Bakersfield’s industries are bracing for the upcoming requirements of the California Air Resources Board’s (ARB) new Cap and Trade regulations. Soon, those industries that emit over 25,000 metric tons per year of greenhouse gases (GHG) will see their allowed emissions, or “cap,” be reduced every year until targeted levels are reached.
However, those requirements don’t seem to matter much in the everyday world of local air permitting. For example, the San Joaquin Valley APCD has asked for public comments on a few new oil development projects for which they are about to issue permits. As part of the review process for CEQA purposes, the APCD has stated that these projects pose no significant environmental impacts and as a result has proposed Negative Declarations for the projects.
For example, Chevron has proposed an expansion of its thermally enhanced crude oil operations in the Cymric oilfield. According to the APCD’s Negative Declaration, eleven new gas fired steam generators will be installed (total heat input = 912.5 MMBTU/Hr). The generators will result in emission increases of VOC (21.99 tons/yr), NOx (33.98 tons/yr), and PM10 (12.8 tons/yr). Because those increases exceed allowable levels, Chevron will offset those increases with emission reduction credits (ERCs) at a 1.5:1 ratio.
However, emission increases of GHG are another story. The Negative Declaration does not say what the increase in GHG emissions from the project will be. Except for minor amounts of construction related emissions (see below), no estimate at all is given for operational GHG emissions.
The reason appears to be two policies adopted by the APCD that deal with the analysis of GHG emissions from new projects. The first, APR 2005, states that GHG emissions are considered to be insignificant if Best Performance Standards (BPS) are used. Furthermore, the policy states that if the project does not require an Environmental Impact Report (EIR), the increase in GHG emissions does not even have to be calculated.
The second policy, APR 2015, says that GHG emissions that are less than 230 metric tons/yr are considered to be zero.
Based upon these two policies, the APCD calculated that GHG emissions from Chevron’s construction activities would be zero (157 metric tons/yr = 0). Additionally, because the steam generators will use BPS (presumably gas firing with low NOx burners), the operational emissions were deemed to be insignificant and not calculated.
If the APCD had calculated the emissions, and if it had published those numbers, one would see that the new steam generators will emit a maximum of 470,000 tons/yr of CO2 (based upon USEPA AP-42 emission factors). It’s curious (to me at least) that the APCD would go to the trouble to show it’s calculations for GHG construction emissions in its report but not the GHG operational emissions, which are several orders of magnitude greater.
As background, Chevron’s San Joaquin Valley oil production operations already emit millions of tons/yr of GHG. An increase of 470,000 tons/yr (426,000 metric tons/yr) is not insignificant, statistically. According to the ARB’s most recently published GHG Emission Inventory, crude oil and natural gas production operations emitted about 17 million metric tons/yr of CO2 (eq). Chevron’s project represents about a 2.5 % increase in that number. (Total state-wide inventory from all sources is about 475 million metric tons/yr.)
Recalling that ARB’s new Cap and Trade program applies to sources that emit 25,000 metric tons/yr, the increase in emissions from Chevron’s project alone is equivalent to adding 17 new sources to the cap and trade program. Nevertheless, according to APCD policy, that’s not significant. What do you think? Should such emission increases be reported to the public or not whenever the APCD issues its analysis of similar projects?
The APCD is accepting written comments on its proposed negative declaration until Jan. 20, 2012. For more information: APCD Public Notice, Draft Negative Declaration