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	<title><![CDATA[Grist - Comment Feed for Pulitzers await the enterprising journalist who digs into the RGGI efficiency story]]></title>
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            <title>Comment #1 by Sean Casten</title>
			<link>http://www.grist.org/article/rggi-not-dead-yet/</link>
			<pubDate>Fri, 26 Sep 2008 07:18:05 -0700</pubDate>
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				<p><strong>RGGI is a bit goofy to analyze</strong></p><p>You raise good points, Adam, but I think the really hard thing with RGGI is the sheer confusion. &nbsp;First, participation is limited to powerplants &gt;25 MW, except in those states that choose to allow others to participate via offsets. &nbsp;This leaves a lot of CO2 sources out of the system, and affects different states in different ways.</p><p>
On top of that, the allocations distributed by state were the result of a rather complex political settlement, tied only by happenstance to the actual emissions in the state. &nbsp; In theory, they took an "allocation to generation" methodology, whereby the allocations are set based on historic CO2 production. &nbsp;However, this put states like Vermont at a steep disadvantage, because they have such little CO2 emissions per MWh of power production from &gt;25 MW power plants. &nbsp;(VT generation is dominated by a single nuclear facility in the southern end of the state). &nbsp;VT therefore got an allocation well in excess of it's actual in-state emissions, while others got less.</p><p>
The result of all of that is that it's very hard to say exactly who has an incentive to participate in RGGI and to what degree - some folks are long on allocations, some are short, some chose to allow non-power carbon sources and sinks to participate, some didn't... whether this leads to a net upward or negative pressure is damned near random, and certainly not a very efficient way to price carbon. &nbsp;</p><p>
As I say, goofy. &nbsp;</p>
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				<p><strong>RGGI is a bit goofy to analyze</strong></p><p>You raise good points, Adam, but I think the really hard thing with RGGI is the sheer confusion. &nbsp;First, participation is limited to powerplants &gt;25 MW, except in those states that choose to allow others to participate via offsets. &nbsp;This leaves a lot of CO2 sources out of the system, and affects different states in different ways.</p><p>
On top of that, the allocations distributed by state were the result of a rather complex political settlement, tied only by happenstance to the actual emissions in the state. &nbsp; In theory, they took an "allocation to generation" methodology, whereby the allocations are set based on historic CO2 production. &nbsp;However, this put states like Vermont at a steep disadvantage, because they have such little CO2 emissions per MWh of power production from &gt;25 MW power plants. &nbsp;(VT generation is dominated by a single nuclear facility in the southern end of the state). &nbsp;VT therefore got an allocation well in excess of it's actual in-state emissions, while others got less.</p><p>
The result of all of that is that it's very hard to say exactly who has an incentive to participate in RGGI and to what degree - some folks are long on allocations, some are short, some chose to allow non-power carbon sources and sinks to participate, some didn't... whether this leads to a net upward or negative pressure is damned near random, and certainly not a very efficient way to price carbon. &nbsp;</p><p>
As I say, goofy. &nbsp;</p>
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            <title>Comment #2 by rsmith02</title>
			<link>http://www.grist.org/article/rggi-not-dead-yet/</link>
			<pubDate>Mon, 29 Sep 2008 04:51:07 -0700</pubDate>
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				<p><strong>offsets</strong></p><p>Some of the above commentary doesn't make sense to me.</p><p>
RGGI= 25MW or greater generation, period. &nbsp;So far, RGGI only has a few categories of offsets and none are power sector-related, and I don't think that would be allowed. &nbsp;</p><p>
RGGI's price is a little over $3/ton, so I doubt offsets will be terribly attractive anyway.</p><p>
I'm not sure if the state by state differences matter a lot as carbon is tradeable throughout the 10 state region. &nbsp;A ton is a ton is a ton. &nbsp;The important thing is that the system as a whole is overallocated as actual emissions are lower than expected.</p><p>
The best news is that almost all allowances are getting auctioned so whoever needs them gets to pay for the privilege. </p>
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				<p><strong>offsets</strong></p><p>Some of the above commentary doesn't make sense to me.</p><p>
RGGI= 25MW or greater generation, period. &nbsp;So far, RGGI only has a few categories of offsets and none are power sector-related, and I don't think that would be allowed. &nbsp;</p><p>
RGGI's price is a little over $3/ton, so I doubt offsets will be terribly attractive anyway.</p><p>
I'm not sure if the state by state differences matter a lot as carbon is tradeable throughout the 10 state region. &nbsp;A ton is a ton is a ton. &nbsp;The important thing is that the system as a whole is overallocated as actual emissions are lower than expected.</p><p>
The best news is that almost all allowances are getting auctioned so whoever needs them gets to pay for the privilege. </p>
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