Skip

VOLUNTARY INCENTIVE BASED PROGRAM AGRICULTURAL ERC EMISSION CRITERIA

VOLUNTARY INCENTIVE BASED PROGRAM AGRICULTURAL ERC EMISSION CRITERIA

VOLUNTARY INCENTIVE BASED PROGRAM AGRICULTURAL ERC EMISSION CRITERIA

 

Promoting the use of Agricultural Generated Emission Reduction Credits as a means to ‘pay for’ conservation practices is a sound approach to addressing the water quality resource (and potentially other resource concerns).  The standard EPA criteria for determining the eligibility for Emission Reduction Credits (ERC’s) will require special reconsideration for agricultural sources. The Farm Bureau is in a unique position to recommend criteria for establishing and encouraging the generation of agriculturally generated ERC’s.  The cornerstone for utilizing ERC’s as a voluntary incentive based approach is overcome the geographic limitations for marketing the credits and allowing the generating of credits from the implementation of USDA NRCS conservation practices for irrigation internal combustion engines and newly constructed confined animal facilities.

 

In general, the following criteria is utilized in analyzing the eligibility of air emission reduction credits for air quality for banking purposes, the ERC reductions may have to be:

 

A. Real

B. Surplus

C. Permanent

D. Quantifiable

E. Enforceable

F. Not used for the approval of an Authority to Construct or as Offsets

G. Based on a Timely Submittal of Application

H. Included in Emissions Inventory

Limitations Based Upon Geographic Boundaries or Air Basin District Boundaries:

 

The following discusses each criterion and the considerations necessary for agricultural sources:

 

A. Real

 

These Emission reductions have been created by the implementation of a USDA NRCS Conservation practice or standard as identified within the field office technical guidance (FOTC). Such conservation practices have been developed through the implementation of approved research that demonstrates the reliability and economic feasibility of the practice, understanding that in many cases the use or sale of such credits contributes to the economic feasibility of the practice or standard.

 

Baseline history is real and the Emission factors are from widely accepted sources such as the monitoring or USDA NRCS published sources or independently verifiable research.  The implementation of an approved NRCS practice on a new facility will enable that facility to receive ERC as an incentive to promote the application of such technology and encourage the implementation of conservation practices.  This is the incentive and a most unique feature to promote the implementation of a conservation practice.  Under this scenario, baseline emissions may be calculated from the present or proposed animal unit capacity for a CAFO.

 

The grower/producer will cooperate with the NRCS on implementing the practice in a manner that ensures that the reductions are real.

 

 

 

 

 

B. Surplus

 

Surplus Emission reductions are reductions that are in excess of those required by any laws, rules, regulations, agreements, orders or State Implementation Plan.  This requires that the Voluntary Incentive ERC approach be adopted as a means to create ERC’s from exempt agricultural sources for the benefit of the air resource. Such adoption of standards by the USDA NRCS in the FOTG will not render such practices ineligible for ERC’s.

 

 

C. Permanent

 

The grower/operator may have to enter into a long-term contract or other agreement with the NRCS to ensure the permanence of the reductions.  To ensure the permanence of the agreement and the notice of interested parties, the contract, or a similar document as approved by the NRCS.  Permit to Operate, or a permit not to operate in perpetuity are unacceptable criteria to enforce permanence.  A maximum of 20 years monitoring to ensure permanence is reasonable and surpasses existing stationary source requirements.

 

 

D. Quantifiable

 

The reduction amounts have been calculated based on historic crop data, historic fuel use, historic animal units or proposed animal units.  The accuracy of determining Emission reductions will be based upon the research results and established Emission reductions from the practice.

 

Validation through monitoring may be required, but site-specific source tests on agricultural sources may be an impractical approach. 

 

The agreement may identify record-keeping/monitoring requirements.

 

 

E. Enforceable

 

The current policy of requiring a permit for agricultural sources is cumbersome and does not recognize the fluid nature of agricultural operations.  If the District, or other regulatory entity, pursuant to state or federal laws, is prohibited to permit the emission unit, then a legal binding agreement shall be sufficient to ensures that the emission reductions will be provided in accordance with the conservation practice.

 

 

F. Not used for the approval of an Authority to Construct or as Offsets

 

The ERCs generated by this policy for banking through this shall not have not been used as offsets for the approval of any other project.  In some actions, reductions may be generated that would be used for projects without having to go through a banking process.  “Double Dipping” should be avoided.

 

 

G. Based on a Timely Submittal of Application

 

Many jurisdictions have requirements for timely applications, in the San Joaquin Valley UAPCD applications for ERCs must be received within 180 days of the reduction.  The timeliness issue should be based upon when the practice was fully implemented and proven, not necessarily limited to a 180-day restriction based upon when the practice was first instituted.

 

 

H. Included in Emissions Inventory

 

In many districts, the source category must have been included within a base year emissions inventory that identified the source category, i.e. a specific agricultural operation or process. Historic emissions inventories use may be fraught with error due to inaccurate science. Historic Emission inventories may be used as guidance but not as a limitation for the creation of ERC’s.  This is another of the unique features of an agricultural ERC Voluntary Incentive Program:

 

Limitations Based Upon Geographic, Basin, or District Boundaries: Many district have limitations on the distance from where an Emission reduction was generated to where it may be used.  Agricultural operations are rural in nature, the voluntary incentive based program is recommended to increase the utility for the use of agriculturally generated credits across air basin (or District) boundaries, especially since ozone precursors and other greenhouse gas Emissions are currently globally traded and have a greater utility the water resource on a broad geographic basis.