Message-ID: <24456094.1075843183906.JavaMail.evans@thyme> Date: Thu, 28 Oct 1999 08:29:00 -0700 (PDT) From: janel.guerrero@enron.com To: enron.environmental@enron.com Subject: NOx SIP call info etc... Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Janel Guerrero X-To: Enron Environmental X-cc: X-bcc: X-Folder: \Jeff_Dasovich_Dec2000\Notes Folders\Renewables X-Origin: DASOVICH-J X-FileName: jdasovic.nsf Last week I attended the 1999 annual meeting for the Council of Industrial Boiler Owners (CIBO) in Arizona. Enron has been a member since 1997. Below is a quick summary of some issues that you might be interested in. Background CIBO considers itself the "voice" of industrial energy producers promoting, through techinical interchange and advocacy: 1)equitable, cost effective laws and regulations; 2) improved reliability and cost effectiveness of industrial energy systems; and 3) the exchange of information among members, government and the public concerning policies, laws and regulations which affect industrial energy systems. List of Members Attending the Conference A-55, Inc AE Staley Manufacturing Company ABB Combustion Engineering, Inc Alcoa, Inc. American Highway Users Alliance Anheuser-Bush Companies, Inc. Archer Daniels Midland Automation Applications, Inc. BASF Corporation Bibb & Associates, Inc. Black & Veatch Corp Bracewell & Patterson Cerestar USA, Inc. Coen Company, Inc. DB Riley, Inc. Detroit Stoker Company Dow Chemical USA DTE Coal Services, Inc. DTE Energy Services Duke/Fluor Daniel Eastman Chemical Company East Kodak Company EI Dupont de Nemours & Co Elsag Bailey Energy & Environmental Research Corp. Enron Foster Wheeler Energy Corp Gardner, Carton &Douglas Gas Research Institute General Motors Corp. Harold Black & Sons, Inc Honeywell, Inc Integrated Waste Services Association Inter-Power/ Ahlcon Partners International Paper ISG Resources, Inc./John Zink Company Michigan State University National Coal Council Nooter/Eriksen, Inc. Ohio University Penn State University PSD Solutions, Inc. Regional Air Pollution Control Agency (Ohio) RJ Reynolds Tobacco Rohm and Haas Company Ross Project Services SFT, Inc. Solar Turbines Inc. The McBurney Corporation Proctor & Gamble Todd Combustion/John Zink Trigen Energy Corporation University of North Dakota US Conference of Mayors Virginia Tech Wartsila Diesel Inc. Wheelabrator Environmental Systems Youngstown Fuels & Technology, Inc. 1999 Survey Results Prior to the meeting, a survey was taken among CIBO members and the responses were shared last week. Key points: 1) When asked which CIBO program provides the greatest benefit to members The Environmental Committee was by far the most popular, followed by the NOx Control Conference and then the Energy Committee meetings were considered most beneficial. 2) The most important Energy Issues in 1999 for CIBO members were, in the following order: Global Climate Change Energy Strategy Regulatory Activitiy Relating to Fuels Retail Wheeeling/Competitive Sourcing Energy Efficiency Regulations Operator Certification Ownership and Operations Options Other 3) Most important 1999 Technical Issues (top 3): Energy Optimization Emission Control Systems Advanced Technologies 4) Most Important 1999 Legislative Issues: 1990 Clean Air Act Reathorization/Amendments Regulatory Reform Utility Dereg Energy and Environmental Taxes RCRA Ash Cost Effectiveness Risk Assessment 5) Most important 1999 Environmental Issues: Northeast States Ozone Transport National Ambient Air Quality Standards Environmental Litigation New Source Review Reform Industrial Combustion Boiler MACT RCRA Non-Utility Fossil Fuel Ash Compliance Assurance Monitoring Environmental Enforcement Emission Trading Pollution Prevention Environmental Justice Risk Assessment & Management World Bank Environmental Standards ISO 14000 International Standards Urban Sprawl Other NOx SIP Call Litigation Oral Arguments are scheduled to be heard on November 9th in Washington, DC. Enron Govt. Affairs reps will be in attendance. CIBO's involvement is as follows: Parties to the NOx SIP Litigation vs The states of: MI, OH, IN, WI, NC, SC VA, WV, AL EPA Utilities from: OH, MO, IN, MI, SC, WI Intervenors on behalf of EPA are listed below: CT, MA, ME, VT, RI, NH, NY, PA, MD CIBO Northeast Utility Companies NMA Trade Groups The Paper Industry Natural Gas Supply Association/Sempra Business Coalition Environmental Groups INGA PP&L Regulation Challenged: The State of Michagan et al vs EPA (98-149) Finding of Significant Contribution and Rulemaking for Certain States in the Ozone Transport Assessment Group Region for Purposes of Reducing Regional Transport of Ozone. Petitioners' Arguments Interpretation of "Significant Contribution" -- cost analysis State Authority -- EPA went beyond its authority Split States -- built on OTAG modeling data. Only a portion of certain states were considered in the modeling, but the rule affected the entire state SBREFA -- EPA, when they published the regulations, didn't consider the impact to small business. Industrial Boilers -- the definition is incorrect Internal Combustion Engines -- now subject to a 90 percent reduction; EPA couldn't show why; incorrect analysis NOx trading credits -- PP&L is arguing for earlier action credits. They don't like the cap on credits b/c it doesn't give full value for the credits ***As a sidenote.....only certain members of CIBO have been funding the litigation effort. Enron is not one those companies. If you have further questions about the annual meeting or the litigation, please give me a call. I'll send around a summary of the hearing after November 9th.