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Current GHG Mitigation Requirements for Power Plants in Washington and Oregon

Presented by Liz Thomas at NIPPC Annual Meeting Sept. 7-8, 2005. Current GHG Mitigation Requirements for Power Plants in Washington and Oregon. Overview. Washington’s current law Prior approaches in Washington Oregon’s law Observations. Application of Washington’s Current CO2 Mitigation Law.

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Current GHG Mitigation Requirements for Power Plants in Washington and Oregon

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  1. Presented by Liz Thomas at NIPPC Annual Meeting Sept. 7-8, 2005 Current GHG Mitigation Requirements for Power Plants in Washington and Oregon

  2. Overview • Washington’s current law • Prior approaches in Washington • Oregon’s law • Observations

  3. Application of Washington’s Current CO2 Mitigation Law • New projects: • > 350 MW: EFSEC - ch. 80.70 RCW • No EFSEC rules yet – no funding • 25 MW – 350 MW: Ecology or Clean Air Agency applies ch. 80.70 RCW via RCW 70.94.892 and WAC 173-407 • Expansion of existing projects: • If now > 350 MW, 15% increase in CO2 emissions • If now 25-350 MW, 25 MW increase or 15% increase in CO2 emissions • Mitigation required only for increment

  4. Substance of Washington Requirements • Applicant must prepare a CO2 mitigation plan to offset 20% of CO2 emissions over 30 years • Theoretically, 3 paths available: • Pay third party $1.60/T • Purchase credits • Invest in CO2 mitigation projects • No rules yet for Path 2 or Path 3 due to lack of EFSEC funding for rulemaking

  5. Prior Washington Practice • EFSEC required mitigation of CO2 emissions on a case-base-case basis • PSCAA sought mitigation pursuant to SEPA authority

  6. Application of Oregon Requirements • EFSC jurisdiction for all projects > 25 MW – no split implementation. • Per OAR 345-024-0500 et seq. • 3 standards: • Base load gas plants: 0.675 lb. CO2 / kWh • Non-base load gas plants: 0.675 lb. CO2 / kWh • Nongenerating facilities (e,g., compressor stations): 0.504 lb. CO2 / horsepower-hour

  7. Substance of Oregon Requirements • Offset emissions in excess of standards, based on 30 years’ assumed operations • Complex formulae to calculate emissions and offsets • Paths: • Implement CHP to offset equivalent emissions • Offset projects – direct or 3rd party • Monetary (Climate Trust) - $0.85/T

  8. Observations • Rules address only CO2, not other GHGs • Rules generally address only power plants, but both states are addressing car emissions • Seek “no lookback” protection • No WA offset projects until legislature appropriates funds for EFSEC rulemaking • How to integrate into regional trading program?

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