Summary of Hearings on Air and Atmospheric Quality Policy
June 19, 2012:
Senate Subcommittee on Clean Air and Nuclear Safety Hearing on “Review of Recent Environmental Protection Agency Air Standards for Hydraulically Fractured Natural Gas Wells and Oil and Natural Gas Storage”
June 19, 2012
: House Committee on Energy and Commerce Subcommittee on Energy and Power Hearing On “The American Energy Initiative: A Focus on EPA’s Greenhouse Gas Regulations”
June 6, 2012:
Senate Committee on Commerce, Science and Transportation Hearing on the European Union's Emissions Trading System
June 30, 2011:
Senate Committee on Environment and Public Works Subcommittee on Clean Air and Nuclear Safety On Oversight: Review of EPA Regulations Replacing the Clean Air Interstate Rule (CAIR) and the Clean Air Mercury Rule (CAMR)
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Senate Subcommittee on Clean Air and Nuclear Safety Hearing on "Review of Recent Environmental Protection Agency Air Standards for Hydraulically Fractured Natural Gas Wells and Oil and Natural Gas Storage"
June 19, 2012
Assistant Administrator for the Office of Air and Radiation, U.S. Environmental Protection Agency
President, Environmental Defense Fund
Director, Wyoming Department of Environment Quality
President and CEO, Colorado Oil & Gas Association
Environmental Manager, Devon Energy Corporation
Director, Air Pollution Control Division, Colorado Department of Public Health and Environment
Subcommittee Members Present:
Thomas Carper (D-DE), Chair
John Barrasso (R-WY), Ranking Member
Ben Cardin (D-MD)
Mike Johanns (R-NE)
Jeff Merkley (D-OR)
Jeff Sessions (R-AL)
Full Committee Members Present:
James Inhofe (R-OK), Ranking Member
Kirsten Gillibrand (D-NY)
Tom Udall (D-NM)
On June 19, the Senate Committee on Environment and Public Works’ Subcommittee on Clean Air and Nuclear Safety held a hearing to discuss the Environmental Protection Agency’s (EPA) air standards for hydraulically fractured natural gas wells and oil and natural gas storage. These rules would be the first federal air standards issued for hydraulically fractured natural gas wells. It would federally regulate other sources of pollution in the oil and gas industry. The EPA finalized requirements for the New Source Performance Standards (NSPS) and National Emissions Standard for Hazardous Air Pollutants (NESHAP) in April 2012 and they will be implemented in 2015. The new source performance standards are meant to reduce emissions of volatile organic compounds (VOCs) and sulfur dioxide from oil and gas operations. The hydraulic fracturing process and its associated equipment have been criticized for emitting significant amounts of VOCs and methane through leaks. The rules require new hydraulically fractured gas wells to use green completion technologies which limit emissions and produce byproducts of methane and other hydrocarbons for producers to sell.
Senator Thomas Carper (D-DE) gave his opening statement discussing the “boom” in natural gas and how hydraulic fracturing has helped in the growth. Hydraulic fracturing is estimated to be used in “11,400 new fractured wells each year.” Carper said that without responsible use, hydraulic fracturing can release methane and other pollutants that form ozone and can cause cancer. Carper said that methane’s global-warming potential is 20 times more potent than carbon dioxide. Colorado and Wyoming were the only two states requiring the capture of these emissions prior to the release of the EPA regulations. Carper said the regulations are a “win-win solution” for industry and environment. He said this will be achieved by reduced emissions completions or green completions. Carper noted the EPA has provided a “reasonable schedule” for green completions, allowing producers until 2015 to fully comply. He closed by saying shale gas formations have “enormous potential” but must be “utilized responsibly.”
Ranking Member Senator John Barrasso (R-WY) gave his opening statement by noting the White House says natural gas is a “viable alternative” to coal and continued by saying the “rhetoric […] does not match the actions.” He cited an article from Bloomberg where Dave McCurdy, president of the American Gas Association, and Jack Gerard, president of the American Petroleum Institute, pointed out that a “dozen federal agencies were considering various rules or policies that could deal drilling a setback.” Barrasso brought up the Utility Maximum Achievable Controllable Technology (MACT) rule, saying it makes it “nearly impossible” to build new coal-fired power plants. He discussed the Sierra Club and their “Beyond Natural Gas” campaign. He quoted the director of the club who said, “we’re going to be preventing new gas plants from being built wherever we can.”
Senator James Inhofe (R-OK) began his statement by re-iterating the Utility MACT rule, which he said would “essentially do away with coal in America.” He quoted witness Fred Krupp, who said, “Given the dysfunction in DC, a state by state approach would be more effective.” Inhofe said he agrees with the statement. He pointed out that EPA Administrator Lisa Jackson said there was no case of groundwater contamination from hydraulic fracturing. He closed by saying that America cannot run “without fossil fuels.”
Senator Ben Cardin (D-MD) began his opening statement by replying to Inhofe’s and Barrasso’s comments. He said the Obama administration has been “sensitive” to energy issues. Cardin continued by saying pollution “knows no state boundary.” He said this is a “national problem” and needs “national solutions.” He further noted that “if we get this [clean air regulations] done right, we can expand our natural gas collections in this country in a way that’s more cost-effective and also will reduce pollutants.”
Senator Tom Udall (D-NM) gave a brief opening statement saying how “natural gas has great potential.” He said that the industry would need to “minimize” environmental impact “to maximize its potential.”
Gina McCarthy then gave her testimony by saying how the standards would not slow natural gas production and would yield cost savings. McCarthy said in the past year net imports of oil have decreased by 10 percent. She said the administration is “committed to the development” of important domestic resources and that this occurs “safely and responsibly.” McCarthy said a reduction between 190,000 and 290,000 tons of VOCs is expected with the new rules each year. As a result of the standards, reduction of air toxic emissions is estimated to be 12,000 to 20,000 tons each year and reduction of methane emissions is estimated to be 1 to 1.7 million tons per year. She said VOCs emissions can be controlled through flaring or green completions until January 2015, when green completions will become required. This gives industry a transition time. Green completions are already implemented at about half of the hydraulically fractured domestic natural gas wells. McCarthy pointed out how the rules were “aligned with existing programs” in states.
Carper began the questions asking what changes had been made from the original proposal. McCarthy said they “increase[d] compliance flexibility.” She mentioned the “phasing process” of green completions. She said they added a subcategory for areas in the U.S. where geologic formations do not allow green completions to be cost-effective and removed some “downstream transmission areas” requirements where VOC content is lower. Carper then asked about the potential for over-estimates on emissions from wells. McCarthy said the EPA data is “reasonable,” with four case studies and 1000 wells used in an EPA assessment.
Barrasso asked McCarthy about the Utility MACT rule and what would happen to coal communities. She replied that coal has a “lack of competiveness against natural gas” and it is not only the rules, but a “market issue.” Barrasso then asked how to “tap the gas” if EPA continues with the proposal to “create more non-attainment areas.” McCarthy said coal is a large portion of the energy supply and will remain at the same level.
Inhofe asked if the administration thinks natural gas is a long term part of our domestic energy supply or only “a bridge.” McCarthy cited a change in the energy supply and how natural gas is becoming the “fuel of choice that’s driven by the market.” Cardin asked if the EPA evaluated the cost-benefits of the regulations; the benefits in regards to communities and the costs of meeting compliance. McCarthy said they had and discussed the Mercury and Air Toxic Standards (MATS) benefits to public health.
Senator Mike Johanns (R-NE) explained how Nebraska was not included in the original development of the EPA standards until the very end and was then told to comply in six to eight months. He said it is “not humanly possible to comply.” He asked why this is a reasonable approach by the EPA. McCarthy clarified the situation with Nebraska, noting the Cross-State Air Pollution Rule (CSAPR) replacing the Clean Air Interstate Rule (CAIR). She said the “program” started with the CAIR, which began equipment installation.
Senator Jeff Merkley (D-OR) asked why companies are voluntarily doing the green completions program before the compliance date. McCarthy noted the cost savings and the “Natural Gas STAR” program. This EPA program promotes discussion between industry members to implement emission reduction technology at their sites.
The second panel began with testimony from Fred Krupp. He began by noting his service on the Secretary of Energy Advisory Board Natural Gas Subcommittee. This subcommittee recommended ways to “address the safety and environmental performance” of hydraulic fracturing. The two “central considerations” were the fast expansion of shale gas in U.S. energy and public health and environmental concerns due to this growth. Krupp said that clean air policies “must reduce pollution, protect people, the environment and communities.” He closed with several quotes from organizations, including a public statement from Southwestern Energy which said, “What we do today with reduced emissions completions in our wells doesn’t cost us any more than just venting the gas into the atmosphere.”
John Corra began his testimony by mentioning the 36,000 oil and gas wells in Wyoming that were not under federal regulation. Fifteen years ago, the state realized the need to manage these oil and gas sources. Corra discussed Wyoming’s “three-tiered approach” which accounts for differences in “intensities of development.” He stated that even though Wyoming’s amount of wells and gas production has increased since 2008, emissions of VOCs and nitrogen oxides have decreased from winter 2009 to winter 2011. Corra closed by noting the “flood of new regulations” from EPA and the lack of funding to help meet these issued regulations.
Tisha Schuller began her testimony by discussing two air emission regulations. First, she discussed Colorado’s Regulation Number 7 which reduces ozone precursors. Second, Rule 805, added in 2008, states that green completions are to be used when “technically and economically feasible.” This rule encouraged the capture of natural gas and reduction of odors. Schuller listed concerns with the EPA regulations including over-estimated emission estimates, compliance requirements, and economics.
Darren Smith began his testimony by stating Devon Energy “does support responsible regulations,” but is against “unreasonable” regulations “grounded on unsound science.” Smith focused his testimony on the over-estimates on data used by the EPA. He said data was reported to EPA via the Natural Gas STAR program, which he said “came from three companies.” Smith said this program reports “gas captured, not gas emitted.” He closed by saying there are concerns that “continued policy research is going in the wrong direction.”
William Allison began his testimony by saying Colorado uses hydraulic fracturing as a standard practice for “virtually” all oil and gas wells. He said federal rules would give a “level playing field” nationwide. He mentioned the use of low-bleed or no-bleed valves which abide by EPA’s rule. Allison said he supports “continued and adequate” congressional funding to ensure EPA and the states can implement these rules.
Barrasso asked Corra about the flexibility of local compared to national rules. Corra said that Wyoming’s ability “to implement policies and have agreement on those policies […] has been essential for us to act swiftly.”
Senator Jeff Sessions (R-AL) asked Smith where green completion is not working. Smith said places with “no infrastructure.” He further stated that the new NSPS rule from EPA has text that is “problematic for operators that are developing in new areas.”
Carper asked if the EPA has given enough time to comply with the standards. Schuller said that industry will be able to meet most, but problems will arise around manufacturing and implementation. Carper closed the hearing by posing one final question to the panel asking each person to give a quick idea of how to make the EPA rule better. Krupp noted how the rule only applies to new wells and standards should apply to existing wells. Corra said not to “over emphasize the importance of allowing states to have the flexibility to implement [the rules] according to the conditions in their own states.” Schuler said compliance needed to be modified so operators can adapt. Smith said the need to make sure “credible science is used.” Allison pointed out how the rules only apply to gas wells.
Witness testimonies, opening statements and an archived web cast is available at the committee’s web site.
House Committee on Energy and Commerce Subcommittee on Energy and Power Hearing On “The American Energy Initiative: A Focus on EPA’s Greenhouse Gas Regulations”
June 19, 2012
President and CEO, American Bakers Association
President, Pennsylvania Farm Bureau
President and CEO, CountryMark Cooperative LLP
Dean, Nicholas School of the Environment, Duke University
Senior Fellow and Director of Climate Strategy, Center for American Progress
Louis Cox, Jr.
President, Cox Associates
President and CEO, Rain Cll Carbon LLC
Commissioner and Vice-Chairman, Public Service Commission of South Carolina
Vice President, Research and Development, CONSOL Energy Inc.
Senior Vice President for External Relations and Environment, Tri-State Generation and Transmission Association, Inc.
Policy Director, Climate and Clean Air Program
Subcommittee Members Present:
Ed Whitfield (R-KY), Chair
Bobby Rush (D-IL), Ranking Member
John Sarbanes (D-MD)
Greg Walden (R-OR)
Lee Terry (R-NE)
David McKinley (R-WV)
Mike Pompeo (R-KS)
Morgan Griffith (R-VA)
Joe Barton (R-TX)
Gene Green (D-TX)
Brian Bilbray (R-CA)
Pete Olson (R-TX)
Full Committee Members Present:
Fred Upton (R-MI), Chair
Henry Waxman (D-CA), Ranking Member
On June 19, 2012, the House Committee on Energy and Commerce, Subcommittee on Energy and Power held a hearing to discuss the current, pending, and potential future greenhouse gas regulations instituted by the United States Environmental Protection Agency (EPA) under the authority of the Clean Air Act (CAA, 42 U.S.C. 7401-7671). Following the 2009 EPA Endangerment Finding, which states that atmospheric concentrations of carbon dioxide and five other greenhouse gas emissions (GHG) endanger public health and welfare, the EPA enacted Mobile Source Regulations, Stationary Source Regulations including a Prevention of Significant Deterioration (PSD) permitting program and New Source Performance Standards (NSPS), and GHG reporting regulations. The hearing focused on the potential impacts of the new regulations on the economy, the job market, and consumers.
Chairman Ed Whitfield (R-KY) opened the hearing with concerns that the EPA GHG emission regulations exhibit “regulatory overreach” and essentially serve as a “backdoor cap and tax policy.” Whitfield asserted that legislative action to address climate change should lie with Congress due to the high volume of regulations, the underestimation of costs, and direct job loss associated with EPA regulatory oversight. Whitfield cited examples of federal court decisions that support his position, including the Sackett vs EPA decision which rejected EPA efforts to deny due process to landowners, the Luminant Generation Company, LLC et al vs EPA case which overturned the EPA’s “arbitrary and capricious” rejection of three Texas permitting regulations for Pollution Control Projects, and the Mingo Logan Coal Company vs. EPA decision that overturned the EPA’s attempt to invalidate a West Virginia coal mining permit. Whitfield concluded that the “EPA-fulfilled prophesy that no new coal plants will be built in this country” will destroy jobs and increase electricity costs for consumers.
In his opening remarks, Ranking Member Bobby Rush (D-IL) stated that the classification of the EPA regulations as “unnecessary job-killers” rejects peer-reviewed studies and scientific research, and “illegitimately” denies that the regulations could lead to healthier livelihoods for citizens. Representative Rush stressed that mitigating GHG emissions would increase the number of jobs, rather than eliminate them. He cited a Chicago Tribune article entitled “Extraordinary Extremes: Climate Scientists Explain Our Crazy Weather,” which discussed the record-breaking heat in Chicago and significant increase in reported tornadoes throughout the country during March 2012. Rush then explained that this article, scientific models, and climate research provide evidence of the tie between natural disasters and human-induced climate change. He listed several steps that could be taken to mitigate the effects of climate change, save consumers money on utility bills, reduce dependence on foreign oil, and protect the environment. His suggestions included investment in renewable energy, advancement of efficiency policies, improving appliance technology, and producing fuel-efficient vehicles.
Full Committee Chairman Fred Upton (R-MI) remarked that the former cap-and-trade initiative was “bad news all around,” however the new GHG regulations “are looking worse.” Upton claimed that the proposed permitting requirements for power plants and the agricultural industry would be an economic roadblock that would “reverberate throughout the rest of the economy.” Upton mentioned his Energy Tax Prevention Act of 2011 (H.R. 910) to amend the CAA and reverse the GHG regulatory authority given to the EPA. He concluded that this bill would ensure a “pro-jobs, pro-growth, and pro-energy future for America.”
In his opening remarks, Representative Joe Barton (R-TX) focused on the small projected change in temperatures as a result of climate change. He stated that the small temperature would not lead to a significant adverse health effect for an individual. Rather, the additional $7 trillion in costs needed to reach GHG emission reduction standards will more negatively affect the nation. He used tail pipe emissions covered in the Light-Duty Vehicle Standards as an example, claiming the standards would require up to $4000 per car in additional production costs.
In his opening statement, Full Committee Ranking Member Henry Waxman (D-CA) described some of the significant impacts caused by climate change such as ocean acidification and decreasing crop yields. He claimed that the Republican Party has denied the evidence presented in review reports released by the International Energy Agency (IEA), the Vatican, and the National Academy of Sciences. The majority party has voted 37 times on the House floor to block efforts to reduce climate change, 45 times to prevent investments into clean energy and energy efficiency, and numerous times against cleaner vehicles and incandescent light bulbs. Waxman said the North Carolina bill to reject the use of projected rates of sea level rise for state planning exemplifies the failure of Republican legislators to “accept reality.” He concluded that the “price of denial will be paid by American entrepreneurs, workers, and communities” and by “many generations to come, starting with our own children and grandchildren.”
Robb MacKie, President and CEO of the American Bakers Association (ABA), began the first panel of testimonies by describing the adverse economic effects of the CAA regulations on the wholesale baking industry. He highlighted the magnitude of the baking industry which consists of more than 700 baking facilities and suppliers, generates more than $102 billion in annual revenue, and employs 600,000 people. MacKie informed the Committee that 20 percent of the baking industry is currently covered under Title V permits to reduce emissions. A larger portion of the baking industry would be required to participate under the new permitting process, which would lower the carbon dioxide emissions threshold to 250 tons per year (tpy). He said this would increase compliance costs and constrict bakers’ ability to respond to market demands. MacKie expressed particular concern over the PSD regulation on “biogenic” carbon dioxide, which includes emissions released during the natural fermentation of yeast when dough rises. The EPA PSD regulations require precise emissions estimations, but MacKie said measuring yeast carbon dioxide would be “technologically challenging and costly.” MacKie concluded that the “overly broad” EPA tailoring rule, which determines the stationary facilities that must comply to CAA permitting programs, would force American families to pay more for baked goods.
President of Pennsylvania Bureau Carl Shaffer testified on the permitting processes required in the farming industry under the CAA. He noted that the tailoring rule regulations for GHGs extends the requirement of NSR/PSD and Title V permits to smaller farms and result in many unintended consequences. Shaffer estimated that average additional costs due to permitting requirements would be $23,000 per farm: a total of $866 million in the agricultural sector from for Title V permits alone. He said the animal industry would be the most affected because about 90 percent of livestock production emits between 100-250,000 tpy of GHGs, which makes them subject to Title V permit requirements. Shaffer said the CAA thresholds of major GHG sources, those that emit more than 100-250tpy, “cannot be changed through regulation” and allow “little or no flexibility.” He concluded that regulation of utilities, refineries, manufacturers, and other input providers incur indirect costs on farmers and ranchers and applauded the goals of H.R. 910 to prevent these additional costs on agriculture.
In his testimony, Charles Smith of CountryMark Cooperative discussed the costs his company would have to incur under additional EPA regulations. He stated that the EPA estimates of compliance costs are underestimated and gave the example of the EPA cost estimate of $9,500 for installation of Continuous Emission Monitoring Systems, when the actual cost of installation for CountryMark was $450,000. Smith stated that replacement of the tailoring rule by the New Source Performance Standards (NSPS) to establish GHG statutory limits of 100 and 250tpy would be “orders of magnitude more stringent” for refineries. He finished his testimony with a statement that EPA mandates would increase capital, operating, and product costs and reduce domestic refining capacity. He recommended that “rational, reasonable cost analyses” are conducted for EPA regulations.
In the following testimony Daniel Weiss, Director of Climate Strategy for the Center for American Progress, described the significance of the 2007 Massachusetts vs. EPA ruling. As a result of the case, the Supreme Court ruled that the CAA applies to pollutants that contribute to global warming, giving the EPA the authority to set GHG emissions limitations. Regulations under the Obama Administration have set a goal to have the largest facilities reduce emissions by 7000 tpy. Weiss asserted that this goal would have no net impact on the economy. Partisan claims that the EPA is instigating a “war on coal” are “untrue,” Weiss said. Coal companies are supported by carbon capture and storage (CCS) research and development funding established under the American Recovery and Reinvestment Act (P.L. 111-5). Weiss then commented on the public health effects associated with human-induced climate change and cited an article that said California has seen 20 times as many cases of West Nile Virus in mosquitoes which Weiss attributed to global warming. Weiss suggested that the House “help reduce the threat to Americans’ health, safety, and jobs posed by climate change.”
William Chameides, Dean of the Nicholas School of Environment at Duke University, testified on the America’s Climate Choices 2012 Report issued by the National Research Council. The report’s findings state that climate change is caused by GHGs and poses risks to humans and natural systems, the impacts indicate a pressing need to prepare for the impact with federal policies, and uncertainties about the severity of climate change impacts are not a reason for inaction. Chameides mentioned the evidence of rising temperatures, measurements of the highest carbon dioxide concentrations in the past 600,000 years, and studies that show natural systems, such as volcanoes, are not the cause of recent climate trends. He said the adverse changes in climate will be “difficult or impossible to undo” and if emissions are reduced soon, the associated risks and costs will be less. He concluded that an iterative risk management approach that is flexible and adaptable is key to reducing the impacts of climate change.
Louis Cox, Jr. focused his testimony on the public health effects associated with GHG emissions. He asserted that the predictions that tighter GHG regulations could reduce mortality rates among the elderly and save lives are not based on careful research analyses. Cox said the data does not predict that physiological changes in individuals do not occur following changes in GHG pollution levels. In fact, the rising temperatures caused by climate change lead to fewer deaths relative to abnormally cold temperatures. Rather than rely on “invalidated assumptions,” Cox suggested scientists conduct independently verifiable risk analyses before assuming a causal relationship between health and GHG emissions.
In his testimony Gerry Sweeney, president and CEO of one of the largest producers of calcined petroleum coke, discussed the importance of energy cogeneration to allow the capture of byproduct heat, lower costs, reduce GHG emissions, and ultimately increase international competitiveness. Sweeney stated that investment incentives would be more effective than regulations. The regulations his company, Rain CII, is already subject to are “lengthy and costly” and the new CAA regulations would impact the manufacturing sector with higher operation costs and higher electricity prices. He emphasized that delay from regulatory uncertainty risks losing commercial industrial opportunities to “more nimble competition abroad.”
Chairman Whitfield began the first question and answer period by asking Cox to explain in more detail the public health risks caused by GHG emissions and what assessments are needed to better evaluate the risks. Cox replied that the only public health effect would be from heat waves caused by rising temperatures and that scientists are using unreliable computer simulations to assume air toxicity health impacts. Representative Whitfield asked the panel to verify that low-sulfur requirements have inadvertently led to an increase in emissions. Weiss commented that this is correct because many installation and process changes increase the GHG emissions the EPA is trying to control. Whitfield then asked how the tailoring rule regulations are integrated into the farming process. Shaffer responded that it is true that regulations could affect everything from manure management to space heating to operating for drying and curing, and said he was uncertain how the farming community would be able to deal with the costs.
Ranking Member Rush asked William Chameides to respond to Cox’s comments that climate change has no effect on public health. Chameides acknowledged that finding causal relationships between air quality and mortality is difficult, however there are methods to look at past public health trends and model future scenarios. He used examples of the power plant shutdowns for the 1996 Olympics in Atlanta, Georgia which led to a decrease in the number of hospital visits, and the 2003 record heat wave in Europe that killed 20,000-35,000 people.
Representative Barton stated that the EPA Endangerment Finding as a “preconceived conclusion” and said the original 1990 CAA amendments were not intended to cover GHG emissions as a criteria pollutant. He recommended that congressional leaders have a “real debate” on GHG emission regulations as applied to the CAA.
Representative Waxman asked if the United States should expect to see more extreme weather events in addition to the intense heat waves and increased frequency of heavy precipitation. Chameides replied that more extreme weather is expected, but it is difficult to connect these events to climate change. Waxman questioned whether the U.S. should be concerned about melting permafrost and what should be done to address this issue. Chameides responded that permafrost melt will emit methane, a potent GHG. He concluded that with every ton of GHG that is emitted, there is an increased risk for geopolitical problems, poor public health, loss of adequate and clean water supplies, waste of clean energy investments, and unsustainable environmental conditions.
Representative Lee Terry (R-NE) directed questions about GHG emissions from farms to Carl Shaffer. Shaffer responded that average farm will be over the EPA GHG limit of 250 tpy and would have to comply with Title V permits. Shaffer expressed concern that the more stringent restrictions coincide with a time when the nation needs to recruit more farmers and the only way to fall below the emissions threshold is to reduce the quantity of livestock.
Representative Gene Green (D-TX) asked what role congress could have in reducing the effects of climate change. Chameides recommended instituting adaptation preparations and policies that would create a level playing field for clean energy in the marketplace.
Congressman David McKinley (R-WV) stated that many are losing jobs because of the administration’s “war on coal.” Representative Morgan Griffith (R-VA) added that he is concerned about the need for international collaboration to improve global air quality. Chameides agreed that GHG emissions are an international problem, “but traditionally America has been a world leader.”
Representative Mike Pompeo (R-KS) stated that 37,350 farms would be regulated by the EPA if the tailoring rule was overturned and asked if this would be economically significant. Shaffer said this would create “unfair competition” between large and small farmers, delay operating and construction timeline, and require re-permitting every five years. Representative Greg Walden (R-OR) reiterated Representative Pompeo’s concerns that about the economic impacts of GHG regulations. Shaffer said the new permitting requirements would have reduced the economic viability of small farms and have a “ripple-down effect” on the local community. Witness Gerry Sweeney added that permitting costs will put international limitations on business.
Representative John Sarbanes (D-MD) asked what the consequences would be if the federal government does not take action to plan and create adaptation procedures for future climate change. Although the full impacts of climate change will not manifest for another 20 to 30 years, Chameides recommended that preparation for the effects of climate change should be analogous to fire-prevention building codes and become an integral part of future infrastructure planning. He concluded that the federal government could have a critical role in coordination, information sharing, and community empowerment.
Representative Pete Olson (R-TX) concluded the first panel discussion with a statement that the EPA should be required to conduct a thorough economic analysis on the costs that could result from the GHG regulations.
During the second panel, David Wright of the National Association of Regulatory Utility Commissioners (NARUC) described the impacts the regulations on electric utility generating units under the EPA NSPS for GHG emissions would have on the power sector. Wright emphasized that the standards are based on the performance of natural gas combined-cycle units (NGCC) and exclude transitional sources, coal-fired power plants that commence construction within 12 months of the proposal date. He said NARUC is concerned that these qualifications will affect resource diversity and consumer costs. Furthermore, NARUC is concerned that new regulations would create uncertainty about existing power sources and result in over-reliance on natural gas. Wright summarized an economic study on the impact of mercury regulation, the Cross-State Air Pollution Rule (CSAPR), the coal-combustion residuals rule, and the cooling water intake structures regulation, which estimated an additional $21 billion in annual costs between 2012 and 2020. The increase in production costs could raise average retail electricity prices by 6.5 percent. Wright concluded that the U.S. needs to increase environmental performance while maintaining energy reliability and stable utility rates.
In his testimony, David Doniger of the Natural Resources Defense Council (NRDC) told the committee of the widespread national support for reductions in carbon pollution. He said 60 percent of Americans believe carbon pollution will result in staggering health costs and two million Americans support the EPA carbon pollution standard for new power plants. He cited the American Electric Power v. Connecticut Supreme Court decision to allow the EPA to institute a NSPS and reduce the 40 percent contribution to total carbon dioxide emissions from power plants. Doniger emphasized that the EPA standards would have no new effect on the power industry, rate payer, or job market. He concluded that the EPA has helped develop CCS technology and “clean up” the two most polluting sectors—power plants and motor vehicles.
Steven Winberg, Vice President of R&D at CONSOL Energy Incorporated, focused his testimony on the development of CCS technology. Winberg stated that CCS is the most affordable option to reduce carbon dioxide emissions and will be a critical technology for developing countries, where 70 percent of the total global GHG output will source from in 2035. He said CCS is currently too expensive for broad-scale deployment and suppliers are at least 10-15 years from commercializing CCS technologies. Winberg stated that the EPA NSPS will prevent construction of new coal-fired power plants because the technology needed to reduce emissions below the established threshold is not yet available. He said advancing CCS would require an increase in technology investments, a national regulatory framework for carbon dioxide storage, and several pilot-, commercial-scale, coal-fired power plants with applied CCS technology.
In the final testimony, Barbara Walz commented on the efforts of the Tri-State Generation and Transmission Association to provide 1.5 million people with affordable electricity. Walz stated that most of the power is from coal-based power plants. She said the EPA NSPS will “effectively ban the construction of new coal-fired power plants” and will have “far reaching and possibly devastating” effects on rural communities. Walz described that Tri-State’s $70 million investment for a new coal-fired electric generating unit may have to be halted because it does not be able to comply with the “stringent” Mercury and Air Toxics Standards (MATS). She added that the GHG NSPS requirement for coal-fired boilers and natural gas-fired combined cycle turbines to remain below a 1,000 pound carbon dioxide per megawatt-hour is unachievable for nearly all units. She concluded that the EPA has adopted an “unrealistic field of dreams philosophy.” Walz suggested the EPA institute compliance deadlines that allow companies to develop, install, and test new technology and implement “achievable” GHG emission standards.
During the second question and answer period, Chairman Whitfield stated that there are negligible benefits associated with reducing mercury levels under MATS. He asked the panel to comment on the potential rate increases for consumers and the reliability of EPA regulations. Wright responded that the Public Commission of South Carolina has petitioned to have study conducted on the potential impact of EPA regulations and has ongoing dialogue with EPA representatives to discuss compliance costs. Walz said that she is unsure if the $70 million coal-fired power plant will be continued due to unreliable and stringent EPA regulations.
Ranking Member Rush asked Doniger if the EPA is trying to prevent construction of new coal-fired power plants and if the EPA is conducting a “war on coal.” Doniger replied that market realities have driven energy decisions away from conventional coal-fired power plants, regardless of EPA NSPS. He added that the EPA has the partisan-neutral goal to protect public health and the environment from the adverse effects of carbon pollution by encouraging the development of coal-fired plants that use CCS technologies.
Representative McKinley told Doniger his claim that mining employment is increasing is false and that West Virginia lost 1,400 coal jobs in May 2012. McKinley questioned how many CCS facilities were operating in the U.S. Doniger responded that there are currently three being developed. Representative Griffith stated that the increase in electricity rate costs associated with the EPA GHG regulations would negatively affect the poor, middle class, minority, and elderly. Representative Pompeo concluded the hearing and stated that to put the EPA regulations in place is “ludicrous” and the claim that the regulations will not impact ratepayers is “silly.”
Witness testimonies, opening statements, and a webcast of the hearing can be accessed on the committee’s web site.
Senate Committee on Commerce, Science and Transportation Hearing on the European Union’s Emissions Trading System
June 6, 2012
The Honorable Ray LaHood
Secretary, Department of Transportation
Director General of the European Commission, Directorate-General for Climate Action
First Vice President, Air Line Pilots Association, International
Preisdent and CEO, National Business Aviation Administration
International Counsel for Climate and Air, Environmental Defense Fund
Vice President for Environmental Affairs, Airlines for America
Committee Members Present
John Rockefeller (D-WV), Chairman
Kay Bailey Hutchison (R-TX), Ranking Member
Maria Cantwell (D-WA)
John Thune (R-SD)
Frank Lautenberg (D-NJ)
Jim DeMint (R-SC)
Claire McCaskill (D-MO)
Johnny Isakson (R-GA)
John Kerry (D-MA)
Mark Begich (D-AK)
Olympia Snowe (R-ME)
On June 6, the Senate Committee on Commerce, Science and Transportation held a hearing on the European Union’s (EU) Emissions Trading System (ETS). The EU ETS, launched in 2005, is a cap and trade system employed by the EU member states. Factories, power plants and businesses are given emissions caps by their nation’s government and are required to monitor the amount of carbon dioxide they release on a yearly basis. If an organization or country goes over the emissions cap, it must buy permits from countries or organizations which stayed below their cap.
In January 2012, ETS was applied to international airlines based in any country, requiring them to adhere to emissions guidelines set by the EU. The next trading period for ETS begins in January 2013, which is when the EU will require airlines to acquire proper emissions caps.
Chairman John Rockefeller (D-WV) began his opening statement by urging airlines in the U.S, and internationally, to reduce carbon. He said he hoped to hear from the second panel of witnesses what airlines have done and will continue to do saying, “Good intentions don’t work … will not reduce emissions.” The chairman said he “support[s] the goals, but oppose[s] the actions” of the EU in applying ETS to international airlines and believes it is an imposition on U.S. sovereignty. Rockefeller raised concerns about how funds acquired by ETS will be spent as there is no provision requiring them to be spent on reducing emissions, which is not consistent with a Directive which amended paragraph three of article 30. The chairman said many in the airline industry and the Obama administration intend to follow an emissions regulation plan by the UN’s International Civil Aviation Organization (ICAO). He said he is skeptical of this as it could be a way for the airlines to “delay and defer any real action” since ICAO would most likely need a lot of time to draft an emissions regulation for international airlines.
Ranking Member Kay Bailey Hutchison (R-TX) expressed confidence in the aviation industry, arguing they “are willing to have voluntary standards.” Hutchison said she too views the EU as “acting outside its prerogative” by applying ETS to international flight. Hutchison said this violates U.S. and ICAO authority by essentially taxing foreign companies.
As Ranking Member of the Subcommittee for Aviation Operations, Safety and Security and the sponsor of a bill prohibiting U.S. airlines from partaking in the ETS, Senator John Thune (R-SD) gave an additional opening statement. The senator discussed his and Senator Claire McCaskill’s (D-MO) bill, the European Union Emissions Trading Scheme Prohibition Act of 2011 (S. 1956) which would give the Secretary of Transportation the authority to allow airlines and other U.S. companies to refuse to pay for any emissions cap imposed by the EU. A similar bill, the European Union Emissions Trading Scheme Prohibition Act of 2011 (H.R. 2594), has been passed in the House of Representatives. Thune claimed the imposition of ETS on international aviation is “arbitrary, unfair and against … international law” according to ICAO and the Convention on International Civil Aviation, known as the Chicago Convention. He said other countries including India, China and Russia have voiced opposition to the ETS.
Senator Maria Cantwell (D-WA) gave an opening statement as the Chairman of the Subcommittee for Aviation Operations, Safety and Security. She began by expressing support for the scientific community’s consensus on the anthropogenic cause of global warming. However, she agreed that the imposition of ETS on U.S. airlines was illegal and expressed doubt that a cap and trade system could reduce emissions. Cantwell cited the possibility for fraud and rewarding historic polluters in a carbon cap and trade system. She supported the airlines’ compliance with the Federal Aviation Administration’s (FAA) Next Generation Air Transportation System (NextGen) which will use airspace more efficiently, thus reducing emissions. While she believed action should be taken against the EU, the senator cautioned the disadvantages of a “trade war” with the EU.
In his testimony, Secretary of Transportation Ray LaHood expressed the administration’s strong opposition to the imposition of ETS on non-EU airlines on “both legal and policy grounds.” LaHood and Secretary of State Hilary Clinton sent a letter to their EU counterparts to express disappointment in their “go it alone policy” and urged them to include others in policies with an international effect.
LaHood asserted that his department will “take a backseat to no one” in reducing green house gas (GHG) emissions in transportation. He lauded the U.S. airlines for carrying more passengers and cargo while actually reducing emissions. The Federal Aviation Administration reports a 12 percent decrease in GHG emissions from airlines from 2000 to 2010, with a 15 percent increase in passenger and cargo transport per plane in the same period. The secretary said he would express support for a policy if it were made in collaboration with other countries, industry and environmental groups. He assured the committee that the administration is attempting to do this through the ICAO.
Hutchison asked LaHood his opinion of S. 1956, Thune and McCaskill’s bill. The secretary reiterated his discontent with ETS as a “lousy policy” but declined to speak for or against the bill. McCaskill asked how the administration could oppose ETS imposition on U.S. airlines without legislation and noted that the secretary’s power does not allow him to defy ETS. Senator Johnny Isakson (R-GA) said that China and India have already begun to prohibit their airlines from paying any fees related to ETS. The secretary agreed with McCaskill that sufficient legislation, like S.1956, would give him the power to prohibit airlines from participating in ETS, but reasoned that the administration can still make international policy through ICAO.
The chairman was skeptical that ICAO could produce action in so short a period before ETS is imposed on international aviation, but LaHood explained that a discussion on the issue would be productive and ICAO is the best institution available for that discussion. Senator John Kerry (D-MA) asked if the administration had composed a framework for an international agreement through ICAO. LaHood reemphasized that ICAO is the best place to create an agreement though the ICAO has not begun composing an agreement because “they haven’t been pushed to.” Senator Mark Begich’s (D-AK) questions clarified that while ICAO can begin the discussion, other resources and policy makers will be needed to form an agreement.
Senator Jim DeMint (R-SC) urged the committee and LaHood to oppose the Law of the Sea (LOS) treaty claiming it would allow the Secretary General of the United Nations to impose a tax on U.S. sea vessels just as ETS would on airlines. Before his questioning, Kerry denied this claim and asserted there are no environmental regulations imposed by LOS. Kerry said he felt the EU is at least moving in the right direction with ETS, though he said agrees that ETS has no legal right to impose on international aviation. He argued the EU is trying to reduce emissions and is “right to question whether the U.S. is serious about this issue.” He accused the U.S. of being the “chief foot-dragger” against carbon emission control, debating that the United States Conference of Mayors have done more to combat climate change with their Climate Protection Center than the federal government. Senator Frank Lautenberg (D-NJ) sympathized with the EU’s logic, saying, “They just want clean air.” However, he said still opposes the ETS imposition on U.S. aviation.
Prompted by the chairman, LaHood explained how airlines are buying more fuel efficient aircraft. He said he predicts that the more efficient use of airspace emplaced by NextGen will decrease airline emissions dramatically. The secretary told Hutchison in response to one of her questions that NextGen is a top priority for the FAA. Thune brought up the argument that the U.S and other countries charge arrival and departure taxes for foreign aircraft that land and take off on their soil. Secretary LaHood said the major difference is how these policies were enacted. The arrival/departure tax was agreed upon by nations party to ICAO, while the ETS was formulated by countries in the EU and is now being imposed upon others. Thune agreed that this was a significant difference. Cantwell asked the secretary about asked about possible effects from ETS on non-commercial flight, such as private and shipping aviation. LaHood said he could not speak on this issue in detail, but was confident the second panel could provide a better explanation.
The second panel of witnesses was opened by Jos Delbeke, the Director General for the Directorate-General for Climate Action of the European Commission. He cited that European citizens feel climate change is one of the most important issues of today, inspiring the EU to introduce ETS. Delbeke reported that the EU is willing to revise the policy and is committed to a global solution to airline emissions. He argued ETS is in accordance with the Chicago Convention as it does not charge a tax in another state. Funds paid to increase an emissions cap will go to another corporation and though it will likely be a European company, money will not go through the EU. Delbeke asserted that any use of the word “tax” or “fine” is irrelevant to ETS; it is a market-based approach to reducing carbon emissions. He ended his testimony by denying any claims of discrimination in favor of European airlines and assured the committee that any money made from ETS will be put toward lowering emissions.
Captain Sean Cassidy testified on behalf of Air Line Pilots Association, International and discussed the detriments of ETS on the 10 million people employed by the airline industry. He felt the system was a “job-killer” and would surely decrease the economic activity of the airline industry from its 2010 level of $1.1 trillion. He argued that the ETS is a tax, citing a conclusions report by the Council of the European Union which claims the system has “the potential to generate revenue.” He claims the ETS is a dismissal of efforts by U.S. airlines to reduce emissions while increasing the number of passengers. He supports the pursuit of an agreement through ICAO as well as S.1956.
Edward Bolen, president and CEO of the National Business Aviation Administration, testified that in his view, the ETS is “fatally flawed.” His organization represents non-commercial aircraft owners and businesses, who he claims are “treated even worse” than commercial airlines. He gave an example where a small commercial plane that flies to Europe two times or less a day is exempt from the cap and trade while a non-commercial craft which makes one flight a year is not exempt. He argued that European factories with less than 25,000 tons of emissions per year would even be exempt.
In her testimony, Annie Petsonk of the Environmental Defense Fund (EDF) showed support for EU ETS calling it “modest, effective and reasonable.” She argued with a set of charts that the decrease in emissions was due to the relative small number of flights during the 2008 financial crisis and the FAA predicts emissions will increase through 2020.The ETS allows many channels to garner emissions credits, even through industry projects in developing countries. Petsonk correctly asserted that though the ETS does not explicitly state money raised must be used to address climate change, there is a provision that member states must state how the fund will be used. ETS states this allocation must be in accordance with Kyoto Protocol to the United Nations Framework Convention on Climate Change. European nations like Germany have already earmarked trade funds for programs which combat climate change. A FAA-supported study at the Massachusetts Institute of Technology estimated a increase of six U.S. dollars (USD) to round trip airfare, but argued that airlines have “great flexibility to choose when, where and how to meet their caps” and will most likely not raise ticket prices.
Petsonk claimed that ETS imposed flight will create jobs in the airline industry, citing the need for workers to develop, build and implement emissions-capping technologies. She stated ICAO has struggled with the issue of reducing airline emissions for 15 years, and has only started to make progress this year, she speculates, from EU ETS. She counter argued the sovereignty issue by discussing arrival and departure taxes levied by many nations, including the U.S.
Petsonk closed by presenting a scenario where S. 1956 or H.R. 2594 passes and the Secretary of Transportation prohibits airlines from participating in ETS. EDF alleges that the airlines’ insurance policies cannot cover a breach in compliance, and S.1956 gives no path for the secretary to absolve the airlines of responsibility. She suggests taxpayers may have to “foot the bill” in this scenario.
Nancy Young testified for Airlines for America (A4A) in opposition to ETS imposition on international aviation. Her testimony defined the imposition as a dangerous precedent which could result in taxing carbon emitting U.S. exports to Europe like automobiles, other machinery and chemicals. She argued ETS is “about a new source of tax revenue for … Europe” and will have little effect on the environment. She presented data from the Environmental Protection Agency which claims commercial aviation represents 1.7 percent of GHG emissions for the U.S., more than ten times less than non-aviation transport (24.8 percent). She claims the airline industry’s self-imposed emission cutting reforms have done more than the cap and trade “tax” introduced by the EU.
To begin his questioning, Rockefeller compared some of the panel’s testimony against the EU to attacks on the EPA and the president by coal companies as a way to “[make] it OK to hate the government … more importantly, [make] it OK not to do anything about cleaning up [the] product.” He asserted that the technology which reduces airline emissions was not industry’s accomplishment saying, “Don’t congratulate yourselves… the Congress did that.”
The chairman questioned Bolen on the 67 percent increase of emissions from non-commercial aircraft. Rockefeller qualified that two-thirds of aircraft over the U.S. are general aviation and private aircraft to emphasize the industry’s sizable effect on GHG emissions. Bolen said the industry now uses pioneering technologies such as the use of composite metal which makes planes lighter and Global Positioning Satellite (GPS) for more direct flight paths. He explained the general aviation community’s excitement for projects like NextGen and the Greener Skies Initiative.
Prompted by Thune, Delbeke argued that ETS is an “exception” to most EU policies in that it is explicitly stated that funds raised from ETS must be used to combat carbon emissions. Petsonk supported his answer citing that German legislation requires money made from allowance auctions to be spent on lowering emissions.
Young explained to Thune that costs to airlines as a result of compliance with ETS, $3.1 billion between 2012 and 2020, may not be passed on to consumers, but if it is not it will certainly disadvantage the airlines in buying equipment and alternative sustainable fuels. Bolen showed that private companies have already begun to pay to register for the ETS.
Cassidy argued that ETS introduces another level of instability, in addition to terrorist threats and other security concerns, and increased fuel prices, to an industry which represents 5 percent of the U.S. gross domestic product (GDP).
Delbeke alluded to the fact that differing estimates were made about the impact of ETS, which he attributed to a misunderstanding of the acquisition of allowances. He explained that 90 percent of emissions credits are given out for free by the EU. Delbeke further stated that ICAO decided in 2004 it would not formulate a global aviation cap and trade agreement; rather it should be developed by individual states.
Cantwell’s final question was whether the aviation industry would follow a target set by ICAO for global emissions. Young responded that ICAO has set up a target, with a framework that was provided by the airline industry in 2010. She explained that the next step is for ICAO and the airlines to come to agreement on how to implement the framework and achieve these targets.
Witness testimonies, opening statements, and a webcast of the hearing can be found on the committee’s web site.
Senate Committee on Environment and Public Works Subcommitte on Clean Air and Nuclear Safety on "Oversight: Review of EPA Regulations Replacing the Clean Air Interstate Rule (CAIR) and the Clean Air Mercury Rule (CAMR)”
June 30, 2011
The Honorable Gina McCarthy
Assistant Administrator, Office of Air and Radiation, Environmental Protection Agency
Secretary, Department of Natural Resources and Environmental Control for the State of Delaware
Texas Commission on Environmental Quality
Managing Principal, Analysis Group, Inc.
Sr. Vice President Policy and Environmental, Tri-State Generation and Transmission Association, Inc.
Director, Institute for Health and the Environment, University at Albany
Subcommittee Members Present
Thomas Carper (D-DE), Chairman
John Barrasso (R-WY), Ranking Member
Benjamin Cardin (D-MD)
Jeff Sessions (R-AL)
Frank Lautenberg (D-NJ)
Bernard Sanders (I-VT)
The Senate Committee on Environment and Public Works Subcommittee on Clean Air and Nuclear Safety held a hearing on June 30, 2011 to review the Environmental Protection Agency (EPA) regulations replacing the Clean Air Interstate Rule (CAIR) and the Clean Air Mercury Rule (CAMR). The rules are intended to give state by state limits on emissions of sulfur dioxide, nitrogen oxides and mercury from power plants. The new rules would affect thirty one states and the District of Columbia.
In his opening statement, Chairman Thomas Carper (D-DE) stated the importance of maintaining and enforcing high air quality. He described efforts at the state level to combat air pollution, yet cautioned that “air pollution knows no boundary.” While his state and many others are making efforts to decrease air pollution, he said if there is not enforcement on the regional and national level, then those efforts lose value. As an example, he pointed out that Delaware is downwind of other states that are not implementing as high of regulations on air quality. The ranking member of the full committee, James Inhofe, submitted his testimony for the record, though he was not present.
Contrasting the chairman, ranking member of the subcommittee Senator John Barrasso (R-WY) stated the importance of job creation for our economy. His concern was that although clean air is important for public health, unemployment is also detrimental to the public’s health. Quoting Dr. Harvey Bronner from a testimony at a previous hearing, “the unemployment rate is well established as a risk factor for elevated illness and mortality rates in epidemiological studies performed since the early 1980’s.” He cited that the new regulations EPA is considering will cost consumers $184 billion in increased energy costs and will result in 1.44 million jobs lost. Senator Frank Lautenberg (D-NJ) said it was “nonsense” to not put in higher emission standards because of the cost for businesses. He stated “you can’t put a price on human life.” Senator Benjamin Cardin (D-MD) expressed discontent with the “train wreck of rules and regulations coming out of EPA.” He acknowledged the importance of regulating pollutants such as mercury, yet was concerned about the negative economic impact of these regulations.
In her testimony, Gina McCarthy of EPA said these regulations would “dramatically improve air quality.” She acknowledged “we are not the first administration to recognize the need to clean up power plants and to issue rules to address that need.” Starting in 1989, with President George H.W. Bush’s proposal of what later became the Clean Air Act Amendments of 1990, power plant clean up has been a policy of the nation, she stated. During questioning, McCarthy stated EPA has done extensive research regarding the effects of the regulations and felt strongly about the benefits the regulations would bring.
The second panel began with a testimony by Colin O’Mara. O’Mara stated that Delaware has made significant improvements in air quality, yet “as much as ninety percent of our non-attainment problem comes from out-of-state sources and we face significant public health consequences as a result.” He urged that air pollution “is a regional challenge and as such requires a true regional solution.” Bryan Shaw stated in his testimony that “the resulting effect of increased cost of power and power shortages, such as rolling blackouts, would not only jeopardize the personal and economic health of Texas citizens, but also endanger lives.” He also expressed concerns on the results and methodology of the investigations EPA has conducted. “EPA misrepresents the risks associated with mercury emissions and ignores the negligible effects of this rule on risk reduction,” he said.
In her testimony, Susan Tierney supported the implementation of EPA’s two new rules, saying “this is do-able.” She stated the trade-off between reliable energy and clean air is not necessary, “the U.S. electric industry has a proven track record of doing what it takes to provide the reliable power supplies.” Barbara Walz was not in support of the new rules. In her testimony, she stated “these new compliance costs will be passed on directly to cooperative member-owners in the form of higher rates.” Additionally, she expressed concern about EPA’s data collection, arguing emission testing was done on a short notice and does not give accurate representation of the air quality. In the final testimony by David Carpenter, he stated that “air pollutants coming from power plants result in significant human morbidity and mortality…it is critical that every possible step be taken to reduce the release of these compounds as to protect human health.”
In response to a question from the chairman, O’Mara stated the regulations were not too tight and that companies in his state have already gone through cost-effective reductions of air pollutants. Barrasso expressed concern regarding other companies nationwide that have reported support for the new rules. He stated from a Wall Street Journal article that those companies have alternate incentives; by increasing the cost of coal production, natural gas consumption would increase and drive up prices. The companies in support of the rules produce natural gas and therefore would benefit from an increased “clearing price.”
Full testimonies and an archived webcast can be found here.
Contributed by GAP Staff; Erica Dalman, AGI/AIPG Summer 2011 Intern; Stephen Ginley, AGI/AIPG Summer 2012 Intern; Nell Hoagland, AGI/AIPG Summer 2012 Intern; and Krista Rybacki, AGI/AIPG Summer 2012 Intern.
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Last updated on
June 27, 2012