[Stoves] Off-topic:World’s first PM emissions trading scheme?

Wed Jun 5 18:11:21 CDT 2019

Crispin:

Thank you. It's been 20 years since I looked into industrial emission
measurement systems and reliability, so I will risk erroneous statements
that I do not have the energy to validate and raise some questions.

1. How does one dilute emissions at the source?

What you are referring to in the early days of EPA is dilution of
concentrations, not of emissions. "Tall stacks" was one such before the New
Source Performance Standards came into effect, I believe for facilities
licensed after 1973 or 1974. I was a witness to both the records and the
facility for a classic case - Homer City, PA - where tall stacks, fuel
change, and coal washing were used to meet the NAAQS but one unit was
subject to NSPS which it failed to meet, even though the three units
together over-complied with emissions required to meet the concentration.

I don't understand your reference to regulators having the right
"calculation". In a scheme such as this, no particular concentration is
targeted, for any particular period or location. All that is counted is
emissions. How the reduction of emissions leads to the location and time
profile of concentrations is another matter. I imagine there are model
simulations with source allocation, but that is an ancillary benefit.

This in turn implies that I am cynical about this being an instrument of a
COMPLIANCE PLAN. There is no enforceable compliance plan for any city in
India that I know of. Requires too much ground work that regulators don't
have the competence and the resources for; no wonder Kirk Smith & Co. get
away with claims that LPG alone will meet ambient air quality standards for
the whole of India. Nobody can tell, and frankly, dear, nobody gives a
damn.

I am also cynical because I do not expect Michael Greenstone to have a
fraction of honesty and passion for a purpose that Kirk Smith and his
associates have (my disagreements with them is a minor matter). This is
likely a research boondoggle, but I will try to find out more when I am
home again.

2. Your assertion about toxicity is also irrelevant. PM2.5 toxicity is not
causally proven, and if at all, any specific pollutants the PM2.5
monitoring may be an indicator of, are ignored in this scheme anyway.

To restate this -- I know from presence in industrial areas of my city or
Surat that there are pollutants from industrial chemicals or open wastes
that in US would be covered under TSCA and the underlying activities banned
or heavily monitored and controlled. No such luck for poor people in India
who suffer the real pollutants. They are guinea pigs for US university
professoriate, that's all.

I don't know if the Gujarat Pollution Control Board or the Gujarat
Ecological Commission (a think tank under the government, not a regulator)
reports document the concentrations of such really toxic substances not
just the indicator that is PM2.5 and picked u p by air quality monitors.
Again, I will try to find out, but absent correction from some colleagues,
I do not expect to be wide of the mark. USEPA and WHO bandwagon of PM2.5 is
a crime against humanity, period.

As Kirk Smith says, "You get what you inspect, not what you expect." He
applies this advice to his own work thus - "We know what air quality
monitors give us by inspection. How do we now convert that into our
expectation? By spreading the gospel of PM2.5 equitoxicity, ignoring the
toxins and pathogens that really kill people, and use the Integrated
Exposure Response curve to concoct DALYs and aDALYs."

But that is immaterial in this bamboozling of Indians by Greenstone.
Whatever changes are seen in concentrations may or may not have any
observable consequences for disease incidence. Such things are left for
epidemiology and public health, and Greenstone is just an economist, namely
a smart liar.

**

Enough. Your reference to SO2 cap-and-trade is misplaced; its purpose was
to reduce the ecological impact of acidic rain by long-range transport.
That it did no such thing and was then valued for PM2.5 reduction is an
example of EPA chicanery. (But economists who buy into PM2.5 health
theology justify the program anyway. There is a paper by Richard
Schmalensee in Journal of Economic Literature Fall 2010 or 2013, I
believe.) I had a cameo role in the research and model forecasts for the
SO2 program; let me leave it at that. The late Philip Lloyd had a
remarkable essay on the EPA hysteria management.

Also, there is no presumption that the cost of emission reduction will be
"passed on to consumers". Stay away pop economics, please.

Nikhil

------------------------------------------------------------------------
Nikhil Desai
(US +1) 202 568 5831
*Skype: nikhildesai888*

On Wed, Jun 5, 2019 at 12:10 AM Crispin Pemberton-Pigott <
crispinpigott at outlook.com> wrote:

> Dear Nikhil
>
>  It is interesting that they use a mass concentration as the metric.
> Because the implications are often unknown or poorly understood, let me add
> flesh.
>
> The mass concentration is the mass of PM per cubic metre of emissions
> (exhaust). Obviously if the exhaust is diluted with air the mass per cubic
> metre is lower. In some jurisdictions and in the early days of the EPA,
> dilution was the solution to pollution. Being less concentrated meant
> protecting people and objects like stone buildings from the effects of
> ozone, SO2 and NOx. It did nothing, however, to reduce the total emitted.
>
> The first question to ask is whether the regulators or proposers have the
> right calculation. The concentration of PM can be determined for a city
> using a PM detector of some kind. Concentration in the ambient air presumes
> a certain exposure to the inhabitants either of the city (in the case of
> Toronto) or the neighbourhood (in the case of Ulaanbaatar).
>
> It is clear that on a windy day, the total mass emitted could be much
> higher because of the diluting effect of Clean Air from a rainy place, an
> ocean or other vast area with very little pollution. The claimed goal,
> remember, is to reduce exposure of people to air pollution on an annual
> basis (generally speaking).
>
> If the mass emitted per cubic metre is not diluted by cleaner air, the
> reported concentration is higher, even though the total emitted is the
> same. So a device or facility can fail or pass depending on whether it is
> appropriately diluted or not.
>
> To fix this error the concept of a standard dilution rate, as reported
> using a standard oxygen concentration like 8%, was introduced. Any emission
> mass concentration can be corrected to any standard dilution value. The
> 150mg per cubic metre is a concentration based emission so additional info
> is needed. What is the O2 level in the proposed 150 mg/m^3? That is
> important to know.
>
> If they can't answer the concentration question it means they are working
> with the old EPA method (this still happens).
>
> Next is the issue of toxicity. If I push out a lot of flyash (silica sand,
> mostly) and substitute a burner that reduces flyash to zero and I emit lots
> of Black Carbon instead, I receive no penalty if the metric is mass
> concentration. PM is a size, not a material, so as I could be creating 10
> or 100 times the health risk while getting paid to "pollute less"
> (according to their assessment).
>
> At present there is no easy solution for this because the EPA classes all
> PM as equally toxic (the equitoxicity ruling we decry so much). While the
> ruling is patently defective, they won't yield to efforts to correct it.
>
> The cap and trade proponents hold up SO2 in the USA as an example of
> success for cap-and-trade.  That is interesting but inappropriate because
> SO2 is a single thing. PM is anything, so emitting less "anything" has no
> quantifiable health effect if the things emitted are not identified. No one
> knows what the city residents will inhale under a PM cap and trade regime.
> Might be better and might be worse - literally no one knows. They are not
> going to measure what it is, only the size and estimated total mass.
>
> Although it is very inconvenient, I suggest that stove designers find out
> what is being emitted by their products even if there are no regulations
> governing it beyond size and a couple of gases. Ethanol in particular can
> generate dreadful organic carbon emissions when burned badly. So can
> biomass.
>
> Finally, the standard dilution for regulation in many places is different
> for different fuels. The "150 mg/m^3" may represent different total masses
> for different fuels when one is reported at O2 = 8% and another is 11%.
> Further, some jurisdictions set different emissions rates for domestic and
> industrial sources.
>
> In one place I encountered recently the permitted domestic rate is half
> the industrial rate, and the domestic sources are far more diluted, simply
> by them being distributed, not concentrated sources. Learn the details. Not
> everything makes sense when viewed closely.
>
> One thing for sure about Surat, whatever the cost of emissions, it will be
> passed on to consumers.
>
> Regards
>  Crispin
>
>
> *From:* pienergy2008 at gmail.com
> *Sent:* June 4, 2019 11:36 PM
> *To:* stoves at lists.bioenergylists.org
> *Reply to:* ndesai at alum.mit.edu; stoves at lists.bioenergylists.org
> *Subject:* [Stoves] Off-topic:World’s first PM emissions trading scheme?
>
> Very interesting. At this stage, only one city and covering 350 industrial
> units. I know the city, Surat, and I think lignite is the most common
> industrial fuel, with some HFO, maybe some coke. Since organic PM is a PIC,
> better combustion would reduce PM but increase CO2.
>
> I suppose Michael Greenstone could cook up an ETS for rural biomass.
> Harvard, Chicago, Yale, MIT make quite a circus. There should be a study of
> an ETS v. an aDALY market (originating from all attribution factors for
> every premature death).
>
> http://timesofindia.indiatimes.com/articleshow/69640732.cms?
> <https://nam04.safelinks.protection.outlook.com/?url=http%3A%2F%2Ftimesofindia.indiatimes.com%2Farticleshow%2F69640732.cms%3Futm_source%3Dcontentofinterest%26utm_medium%3Dtext%26utm_campaign%3Dcppst&data=02%7C01%7C%7C24ac5abb00f54cb17edb08d6e902779e%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C636952594137640347&sdata=n5E0hCJKvbO9Q5khNb%2BbjcXhotJTAWcSqsTn4kxF1Ok%3D&reserved=0>
>
> ------------------------------------------------------------------------
> Nikhil Desai
> (US +1) 202 568 5831
> *Skype: nikhildesai888*
>
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