On July 1, 2019, the Department of Energy and Environment (DOEE) proposed amendments to Chapter 8 of the District's air quality regulations that complement the goals of the Sustainable DC and DC Clean Energy Plans. The DC Clean Energy plan was published in August 2018 and explains how the District will use forward-looking energy policies to achieve its greenhouse gas (GHG) emissions targets for 2032.
One of the actions from the plan is to phase out fossil fuels from the District's energy supply by generating laws that set a maximum GHG intensity for electricity supplied to the District. As such, the proposed amendments to Chapter 8 establish a maximum carbon intensity threshold for fuel burned within the District, either for electricity or heating.
Details of the proposed rule include:
- Any new or existing fuel burning equipment (at a major stationary source), as of December 31, 2019, is required to meet the following emission limit:
- 180 lbs/MMBtu heat input of carbon dioxide (CO2) on a daily average basis for each fossil fuel combusted.
- The emission limit applies to each individual fuel type before it is blended or combined with another lower emitting CO2 fuel.
- To show compliance with the proposed regulation, the source must:
- Determine the heat content of their fuel by sampling and testing at least once per year or having fuel specifications from the fuel supplier (updated annually).
- Determine the CO2 mass emissions from the emission source by direct measurement or fuel analysis.
- Monitor and record daily fuel use.
- Determine and record the lbs CO2/MMBtu of heat input, on a daily average basis, for each fossil fuel combusted each day from each emission unit covered by this regulation.
- Submit a quarterly emissions report and certification.
One worthy note is that if a source is using fuel oil that meets the requirements of Title 20 of the District of Columbia Municipal Regulations (20 DCMR) 801 (which is biomass, digester gas, kerosene, propane, or natural gas) the source is considered to be in compliance with the regulation.
The proposed rule can be found online here. Anyone interested in providing comments on the proposed regulation must do so by July 29, 2019. Comments may be mailed/hand delivered to DOEE or email comments to firstname.lastname@example.org. Comments should be clearly marked “Public Comments: Section 807 of the Air Quality Regulations.”
Trinity Consultant's Washington, D.C. office is experienced in assisting clients with air quality regulations within the District. Please contact our office (240) 379-7490 if you have any questions or concerns regarding the proposed regulation and its potential impact on your operations.