Transcript Slide 1

Go Green, Live Healthy, Be Safe
GHG Reporting and Regulation
Laura Mendicino
Freescale Semiconductor / SIA
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Overview
GHG Reporting: SIA Strategy
GHG Reporting: SIA Comments to USEPA
ACES (Waxman-Markey) Legislation Overview
SIA Legislative Strategy
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Proposed Rule Emissions Estimation
3 components to determine semiconductor GHG emissions (CO2e)
- amount of each F-GHG (+N2O) used
- emissions factors for each gas/process (including abatement)
- 100 yr Global Warming Potential (GWP)
Proposed Rule required very prescriptive methods to determine gas
usage and emission factors
- Gas usage for all facilities (cylinder weighing, mass flow
controllers)
- Measured emission factors (no “defaults”) for large facilities
- Abatement factors for any facility only allowed if measured
**Large facility defined as > 10,500 m2 Si processed per year
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SIA Issues with Proposed Rule
1) Erroneous assumptions by EPA regarding current industry practices
2) The proposed rule would require gas usage tracking and reporting by
instrumentation and methods that most companies do not currently have
- Purchase of capital equipment and possible re-piping of gas
distribution systems
- Significant cost & burden well beyond EPA estimates
3) The rule would require large companies to measure process-specific
emissions factors that most companies do not currently have
- Each type of tool (CVD, Etch), has multiple platforms with each
platform running multiple recipes, each of which would have to be
characterized.
- Significant cost/burden (large facilities) for emissions
characterization well beyond EPA estimates
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
7/17/2015
CONFIDENTIAL - SIA Board Meeting – June 09, 2009 – Washington, DC - CONFIDENTIAL
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SIA Issues (cont.)
4) The rule only allows for abatement to be considered if factors are
measured in specified ways (no defaults)
5) Much of the required data (emissions and capacity) to be reported
is considered highly confidential and would become public record
6) The rule requirements are well above & beyond what other
countries/regions require (competitiveness)
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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SIA Strategy
Comprehensive review of Proposed Rule requirements
High level comments provided at 04/06 public hearing
Partner with International Sematech Manufacturing Initiative (ISMI) to collect
comprehensive data from broad joint-membership:
- Gas usage measurement
- IPCC Tier methodology used to estimate emissions
- Level of emissions characterization & methodology used
- Level of abatement characterization & methodology used
- Estimated cost (per facility) to meet Proposed Rule
- Information on N2O and heat transfer fluid usage & data
- Information on confidentiality & competitiveness
Perform gap analysis of proposed requirements and current industry
practices
Propose more amenable alternatives to proposed requirements
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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SIA Comments
Provided long history of semiconductor commitment to GHG emissions
reduction
Provided comments on Source Category-specific aspects
- Gas Consumption Determination (proposed Tier 2b estimates)
- Applying Emissions Factors (proposed Tier 2b default factors)
- POU Abatement - Verification of DRE
- N2O Emissions
- Emissions of Heat Transfer Fluids
- Reporting Threshold and De minimis Emissions
Comments provided specific details on:
- Issues raised by the proposed requirement
- ISMI survey results
- SIA proposed alternative method for reporting
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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SIA Comments (cont.)
Provided comments on general provisions of the Proposed Rule
- Competitiveness
- Confidentiality
- General reporting requirements (for all)
- Analysis of Regulatory Impact Analysis (RIA)
All ISMI survey data provided with comments for EPA review
Next step: Focus on legislation regarding GHG emissions
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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Waxman-Markey Bill (ACES)
American Clean Energy & Security Act
Essentially 4 “Titles” in proposed legislation
- Clean energy
- Energy efficiency
- Global warming (III/VII/VIII)
- Transitioning
Most aspects of “Cap & Trade” fall under Title III/VII/VIII
- Emissions allowances (with progressive “caps”)
- Offsets
- Performance Standards
Bill narrowly passed House on 6/26
Senate likely to take Bill to Committee after August recess
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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Current Structure (Semiconductor specific)
All Fluorinated gases regulated “upstream” except NF3
- Gas supplier must carry allowances = to total CO2e of gas
produced and sold in the US (not exported)
- End users can file for and obtain “compensatory allowances” for
the amount of upstream regulated F-gases not emitted due to
destruction or conversion (abatement or process)
- Compensatory allowances could be “given” to upstream gas
suppliers
- HFCs are regulated upstream and separately with a phase-out
over time (similar to Montreal Protocol)
- SF6 also regulated upstream do to its commodity end use
NF3 is regulated “downstream”
Potential that other F-gases (not HFCs or SF6) could be regulated
downstream – EPA to commission study by 2014
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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Covered Entities and Reporting Entities
“Covered Entities” (subject to Cap) defined as facilities that
- Produce F-gases (not end users) > 25,000 T CO2e
- Emit > 25,000 T CO2e of NF3 specifically
- Have stationary combustion emissions of > 25,000 T CO2e
Reporting Entities (“Would be” “Covered Entity”)
- Emit > 10,000 but < 25,000 T CO2e NF3
- Emit > 10,000 but < 25,000 T CO2e combustion
- Subject to Registry, but not Cap
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of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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SIA Issues/Strategies
Move F-Gas regulation (not HFCs or SF6) downstream
- Would make more facilities “covered entities” but would relieve
suppliers of burden of allowances
Modifications to Registry language – assert administrator’s discretion to allow
alternative methodologies for emissions determination (not CEM)
Credit for Early Action (offsets & reductions 2001 to 2009)
Title IV assistance – “free” allowances for energy intensive & competitive
industries (would phase down over time)
PFC definition and “new GHG” notices
New Source Performance Standards for not covered entities (uncapped)
Moderate HFC phase-out for our industry use
Freescale Semiconductor Confidential and Proprietary Information. Freescale™ and the Freescale logo are trademarks
of Freescale Semiconductor, Inc. All other product or service names are the property of their respective owners. © Freescale Semiconductor, Inc. 2006.
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