Dairy ERC Rober I

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Emission Reduction Credits (ERCs) and Offsets – Cotton’s Experience: 

Emission Reduction Credits (ERCs) and Offsets – Cotton’s Experience Roger A. Isom Vice President & Director of Technical Services

ERCs: 

ERCs Great as long as there is demand! $12k per ton to $50k per ton in less than 6 months

Are ERCs saleable?: 

Are ERCs saleable? San Joaquin Valley - # of PM10 sales in 2005 = 5 # of PM10 sales in 2006 = 67

ERC Cost per Transaction: 

ERC Cost per Transaction

ERCs: 

ERCs Be careful what you ask for…You might just get it! Weigh your options

Selling ERCs: 

Selling ERCs Only 2 times in last 15 years have PM10 ERCs really sold! Power plants in the early ’02 Dairies in late ’06 Some cotton gins have held ERCs for 15 years Cost more than revenue

ERCs: 

ERCs Great if you’re selling, bad if you’re buying Double-edged sword

ERC Types: 

ERC Types Retrofit Installation of equipment that is not required “early implementation” Shutdown Closure of facility or operation

BACT & BARCT: 

BACT & BARCT Controls that create ERCs become BACT and BARCT Most cotton gin ERCs are shutdown ERCs, not retrofit ERCs

HS&C – 42301.18 {c}: 

HS&C – 42301.18 {c} A district may not require an agricultural source to obtain emissions offsets for criteria pollutants for that source if emissions reductions from that source would not meet the criteria for real, permanent, quantifiable, and enforceable emission reductions.

Mitigation vs. NSR: 

Mitigation vs. NSR Project = 25 tons PM10 Mitigation – Onsite = 10 tons Leaves 15 tons –> may or may not trigger offsets New Source Review – Must provide BACT and offsets 15 tons plus offset ratio

Solution: 

Solution Don’t know But we’ll be glad to help once all cotton gin ERCs are sold!

Remember: 

Remember Happy cows love California cottonseed!