Climate Change Work Grou

Report to the CAAAC

Mark MacLeod – EDFEric Svenson – PSEGPeter Tsirigotis – EPA

February 2nd & 3rd, 2010
Agenda

• The Charge

• Caveats• Organizing the Work

• Work Group Recommendations

• Recommend the Report to EPA

• Thoughts on Phase II
The Charge

• Identify the major issues and potential barriers to

implementing the PSD Program under the CAA for

greenhouse gases. [Phase II]

• Identify information and guidance that would be use

EPA to provide concerning the technical, economic, 

environmental performance characteristics of poten

options. [Phase I]

• Identify approaches to enable state and local permit

authorities to apply the BACT criteria in a consistent

and efficient manner. [Phase I]
Caveats
Organizing the Work

• Defining the Source: What is the source that is being analyz

controls?

• Criteria for Determining Feasible Control Technologies: Wh

technologies are demonstrated in practice and what criteria 

used to determine the technological feasibility of a control m

• Criteria for Eliminating Technologies: How do technologies 

eliminated from consideration in the BACT analysis based on 

energy, environmental or other impacts?

• Needs of States and Stakeholders:

– What are the States’ technical information and data needs regard

control and mitigation measures in the context of determining BA

– What steps can be taken to expedite, streamline or provide addit

certainty in the BACT process, especially for existing sources give

PSD permitting involves existing sources rather than new greenfie
Highlights

• Guidance requested from EPA

• Discussion on Defining the Source• Affirming that the use of the existing EP

approved permitting authority BACT prfor GHGs does not create a new proces

• Needs of States and Stakeholders
Recommendations
Scope of Analysis:

Defining the “Source”

Don Neal, Calpine
Criteria for Determinin

Feasible Control Technolo

John McManus, AEP
Criteria for

Eliminating Technolog

Ann Weeks, CATF
Needs of States and Stakehold

John Paul, RAPCA
Recommend the Report to E
Phase II

We seek the advice of the CAAAC and EPA on continuation of the Work Group for a second phas

of topics, which could include, but not be limited to, the following:

• the scope of applicability of PSD and BACT to GHG sources,

• the appropriateness of using presumptive BACT standards for some/all GHG source cate

• whether it is permissible and appropriate to use averaging or trading (e.g., trading of qu

as a BACT mechanism itself or as a compliance flexibility option,

• the potential to credit towards BACT compliance (or for netting) appropriate reductions 

increased energy efficiency or demand reductions at other units within a facility (or amo

owned or operated facilities), across a larger range of sources (e.g., a regional electricity 

transportation system) or at the customer level (e.g., through a smart grid strategy and 

• how should BACT reviews be conducted and permit conditions established to encourage 

and promote the use of innovative control technologies for GHGs, and

• evaluating energy efficiency processes and practices as part of the top‐down BACT dete

including: benchmarking to help guide the consideration of energy efficiency; potential 

standards and policy designed to provide incentives for more efficient solutions, such as 

power, combined cycle turbines and equipment; and, identifying practices and projects 

deploying efficient and low‐emitting solutions.