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Emissions Standards for Distributed Generation

Emissions Standards for Distributed Generation. Harrisburg, PA 16 June 2003. Baseline Issue: New vs Existing DG. New DG: Addressed by proposed model rule Existing: What is the environmental driver/concern? What is the affected inventory? What are the compliance options?

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Emissions Standards for Distributed Generation

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  1. Emissions Standards for Distributed Generation Harrisburg, PA 16 June 2003 Website: http://www.raponline.org

  2. Baseline Issue: New vs Existing DG • New DG: • Addressed by proposed model rule • Existing: • What is the environmental driver/concern? • What is the affected inventory? • What are the compliance options? • Approaches for addressing the issue

  3. Treatment of New DG • Model Emissions Rule for New DG Projects • Funded by DOE/NREL • Developed by a public/private stakeholder group over a 2 year period • Available at www.raponline.org

  4. The Model Rulemaking: Purpose • Recognizing the role of DR in existing and restructured electricity markets • What concerns are being addressed? • Environmental protection and promotion of clean DR • Administrative simplicity and consistency between states • Promoting certification of small engine conformance to clean standards • Promoting environmental technology advances by setting clear targets

  5. Principles Guiding Development of the Rule • The model emissions standards should: • Lead to improved air quality, or at least do no additional harm • Be technology-neutral and fuel-neutral, to the extent possible • Promote regulatory consistency across states • Reduced barriers  improved economic efficiency  greater environmental benefit

  6. Principles Guiding Development of the Rule • The model emissions standards should: • Promote technological improvements in efficiency and emissions output • Encourage the use of non-emitting resources • Account for the benefits of CHP and the use of otherwise flared gases • Be easy to administer • Facilitate the development, siting, and efficient use of DR

  7. Key Issues:Applicability • What types of sources should be covered? • New only • What sizes of generators should be addressed? • Anything not covered by federal NSR • What functions should be covered? • Emergency and non-emergency

  8. Key Issues:Emissions • What are “appropriate” emissions standards? • Better than grid average, as good as new BACT for large combined cycle sources, LAER? • A middle ground that pushes technology to beat expected improvements over the next decade • Credits for flared fuels, CHP, renewables and end-use efficiency • Pollutants: NOX, PM, CO, CO2, SO2

  9. Proposed Emissions Limits • Emergency Generators • 300 hours annual operation • 50 hours annual maintenance (included in the 300 total) • EPA off-road engine standards, expressed in pounds/MWh

  10. Proposed Emissions Limits • For NOX, PM, CO, CO2: • Output-based limits: pounds per MWh • For SO2: • Diesel is the issue • Ultra-low sulfur fuel requirement following EPA on-road requirements • Technology review prior to Phase Three

  11. Proposed NOX Limits(lbs/MWh) * Subject to Technology Review

  12. Proposed PM LimitsNon-Gas only (lbs/MWh) * Subject to Technology Review

  13. Proposed CO Limits (lbs/MWh) * Subject to Technology Review

  14. Proposed CO2 Limits (lbs/MWh) * Subject to Technology Review

  15. Treatment of Existing DG • What is the environmental driver/concern? • Most often non-emergency use of diesels • What inventory is affected? • Is there much non-emergency DG to be addressed? • What are the control options/cost? • Typically fewer options/higher cost than new DG or existing larger sources

  16. Issues with Expanded Use of Diesel Gensets • Poor inventory of existing diesels • Existing diesel units changing from strict emergency use to: • Participation in demand response programs • Reliability and ancillary services • Does this create an environmental problem? • What are the current permit conditions?

  17. Addressing Expanded Useof Diesel Gensets • Require registration of all units • Clearly prohibit non-emergency use for uncontrolled units • Establish appropriate tracking protocols • Set additional compliance requirements for non-emergency uses

  18. Other Existing DG • Inventory of sources may be an issue • Likely to be many fewer non-emergency than emergency sources • How much of an environmental concern is there? • Historic approach to existing sources has been technology-specific and cost-limited (RACT)

  19. Addressing Other Existing DG • Small DGs may have very limited compliance options and high costs • Environmental impact may be low • Conventional RACT approach may yield minimal compliance requirements - NY rule • Alternative approach: Connecticut considering model rule’s attainment standards for existing DG

  20. Conclusions • The model rule provides an appropriate air regulation framework for new sources • Existing sources can be addressed through a mix of permit restrictions and conventional regulatory programs

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