LCA Dissents to the CTF Final Portfolio
January 19, 2022
Governor’s Office of Coastal Activities
Attention: CITF Chairman Harry Vorhoff
The Louisiana Chemical Association (LCA) is providing these dissents to the Governor’s Office on the Climate Initiatives Task Force’s (CITF) Final Portfolio of Climate Strategies and Actions (Final Portfolio). LCA is a nonprofit Louisiana corporation, composed of 63 members with over 100 chemical manufacturing plant sites in Louisiana. LCA was formed in 1959 to promote a positive business climate for chemical manufacturing that ensures long-term economic growth for its member companies. LCA member companies employ over 270,000 Louisianians in direct and indirect jobs and create products that support the modern lifestyles of all people in Louisiana, across the Nation, and through exports around the world.
The risks of climate change are a global issue that requires action by all members of society. LCA and its member companies are committed to finding real solutions both to reduce greenhouse gas (GHG) emissions in their operations and to protect the jobs that the chemical industry supports throughout the State. As a sign of that commitment, in February 2021, LCA adopted climate change policy principles, which include several of the strategies and actions described in the Final Portfolio.
LCA appreciates the opportunity to comment/provide feedback on the Final Portfolio by providing the following dissents:
- Action 1.1 – Adopt a Renewable and Clean Portfolio Standard and create a statewide market for Renewable Energy Certificates
LCA is concerned that Action 1.1 may serve to negatively impact investment in projects, which leads to concerns about future reliability of power supply and power generation. To the extent any such standard is adopted, there should be no limitation on the amount of clean power.
- Action 1.5 – Explore the role of Power Purchase Agreements and deregulating power generation in the energy transition
LCA supports Action 1.5 but believes it should be clarified to include not just renewable power but also clean power. Power Purchase Agreements (PPAs) for clean power should be included in the request to the LPSC, because such resources will have few, if any, emissions by 2050.
- Action 1.6 – Develop a regional long-range transmission infrastructure plan to meet Louisiana’s transmission goal
LCA does not believe that specific percentage goals for transmission expansion should be included in Action 1.6, because these numbers are premature. Instead, LCA believes expansion of the transmission infrastructure should be based on the results of transmission planning studies, which consider factors such reliability, cost/benefits of the proposed investment, the particular needs of renewable and clean energy projects, resiliency associated with severe weather events, etc.
- Action 2.4 – Evaluate an Emission Reduction Generation and Supply (ERGS) program
LCA supports Action 2.4 but believes it should be revised so it is clear that the Action is not limited only to renewable power. Based on the most recent edits to the Portfolio of Strategies and Actions, it now appears to limit its application to renewable power which LCA believes may have been in error.
- Action 3.4 – Develop and enforce a Net Zero Industry Standard
Rather than increased regulations, LCA supports a market-based approach to climate policy. LCA has concerns that Action 3.4 as written may lead to carbon leakage by the outsourcing of GHG emissions to neighboring states that have less restrictions. Such a move would not only negate any GHG emissions reductions achieved within the State, but it could also harm Louisiana’s economy and potentially cost the jobs of thousands of Louisianians.
- Action 4.1 – Set Industry Efficiency Standards
LCA believes that market forces, and not increased regulation, will be the primary driver for achieving greater efficiency. LCA believes that increased regulation may serve to stifle the innovation and creativity necessary to achieve energy efficiency.
- Action 5.1 – Accelerate electrification of industrial processes and equipment through pilot projects, incentives, and requirements
LCA believes that technology to promote and accelerate gasification should take place through market forces, and not through a regulatory framework. Increased regulation has the potential to stifle creativity, innovation, and competition.
LCA and its member companies appreciate the opportunity to be part of the Governor’s Climate Initiatives Task Force and its committees and advisory groups and to submit comments on the Final Portfolio of Climate Strategies and Actions. Thank you for your assistance and cooperation.
Gregory M. Bowser
President & CEO, Louisiana Chemical Association