The schedule is set. March 1 is the one and only public comment session being held by the Environmental Improvement Board. Now is the time to begin mobilizing participation so that all voices are heard on the matter of a proposal to implement a New Mexico-only cap on greenhouse gas (GHG) emissions. This is a critical policy issue that could have major economic impacts of the state. I’ll be heading up for this important meeting. I encourage you to attend as well.
Please spread the word and encourage participation at the March 1 public comment session in Santa Fe. , Please consider sending an alert to your membership in the next week to remind them of this key date and urge their participation. Below is a sample alert that you are welcome to forward.
Attached are some background materials that may be of use to you as you brief others on this issue.
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The New Mexico Environmental Improvement Board (EIB) will hold a public comment session on March 1 to hear input on a proposal to implement a cap on greenhouse gas (GHG) emissions in the state.
Numerous groups are in opposition to this proposal because of the severe economic impacts such a measure would likely have on New Mexico.
The proposal calls for a reduction in statewide Greenhouse Gas emissions to 25% below 1990 levels by the year 2020 – a more aggressive goal than anything currently under consideration at the federal level. The cap would apply to such entities as oil and gas producers, refineries, manufacturers, cement and asphalt plants, power plants, universities, military bases, mineral processing operations, and numerous others.
* When: March 1 from 10 a.m. to 5 p.m.
* Where: State Personnel Office Auditorium, Willie Ortiz Building, 2600 Cerrillos Road, Santa Fe 87505
* What: EIB public comment session on proposed New Mexico Carbon Cap.
The EIB has not yet set the exact process for the session, but if you plan on making a comment you should assume you will be heard on a first-come, first-served basis unless you hear otherwise.
Key concerns that those opposed to the proposal include:
* This proposal provides no cost mitigation measures because it requires affected sources to reduce their emissions of greenhouse gases through the addition of pollution controls that are not commercially available, fuel switching, reduced operation, or closure.
* The cap would affect regulated industries, and their customers, in the state of New Mexico only. It would represent a cost driver unique to New Mexico, and therefore place the state at an economic disadvantage with other states. Ultimately, it creates an incentive for affected industries to leave the state.
* While exact impacts are not yet known because no comprehensive economic impact study has been performed, it is clear that this price driver unique to New Mexico would significantly increase the cost of doing business in the state.
* The cap would make no discernable impact on the amount of manmade greenhouse gasses widely believed to be contributing to global climate change.
* The proposed cap on GHG emissions is applicable to regulated sources in New Mexico and covers only about 32 percent of anthropogenic GHG emissions in the state.
* Under current law, the Board has no authority to regulate air emissions from power plants located on tribal lands. Such sources represent the single largest emitter source of GHG emissions in New Mexico and nearly half of all GHG emissions from the electric utility sector in the state.
For those interested, the location of the meeting has changed to the State Personnel Office Auditorium, Willie Ortiz Building, 2600 Cerrillos Road, Santa Fe 87505. The meeting will begin at 10am.
I plan to attend and make a short presentation regarding the underlying fallacy of effects of GHG
Following is a letter filed with the EIB:
25 February 2010
Gregory Green, Chairman
New Mexico Environmental Improvement Board
C/O Board Administrator [email to joyce.medina@state.nm.us; signed copy by fax to 505.827.2836 ]
Re: New Energy Economy Petition, Case Number 8-19
Dear Chairman Green:
This letter is in regard to the EIB rulemaking proceeding cited above, and I request that it be made a part of the record.
In brief, the New Energy Petition, (hereinafter, “petition”) should be denied
in its entirety for the following reasons:
The petition, if adopted, would impose on New Mexico citizens significant economic burdens, without commensurate economic or environmental benefit. To my knowledge, the petitioners have neither quantified, nor otherwise demonstrated, tangible benefit to New Mexicans from the proposed carbon caps, while the economic damage implicit in the petition would be enormous.
Already, opposition to the petition has ranged from dairy producers, City of Farmington, oil and gas producers and refiners, Grupo Cementos de Chihuahua, electric utilities, and ordinary consumers of their products. Their concerns are not trivial:
1. The producers: To achieve the level of reductions required by the petition, for the most part, the technology neither exists, nor is even on the drawing board in the affected industries. Where technology is beginning to emerge, the time and costs of application are prohibitive.
2. The consumers: The inevitable shifting of costs to the ultimate consumer without commensurate tangible benefit represents a punitive tax on an extraordinarily large proportion of the population.
3. Cities, towns and small communities: These entities would be put at economic disadvantage when those producers that are able to move are given incentive to abandon this state for less punitive locations.
For but one example, but an important one, the following will discuss
the problems and issues raised by the petition for the consumers and the producers of electric energy:
1. As is well known, the relationship between electric energy production and GDP is direct, and fundamental in the U.S. economy and in the State of New Mexico. Curtail, or arbitrarily raise the price of electricity by draconian limits, and the entire population suffers. Ordinary consumers are hurt, economic development suffers, industry is driven out (as electricity is an important cost component of any industry). State tax revenues are impacted negatively.
2. Further, electricity is on the solution-side of environmental problems: e.g. electrostatic precipitators reduce particulate emissions in industry, sewage treatment facilities require electricity, electric furnaces replace coke ovens, and electric transportation increasingly is important in reducing anthropogenic carbon emissions. These are but a few examples.
3. Opportunities for reducing carbon gas emissions in electricity production are highly limited at this time:
– Find alternative sources? Yes, and PNM is already investing in wind energy, but nowhere are there enough locations or transmission lines to achieve the petition reductions. And, the cost of electricity to the customer would rise significantly.
– And, yes, nuclear power is carbon-free. (The Obama administration has recently proposed loan guarantees for the development of a new generation of nuclear power plants.) However, the time required to license and construct new nuclear facilities not only exceeds the arbitrary limits imposed by the petition, but do we then impose upon the consuming public the added costs of shutting down highly-efficient, operating coal-fired power plants?
– Force domestic utilities to buy power from out-of-state producers? If the source of the power is coal or gas, the carbon is merely shifted to another state. Additional power from nuclear generation is not presently available.
– Trap the carbon gas as it is produced, and pump it into the earth, or the sea? Los Alamos and others have been working on this, but ultimate results are uncertain, and once again, time will be required before success can be assured.
– Ration electricity use? Perhaps in a dictatorship, but I hope not in New Mexico.
Finally, Mr. Chairman, I have a suggestion: before any other steps are taken, or decisions made by your board (unless the petition is denied outright, which would be merciful), the proponents of the petition should be required
to provide a competent and thorough cost/benefit analysis of their proposition, with the data for their studies to be made fully transparent for all New Mexicans to see.
I wish you well in your deliberations.
Sincerely,
/S/
Ashton B. Collins, Jr.