Henry Balikov, CEP Goldman Environmental Consultants May 10, 2007 The Strategic Advantage of Water Pollution Credits: Leveraging the Lessons Learned from Trading Sulfur Dioxide and Creating a Business Strategy based on a Clean Water Commodity Market
Jan 28, 2016
Henry Balikov, CEPGoldman Environmental Consultants
May 10, 2007
The Strategic Advantage of Water Pollution Credits:
Leveraging the Lessons Learned from Trading Sulfur Dioxide and Creating a Business Strategy based on a Clean Water Commodity
Market
© 2007 Goldman Environmental Consulting. All rights reserved.
Page 2
Contents
Beyond Command and Control– Clean Air Credits
– Carbon Credits
– Clean Water Credits
Credits and Markets– Who would use them?
– What is the benefit of using them?
– Lessons learned from current programs
Be prepared. Strategic planning made easy
© 2007 Goldman Environmental Consulting. All rights reserved.
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Why are we here?
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Evolution
The evolution of pollution credits
– Sulfur, Carbon, and Water Who would use them? What is the benefit of using them?
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These systems can work
Clean Air Credits – are already a significant factor in overall
pollution reduction
Carbon Credits – are capturing the imagination
Clean Water Credits– can make a contribution that is worth
considering
Title IV of the Clean Air Act has significantly decreased emissions from utilities.
In the first 12 years of the Acid Rain (cap and trade) Program, sources in the Program reduced their emissions of sulfur dioxide by over 33%. That resulted in over 5 million tons less of SOx.
© 2007 Goldman Environmental Consulting. All rights reserved.
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Clean Air Credits
=
+
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Clean air credits: what are they?
• Started in 1990 Clean Air Act
• Initial focus on sulfur oxides from electric power utility units
• Now a “cap” on total allowed
• Units of SO2 are “retired” annually
• Unused can be banked forward
© 2007 Goldman Environmental Consulting. All rights reserved.
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Clean air credits: how do they work?
Have the “markets” been as efficient as “command and control” alternatives?
How has the cost per ton of reduction compared to other methods or approaches?
© 2007 Goldman Environmental Consulting. All rights reserved.
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Carbon Credits Redux
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Carbon Credits Redux
Various markets already exist– Kyoto “international emissions” trading
– EU-wide trading
– Several national emissions trading programs
– Voluntary reduction initiatives
California has committed to a 25% reduction in greenhouse gas emissions by 2020.
© 2007 Goldman Environmental Consulting. All rights reserved.
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Clean Water Credits
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Clean Water Credits
Emulate Clean Air Credits or find a different methodology?
Obstacles– Regional or basin-centric?
– Onus is on the local government or regulatory body
– Point source vs. non-point source
– POTW vs. direct-discharger
– How significant are mixing zones
– How many pollutants are relevant?
– Will the market(s) have “critical mass”?
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Who would use them?
Typical organizationsPOTW or direct?
Who would manage the marketplace?
Typical organizations POTW or direct discharger? Who would manage the marketplace?
© 2007 Goldman Environmental Consulting. All rights reserved.
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How would the trade work?
eBay for effluents? Right now many are volunteering their
reductions to have them “permanently retired”
NGOs are stepping up to track the reductions
For trading credits will there be brokers? Will they be sanctioned by regulators?
© 2007 Goldman Environmental Consulting. All rights reserved.
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What are the basic benefits?
Water Quality Standards remain in place Creates a different incentive to improve
– Efficiencies improve
– Costs decrease
Collateral benefits
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Why did Oregon get involved?
Oregon’s circumstances favorable to trading include the following: – There is a "driver" that motivates facilities to seek pollutant
reductions, such as more stringent permit limits.
– Some sources can control pollution less expensively than others.
– There is something to trade. When all sources in a watershed are required to reduce pollutant loads by a large margin, opportunities for trading are reduced.
Oregon believes that where watershed circumstances favor trading, it can be a powerful tool for achieving pollutant reductions faster and at lower cost.
© 2007 Goldman Environmental Consulting. All rights reserved.
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For Oregon, trading is a viable tool
“Almost everyone starts out viewing trading negatively (it is seen as a way for polluters to get off the hook and buy their way out of meeting their legal obligations etc. etc.), once I have had about 20 minutes to show how we can and have used it to achieve actual gain (not just break-even) for the resource, they come around. It takes longer to win over regulators, and much longer to win over the permit holders who might actually do it. That is because they are concerned they will get sued. In a way this is a reasonable concern because there have been so many lawsuits over trivial issues.”
Sonja Bjorn-Hansen
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Part of the strategic plan
Toll road analogy – those who pollute should pay.
Part of business strategy. The Choice:
pay to pollute, or actually make money by NOT polluting
and selling/trading clean water credits Should there be a “use or lose” time limit?
© 2007 Goldman Environmental Consulting. All rights reserved.
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Can we discuss?– What might be the interests of Stakeholders?
– How to create a value proposition
Obtain professional guidance to help craft a pollution strategy and manage risk.
Limit exposure by cleaning up your act.
Pollution and the bottom line
© 2007 Goldman Environmental Consulting. All rights reserved.
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The fundamental process - Ask:1. What is the desired end state?
2. What is today's situation? What is the gap from that desired state and why?
3. What specific actions must be taken to close the gap between today's situation and the ideal state?
4. What resources are required to execute the activities?
Strategic planning made easy
© 2007 Goldman Environmental Consulting. All rights reserved.
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Strategic Analysis
Assess– Stakeholders including customers and workforce
– Competition
– Technology
– Supplier markets
– The economy
– The regulatory environment
It is rare to find all six factors having critical
importance
It is rare to find all six factors having critical
importance
© 2007 Goldman Environmental Consulting. All rights reserved.
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Some final thoughts
This should be part of an overall strategy for each organization.
Its value may be critical to managing key risks – reducing the environmental footprint is a proven way to reduce risk.
In a world where facilities frequently come under new ownership or management, it can help assure a better level of performance.
Obtain professional guidance to help craft a pollution strategy and manage risk.
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