November 19-25, 2022
In this week's issue:
- NACAA Comments on EPA Power Sector Strategy Calls for Partnership, Urgency, and Strategic Action (November 22, 2022)
- CEQ Launches Improvements to the Climate and Economic Justice Screening Tool (November 22, 2022)
- COP27 Concludes; Final Agreement Proposes Damage Fund But Does Not Commit to New GHG Reductions
This Week in Review
NACAA has submitted comments authored by its Climate Change Committee to EPA’s non-regulatory docket (EPA-HQ-OAR-2022-0723), which the agency is using to take early input on its power sector strategy including the regulation of greenhouse gases (GHGs) from the electric power sector. NACAA’s comments emphasize the importance of coordinating with state and local implementers of the Clean Air Act, and offers policy principles and technical input for compliance flexibilities, along with an appendix of technical information based on seven chapters excepted from the May 2015 NACAA “Menu of Options” document.
NACAA’s letter asserts the unique role played by state and local clean air agencies and calls for engagement from EPA to be early, frequent, and meaningful as it develops these rules. It calls on EPA to support, and not conflict with, state and local climate programs. It identifies innovative new areas for consideration by EPA that have evolved since prior rules were developed and proposed, while urging EPA to remain within the limits placed by the West Virginia v. EPA decision. The letter calls for EPA to be an effective advocate for funding and resources for its co-regulators to succeed with new programs and actions. It identifies a need for strategic prioritization during implementation, and enumerates co-benefits that should be weighed like air pollution and equity considerations. Finally, it emphasizes the urgency posed by the climate crisis for EPA to take action. In an appendix, NACAA offers seven chapters excerpted from the May 2015 Clean Power Plan Menu of Options, for EPA’s consideration when evaluating compliance flexibilities. These chapters include topics such as improving generator efficiency and performance, improving fuel quality, co-firing and onsite innovation, and emissions capture. Although EPA requested comment from NACAA and others by November 22, 2022, the non-regulatory docket will remain open until March 2023, should your agency wish to file comment (or if a need arises for NACAA to offer additional information to the docket.)
For further information:
The White House Council on Environmental Quality (CEQ) has released an updated version of the Climate and Economic Justice Screening Tool (CEJST) – Version 1.0 – which includes new data, enhancements and improvements. The CEJST is designed to guide in the implementation of the Administration’s Justice40 initiative by helping to identify overburdened communities so that federal funding may be focused appropriately. The Justice40 effort is designed to provide 40 percent of the benefits of the federal government’s climate, clean energy, affordable housing, clean water and other investments to communities that are underserved, marginalized and overburdened by pollution. The CEQ previously issued a beta version of the CEJST tool and requested comment from federal agencies; state, local and tribal governments; environmental justice groups; and the public. Version 1.0 includes an updated methodology, new data and enhancements to the website. For example, the changes include the addition of tribal nations and data related to territories, nine new data sets to identify burden (e.g., projected climate risks, lack of greenspace, redlining data, legacy pollution) and enhancements to improve accuracy. The CEQ will continue to update the CEJST based on public feedback and input from the National Academies of Sciences, Engineering, and Medicine.
For further information:
https://screeningtool.geoplatform.gov/en/#3/33.47/-97.5
and
The 27th Conference of the Parties (COP27) to the United Nations Framework Convention on Climate Change (UNFCCC) held in Sharm al Sheikh, Egypt, has concluded with a final agreement text after negotiations between nations stretched beyond the scheduled dates of the conference. The final agreement articulates support for the establishment of a “loss and damage fund” that would fund recovery efforts in developing nations for climate change-caused disasters. This fund had been supported by the “G77” group of developing nations and the European Union, among others, and upon agreeing to its inclusion in the final agreement U.S. delegates called the fund a “voluntary funding stream”; no details have been established about how it will be funded or operate. In addition, no further cuts in emissions were agreed to beyond those made at COP26 in Glasgow, Scotland, and the agreement does not call for a drawdown of the use of oil or natural gas, instead saying that “the global transition to low emissions provides opportunities and challenges for sustainable economic development and poverty eradication,” (emphasis added) seen by some as tacit support for fossil fuels without the highest GHG emissions.
For further information:
https://unfccc.int/sites/default/files/resource/cop27_auv_2_cover%20decision.pdf