how baseline energy use is calculated when a state or federal code or standard is in place for that equipment • Goal: Develop a clear and simple way to describe the role of codes and standards in additionality calculations • Recommendation: Include the code or standard adjustment directly in the baseline energy use formulas, as most of the new equipment installed will have to meet state or federal appliance and equipment standards RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

  6. Offsets Issue 5 Methane from Agriculture – Accounting • Issue: The rule is clear that “regional-type digesters” are acceptable, but does not account for GHG emissions due to transporting manure to a central site (this appears to be the only offset type that has significant emissions from O&M) • Goal: Ensure that all project GHG emissions are captured in the accounting protocols • Recommendation: Require “regional-type digesters” from multiple farms to account for transport GHG emissions based on a standardized emissions factor to transport one ton of manure, one mile (distance easily measured and mass already reported) RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

  7. Derek K. Murrow Director of Policy Analysis dmurrow@env-ne.org Michelle E. Lichtenfels Policy Analyst mlichtenfels@env-ne.org Contact Information Environment Northeast 101 Whitney Ave. New Haven, CT 06510 (203) 495-8224 Rockport, ME – Boston, MA – Hartford, CT www.env-ne.org RGGI Stakeholder Meeting, Hartford, CT, May 2, 2006

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