By Richard Denison

Richard Denison, Ph.D., is a Lead Senior Scientist.

Environmental Defense Fund yesterday submitted questions to EPA that we hope are answered by the agency at the public meeting it is convening on December 6th on changes to its new chemicals reviews.

Despite providing some new documents in advance of the public meeting, details about EPA’s new policies and practices for reviewing new chemicals under the reforms made to TSCA by the Lautenberg Act remain scant.  We identified a number of serious concerns when these changes were first announced by Administrator Pruitt in a news release issued on August 7 – concerns that the meeting background materials EPA has provided only serve to heighten.

The questions we submitted today relate to our concerns in the following topics:

• The statutory and scientific basis for EPA’s new policies, the timing of their application, and omissions from the new framework
• EPA’s plan to use so-called “non-5(e) SNURs” in lieu of consent orders
• Recent policy changes not included in EPA’s agenda for the public meeting
• Public access to information
• Confidential business information claims
• Use of section 5(e) SNURs

EDF has been raising concerns for some time now over the recent redirection of the new chemicals program starkly away from the approach taken following last year’s enactment of the Lautenberg Act.

Many of the questions we’ve just submitted were formally submitted by letter to EPA’s Office of Pollution Prevention and Toxics (OPPT) more than 3 months ago, on August 16, 2017.  Unfortunately, we have yet to receive responses to them.  We hope they will be addressed at the December 6th meeting.

Written by Lisa Sharp

I live in Oklahoma and the oil and gas industry plays a big role in my life. Not only do I depend on fossil fuels to run my life, energy production is the leading industry in Oklahoma. Approximately, one-quarter of working Oklahomans are employed directly...

We need just one more Senator to block one of Trump's most dangerous EPA nominees. Regional. C4.

We need just one more Senator to block one of Trump's most dangerous EPA nominees. Regional. C4.

We need just one more Senator to block one of Trump's most dangerous EPA nominees. Regional. C4.

We need just one more Senator to block one of Trump's most dangerous EPA nominees. Regional. C4.

This is big. And your representative played a crucial role. Regional. C4.

This is big. And your representative played a crucial role. Regional. C4.

By EDF Oceans

The fortunes of people everywhere are inextricably linked to the oceans.  Overfishing remains one of the world’s most pressing environmental challenges, but around the world we are seeing incredible progress toward sustainable fishing.

On World Fisheries Day, we wanted to share fives stories from the past year that inspire us:

 

1) Belize continues to be a leader when it comes to ocean sustainability after announcing bold new commitments at the United Nations Oceans Conference in June. This announcement included voluntary commitments from the government of Belize which will secure their fisheries as an engine for sustainable development and poverty alleviation. Belize has already made major steps to protect its magnificent barrier reef, and the biodiversity and fisheries that live there. In doing so it has established itself as a global leader in small-scale fisheries management. These new commitments will secure those gains and strengthen the foundation for good governance of fisheries so that they continue to provide jobs, food, and income for fishing communities.

 

2) Two more rockfish species from the U.S. Pacific groundfish fishery have been declared “rebuilt” well ahead of schedule. The fishery, which includes species of sole, flounder and rockfish, was declared a federal disaster in 2000. Now, nearly two dozen important species are certified as sustainable to eat, and just this year Bocaccio and Darkblotched rockfish were declared rebuilt. The National Oceanic and Atmospheric Administration attributes the recovery to a combination of habitat protection and the secure fishing rights program implemented in 2011. Commercial and recreational fishermen – who have worked for years to avoid catching the species in order to rebuild populations – will soon be much freer to harvest them. This means that commercial fishermen can supply consumers with these beautiful, delicious, sustainable rockfish and that recreational fishermen will have more opportunities to catch them. This success is just the latest of many for the West Coast groundfish fishery.

 

3) Sustainable fishing commitments in the Philippines. The Philippines recently announced it has partnered with EDF to implement sustainable fishing reforms based on science. More than 70 percent of fish stocks in the Philippines, for which there are data, are considered overfished. Science-based fishing reforms can put the Philippines on the road to improved food security for the millions of Filipinos who depend on fish as a source of food and for their livelihoods.  This monumental step forward for the Philippines can set an example for how to build policies that can improve food security and provide economic prosperity, while at the same time recover fisheries.

 

4) New online trainings from our own Fishery Solutions Center will help practitioners around the world manage their fisheries sustainably. The Virtual Fisheries Academy is a brand new, free online learning center that allows stakeholders to build upon their existing knowledge in order to develop fishery management solutions tailored to their own fisheries. Since we launched the Academy in September, more than 250 fishery practitioners from 52 countries have signed up to take the courses. We are excited to see how these stakeholders apply what they learn to enable good fishery governance around the globe. To learn more about the Virtual Fisheries Academy, join our Open Channels webinar on December 5th.

 

5) By getting fishing right today, we can help ensure a more resilient ocean world tomorrow. Climate change will cause undeniable shifts and changes to global fisheries—threatening the people who depend on them most for food security and nutrition. The good news is that with practical solutions, we can increase the number of fish in the sea, the amount fish on the plate, and prosperity even in the face of climate change. Preliminary research from EDF, Oregon State University, and the University of California Santa Barbara shows that cooperation and responsive management are needed to ensure these benefits, but we are confident and hopeful that countries can come together and find solutions that work for fishing communities all over the world.

 

The fortunes of people everywhere are inextricably linked to the oceans.  Overfishing remains one of the world’s most pressing environmental challenges, but around the world we are seeing incredible progress toward sustainable fishing. On World Fisheries Day, we wanted to share fives stories from the past year that inspire us:   1) Belize continues to […]

The fortunes of people everywhere are inextricably linked to the oceans.  Overfishing remains one of the world’s most pressing environmental challenges, but around the world we are seeing incredible progress toward sustainable fishing. On World Fisheries Day, we wanted to share fives stories from the past year that inspire us:   1) Belize continues to […]

By amymorse

When I worked on the trading floor at Goldman Sachs, one of the major services we provided our corporate clients was risk management. Sitting on the commodity desk, we bought and sold financial products that allowed the world’s biggest consumers and producers to manage their exposure to the often fluctuating price of natural resources like aluminum, crude oil, and natural gas. Companies take action to manage this price risk in order to provide long-term stability for the company and its investors.

Now as a member of the EDF+Business team, I focus on a different kind of risk: climate risk. And just like financial risk, it needs to be managed for the long-term benefit of all stakeholders involved.

Kate Gaumond, Analyst, EDF+Business

Methane Risk is Climate Risk

Investors are catching on, recognizing that information about climate risk is vital to maintaining robust portfolios of well-managed companies. And for investors to be serious on climate, they have to be serious not just on carbon dioxide, but on methane as well.

Beyond contributing to climate change, methane poses a specific reputational risk to the long-term future of the oil and gas industry. Oil and gas operators are betting on the idea that natural gas could be the cleaner burning fuel of the future. However, until the methane problem is fixed, operators are leaking away much of the climate benefit of natural gas, and tarnishing their product’s brand of “clean” energy.

Fortunately, investors have a unique business-minded voice, and important power, to influence industry and policymakers to ensure that climate risk, like any other material risk, is managed and disclosed to everyone’s gain.

From Goldman Sachs to @EDFBiz: How @Kate_Gaumond is leveraging her expertise to understand how…
Click To Tweet

Shareholder Resolution Successes

One kind of powerful leverage investors have to call for better methane management is through direct company engagement. This engagement can involve collaborative problem-solving between investors and operators to best address methane risk. Another route is shareholder resolutions. In 2017, investors filed 17 total methane resolutions with companies across the natural gas value chain. And this year these resolutions had unprecedented success.

The resolutions that went to a vote achieved near majority turnout. Resolutions for ExxonMobil, Kinder Morgan, and Occidental all received roughly 40% votes. And while those votes do not obligate a company to respond, the investor voice is a persuasive one to management. When 40% of a company’s shareholder base wants information, it is in the company’s best interest to act. For example, just months after the near 40% vote on methane, ExxonMobil announced a sensible and innovative plan to manage methane emissions on all upstream and midstream XTO assets. Investors spoke and management listened.

Methane management disclosure still has room to improve. The oil and gas industry prides itself on continuous improvement, and investors must hold these companies to high standards on methane risk management, calling for clear reduction targets and detailed action plans on how to achieve them.

Regulations and Returns

Not limited to company engagement, investors can use their voice to advocate for sensible and effective policy as well. In an industry as fragmented as oil and gas, investors understand that smart, common-sense methane rules are necessary to ensure that the best operational practices are standard across the industry, minimizing the risk of long-term reputational damage to natural gas. In 2017, investors engaged on policy at the state, national, and international level. Investors testified in front of EPA hearings to stop short-sighted attempts at delaying US federal methane rules. Internationally, investors co-signed a letter to Canadian policymakers to strengthen the proposed methane rules in order to best protect investors’ stake in the oil and gas industry.

Especially considering today’s political environment, investors will need to continue to leverage their voice to make policy makers understand the business case for smart regulations. Investors have the unique ability to hold companies accountable for their public statements, and to their lobbying and trade association memberships that attempt to dismantle risk-reducing rules.

Looking to 2018

Investors understand the risk methane poses to their portfolio, and are increasingly tilting their portfolios towards companies that are seriously addressing climate risks like methane. Astute operators recognize this trend and are listening to the voices of their investors. The risks of unresponsiveness are too great to ignore. With the progress of 2017 as a springboard, operators should only expect investor engagement on this material risk to grow.

planning and investment. It’s about leadership. Will you make your voice heard?

Follow Kate and EDF+Business on Twitter.

Stay on top of the latest facts, information and resources for oil and gas industry investors. Sign up for our Methane Matters Investor Newsletter.

When I worked on the trading floor at Goldman Sachs, one of the major services we provided our corporate clients was risk management. Sitting on the commodity desk, we bought and sold financial products that allowed the world’s biggest consumers and producers to manage their exposure to the often fluctuating price of natural resources like […]

Don't let the Trump Administration take us backwards. Tell Scott Pruitt: Revoking the Clean Power Plan is unacceptable.

This post was co-authored by Maureen Lackner and originally appeared on the EDF Talks Global Climate blog. The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated. California’s emissions trends […]

The post California Bucks Global Trend with another Year of GHG Reductions appeared first on Market Forces.

This post was co-authored by Maureen Lackner and originally appeared on the EDF Talks Global Climate blog. The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated. California’s emissions trends […]

By Jonathan Camuzeaux

This post was co-authored by Maureen Lackner and originally appeared on the EDF Talks Global Climate blog.

The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated. California’s emissions trends are showing what is possible with strong climate policies in place and provide hope even as new analysis projects that global emissions will increase by 2% in 2017 after a three-year plateau.

California’s emissions kept falling in 2016

The 2016 emissions report, an annual requirement under California’s regulation for the Mandatory Reporting of Greenhouse Gas Emissions (MRR), shows that emissions covered by the state’s cap-and-trade program are shrinking, and doing so at a faster pace than in prior years. Covered emissions have dropped each year that cap and trade has been in place, amounting to 31 million metric tons of carbon dioxide-equivalent (MMt CO2e) over the whole period, or 8.8% reduction relative to 2012. The drop between 2015 and 2016 accounts for over half of these cumulative reductions (16 MMt CO2e; 4.8% reduction relative to 2015). The electricity sector is responsible for the bulk of this drop: electricity importers reduced emissions about 10 MMt CO2e while in-state electricity generation facilities reduced emissions by about 7 MMt CO2e.

Some sectors’ emissions grew in 2016. Just as with global transportation emissions, California’s transportation emissions have steadily crept up in recent years, and the MRR report suggests this trend is continuing. Transportation fuel suppliers, which account for the largest share of total emissions, reported a 1.8 MMt CO2e increase in emissions covered by cap and trade since 2015. Cement plants and hydrogen plants also experienced small increases in covered emissions. One of the benefits of cap and trade, however, is that if the clean transition is occurring more slowly in one sector, other sectors will be required to reduce further to keep emissions below the cap while the whole economy catches up.

Emissions that are not covered by the cap-and-trade program dropped, from 92 MMt CO2e in 2015 to 87 MMt CO2e in 2016. While small, this represents the largest reduction in non-covered emissions since 2012 and is mostly driven by suppliers of natural gas/NGL/LPG and electricity importers. Net non-covered and covered emissions reductions resulted in a 20.5 MMt CO2e drop in total emissions from these sectors.

These results are a welcome reminder that the cap-and-trade program is working in concert with other policies to accomplish the primary objective of reducing emissions.

The California climate policies are accomplishing their emissions reductions goals

The 2016 MRR data indicate impactful reductions in GHG emissions and progress toward reaching the state’s target emissions reductions by 2020. The 2016 emissions drop is a consequence of several factors: a CARB analysis of the year’s electricity generation points to increased renewable capacity, decreased imports of electricity from coal-fired power plants, and increased in-state hydroelectric power production. To put it in perspective, the 20.5 MMt CO2e emissions reductions is equivalent to offsetting the energy use of about 2.2 million homes, or 16% of California’s households.

Emissions below the cap are a climate win, not a concern

Total covered emissions in 2016 were about 324 MMt CO2e, well below California’s 2016 cap of roughly 382 MMt. Some observers of the cap-and-trade program worry that an “oversupply” of credits will result in reduced revenue for the state and lesser profits for traders on the secondary market. This concern was especially pronounced when secondary market prices dipped below the price floor in 2016 and 2017.

Importantly, oversupply of allowances is not a bad thing for the climate. As Frank Wolak, an energy economist at Stanford, points out, oversupply may be a sign of an innovative economy in which pollution reductions are easier to achieve than anticipated. Furthermore, having emissions below the cap represents earlier than anticipated reductions which is a win for the atmosphere. Warming is caused by the cumulative emissions that are present in the atmosphere so earlier reductions mean gases are not present in the atmosphere for at least the period over which emissions are delayed.

While market stability is a valid concern, the design of the program has built-in features to prevent market disruptions. Furthermore, the California legislature’s recent two-thirds majority vote to extend the cap-and-trade program through 2030 provides long-term regulatory certainty. Both the May and August auctions were completely sold out suggesting that the extension has succeeded in stabilizing demand.

These results are a welcome reminder that the cap-and-trade program is working in concert with other policies to accomplish the primary objective of reducing emissions, and that we’re doing it cheaply is an added bonus. Early reductions at a low cost can lead to sustained or even improved ambition as California implements its world-leading climate targets.

As California closes its fifth year of cap and trade, it should be with a sense of accomplishment and optimism for the future of the state’s emissions.

By Jonathan Camuzeaux

A parabolic trough solar thermal electric power plant located at Kramer Junction in California | Photo: Wikimedia

By Jonathan Camuzeaux and Maureen Lackner

The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated. California’s emissions trends are showing what is possible with strong climate policies in place and provide hope even as new analysis projects that global emissions will increase by 2% in 2017 after a three-year plateau.

California’s emissions kept falling in 2016

The 2016 emissions report, an annual requirement under California’s regulation for the Mandatory Reporting of Greenhouse Gas Emissions (MRR), shows that emissions covered by the state’s cap-and-trade program are shrinking, and doing so at a faster pace than in prior years. Covered emissions have dropped each year that cap and trade has been in place, amounting to 31 million metric tons of carbon dioxide-equivalent (MMt CO2e) over the whole period, or 8.8% reduction relative to 2012. The drop between 2015 and 2016 accounts for over half of these cumulative reductions (16 MMt CO2e; 4.8% reduction relative to 2015). The electricity sector is responsible for the bulk of this drop: electricity importers reduced emissions about 10 MMt CO2e while in-state electricity generation facilities reduced emissions by about 7 MMt CO2e.

Some sectors’ emissions grew in 2016. Just as with global transportation emissions, California’s transportation emissions have steadily crept up in recent years, and the MRR report suggests this trend is continuing. Transportation fuel suppliers, which account for the largest share of total emissions, reported a 1.8 MMt CO2e increase in emissions covered by cap and trade since 2015. Cement plants and hydrogen plants also experienced small increases in covered emissions. One of the benefits of cap and trade, however, is that if the clean transition is occurring more slowly in one sector, other sectors will be required to reduce further to keep emissions below the cap while the whole economy catches up.

Emissions that are not covered by the cap-and-trade program dropped, from 92 MMt CO2e in 2015 to 87 MMt CO2e in 2016. While small, this represents the largest reduction in non-covered emissions since 2012 and is mostly driven by suppliers of natural gas/NGL/LPG and electricity importers. Net non-covered and covered emissions reductions resulted in a 20.5 MMt CO2e drop in total emissions from these sectors. 

These results are a welcome reminder that the cap-and-trade program is working in concert with other policies to accomplish the primary objective of reducing emissions.

The California climate policies are accomplishing their emissions reductions goals

The 2016 MRR data indicate impactful reductions in GHG emissions and progress toward reaching the state’s target emissions reductions by 2020. The 2016 emissions drop is a consequence of several factors: a CARB analysis of the year’s electricity generation points to increased renewable capacity, decreased imports of electricity from coal-fired power plants, and increased in-state hydroelectric power production. To put it in perspective, the 20.5 MMt CO2e emissions reductions is equivalent to offsetting the energy use of about 2.2 million homes, or 16% of California’s households.

Emissions below the cap are a climate win, not a concern

Total covered emissions in 2016 were about 324 MMt CO2e, well below California’s 2016 cap of roughly 382 MMt. Some observers of the cap-and-trade program worry that an “oversupply” of credits will result in reduced revenue for the state and lesser profits for traders on the secondary market. This concern was especially pronounced when secondary market prices dipped below the price floor in 2016 and 2017.

Importantly, oversupply of allowances is not a bad thing for the climate. As Frank Wolak, an energy economist at Stanford, points out, oversupply may be a sign of an innovative economy in which pollution reductions are easier to achieve than anticipated. Furthermore, having emissions below the cap represents earlier than anticipated reductions which is a win for the atmosphere. Warming is caused by the cumulative emissions that are present in the atmosphere so earlier reductions mean gases are not present in the atmosphere for at least the period over which emissions are delayed.

While market stability is a valid concern, the design of the program has built-in features to prevent market disruptions. Furthermore, the California legislature’s recent two-thirds majority vote to extend the cap-and-trade program through 2030 provides long-term regulatory certainty. Both the May and August auctions were completely sold out suggesting that the extension has succeeded in stabilizing demand.

These results are a welcome reminder that the cap-and-trade program is working in concert with other policies to accomplish the primary objective of reducing emissions, and that we’re doing it cheaply is an added bonus. Early reductions at a low cost can lead to sustained or even improved ambition as California implements its world-leading climate targets.

As California closes its fifth year of cap and trade, it should be with a sense of accomplishment and optimism for the future of the state’s emissions.

The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated.

The California Air Resources Board’s November 6 release of 2016 greenhouse gas (GHG) emissions data from the state’s largest electricity generators and importers, fuel suppliers, and industrial facilities shows that emissions have decreased even more than anticipated.