overview epa’s proposed clean power plan and …...coal plant efficiencies • epa notes that...

Overview EPA’s Proposed Clean Power Plan and Impacts for Louisiana

Clean Cities Coalition MeetingNovember 5, 2014

David E. Dismukes, Ph.D.Center for Energy StudiesLouisiana State University

CAVEAT: The views and opinions provided in this presentation are those of the author and do not necessarily reflect the official position of the State of Louisiana or any Louisiana executive agency.

Take Away Points

New Natural Gas End Uses & Fuel Diversity Concerns

2© LSU Center for Energy Studies

Overview

EPA proposed the Clean Power Plan (“CPP”) in June 2014 with the goal of reducing carbon emissions by an average of 38 percent in 2020 (interim target) and 42 percent by 2030, both from 2012 levels.

The CPP is primarily based upon a target rate (lbs/MWh), not a level; although there is a potential “mass-based” conversion.

Rule differs from many past EPA approaches since it:

a) is primarily based on a target rate (lbs/MWh), not emissions level reduction;

b) Is not based on a market-based mechanism or a fixed technology method of emissions reductions;

c) Defines a range of potential compliance options; andd) Has ambiguous non-compliance provisions (at this point).

Final comments on the proposed rule are due on December 1, 2014.

Proposed Louisiana CO2 State-wide Emission Rate Reduction



Overview

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2012 Baseline 2020 Interim Goal 2030 Final Goal

Source: EPA Clean Power Plan Proposed Rule Technical Documents, available at: http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule-technical-documents.

Louisiana’s 2012 baseline is set at 1,533 lbs/MWh and will be required to decrease to 948 lbs/MWh by 2020 and to 883 lbs/MWh by 2030.

lbs

CO

2/M

Wh

2020 Interim Goal: 948 lbs/MWh; a reduction of

585 lbs/MWh, or 38 percent.

2030 Final Goal: 883 lbs/MWh; a reduction of

650 lbs/MWh, or 42 percent.

Total Annual CO2 Emission Reductions Needed



Overview

Note: Plant emissions are for 2012.Source: 2012 EPA Clean Air Markets database.

Proposed rule will require Louisiana to reduce its power sector annual CO2 emissions by over 27 million short tons of CO2 by 2030.

Over 27 million tons of CO2 per year

Big Cajun 2: 11 mllion tons CO2

Brame Energy Center:5.9 million tons CO2

Dolet Hills:5.7 million tons CO2

RS Nelson:6 million tons CO2

State Comparison of Emission Rate Reductions



Overview

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Louisiana’s rate reduction of 650 lbs/MWh is close to the overall U.S. average of 649 lbs/MWh.

US average emission rate reduction: 649 lbs/MWh

Louisiana’s emission rate reduction: 650

lbs/MWh


lbs

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State Comparison of Total Annual CO2 Emission Reductions



Overview

Louisiana requirement is 22nd most stringent state goal under the proposed rule. Top five states account for five percent of the required reduction; top ten states account for

12 percent of the required reduction.

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State Comparison of Total Annual CO2 Emission Reductions



Overview

On a percentage basis, Louisiana’s required reduction of 42 percent ranks 20th overall.

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Myth: Louisiana Will Not be Impacted Much Since it is a Natural Gas State



OverviewP

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Coal Generation as Percent of Total Emissions ReductionU.S. Average Emissions Reduction

States with large shares of coal-fired generation have reduction rates lower than the U.S. average, and lower than many states with larger shares of natural gas-fired generation.


Comparative Impacts: Emission Reductions Per-Capita



Overview

Greater than 3.0M short tons per person

No Requirement

Less than 2.0M short tons per person

2.0M to 3.0M short tons per person

Louisiana is the 8th hardest impacted state requiring 4.04M short tons of CO2 reductions per capita person by 2030.

Source: 2012 EPA Clean Air Markets database; National Electric Energy Data System (“NEEDS”); 40 C.F.R. Part 60, p. 34895; and 2014 Census Estimates.

Comparative Impacts: Emission Reductions Per State GDP



Overview

`

Greater than 100 M short tons per million $

No Requirement

Less than 50M short tons per million $

50M-100M short tons per million $

Louisiana is the 16th hardest impacted state in terms of reduction of CO2 per state GDP.

Source: 2012 EPA Clean Air Markets database; U.S Energy Information Administration, U.S. Department of Energy



BSER and EPA’s Building Block Approach

EPA’s Proposed Clean Power Rule – Louisiana BSER Targets



BSER and Building Blocks

15%

16%

3%

58%

8%

The EPA’s Proposed Clean Power Rule is based on a Best System of Emissions Reductions (“BSER”) that includes four “building blocks.”

Building Block 1: EPA reviewed the opportunity for coal-fired plants to improve their heat rates. BSER

assumes all coal plants can increase their efficiency by 6

percent.

Building Block 2: EPA found an average

availability of 70 percent for natural gas CCs to be technically feasible.

Building Block 3a: EPA identified five nuclear units

currently under construction and assumes that 5.8 percent of

existing nuclear capacity is ‘at-risk” but can be retained.

Building Block 3b: EPA developed targets for

renewable energy penetration in six regions and calculated

regional growth factors to achieve each target by 2030.

Building Block 4: EPA estimated energy efficiency deployment in 12

leading states and assumes all states can increase their current annual

savings rate to reach annual savings of 1.5 percent by 2030.

Each building block accounts for a portion of the total goal.

Louisiana Average Fossil EGU CO2 Emissions Standard based on BSER



BSER and Building Blocks

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2012 FossilEmissions Rate

Coal Heat RateImprovement

Gas CC Re-Dispatch

New and "At-Risk" Nuclear

Existing andNew

Renewables

New EnergyEfficiency

2030 ProposedEmissionsStandard

Louisiana Average Coal CO2 Rate

Louisiana Average NGCC CO2 Rate

CO2 RateReduction: 42%

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il E

GU

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2E

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sion

s S

tand

ards

(lbs

/MW

h)

Source: LA 111(d) EGU Computation.xlsx.


Building Block 1: Coal Plant Efficiency Improvements

Building Block 1: 4-6 Percent Lower Emissions from Existing Coal Generation



Coal Plant Efficiencies

• EPA notes that several studies have examined the potential to improve heat rates as coal-fired power plants, noting specifically a 2009 study by the engineering firm Sargent & Lundy.

• Based on the 2009 Sargent & Lundy study, EPA estimated that potential heat rate improvements are in the order of approximately 4 to 12 percent. Furthermore, based on review of EPA and DOE EIA generation data, EPA estimates that historically EGUs have experienced heat rate improvements from 3 to 8 percent.

• Based on a review of prior studies and generation trends, EPA estimates the potential for improvements in heat rates of between 4 and 6 percent, which mirrors a reduction in CO2 emissions by the same.

• EPA notes that improvements in heat rates decrease fuel consumption and thus costs, and that a 6 percent improvement would be sufficient to cover costs associated with improvement.

Source: 40 C.F.R. Part 60, pp. 34859-34861.

FacilityGenerator

ID

2012 Emissions

Rate(lbs/MWh)

Thermal Efficiency

Improvement Factor

(%)

Adjusted Emissions

Rate(lbs/MWh)

2012 Net Output(MWh)

Dolet Hills 1 2,460 6.0% 2,312 4,616,823

R S Nelson 1 2,693 6.0% 2,531 821,331 R S Nelson 2 2,683 6.0% 2,522 802,645 R S Nelson 6 2,493 6.0% 2,344 3,118,384

Big Cajun 2 1 2,192 6.0% 2,061 3,273,725 Big Cajun 2 2 2,140 6.0% 2,012 3,408,652 Big Cajun 2 3 2,114 6.0% 1,987 3,594,632

Brame Energy Center 2 2,257 6.0% 2,121 2,677,857 Brame Energy Center 3 2,439 6.0% 2,292 1,992,364

Average Emissions Rate: 2,323 2,184

Building Block 1, Coal-Fired Heat Rate Efficiency




EPA applies a six percent thermal efficiency improvement factor for each coal generation facility, setting a 139 lbs/MWh reduction target.


Building Block 1 Issues




There are a number of incorrect and problematic assumptions included in the development of this building block:

• Use of gross rather than net heat rate reductions.

• Statistical modeling used for heat rate analysis is flawed.

• Fails to consider recent efficiency gains/new pit technologies.

• Fails to consider efficiency losses of control technologies from other EPA rules.

• Cannot be practically done given new source review standards.

• Fails to examine or consider stranded generator costs (rate impacts).


Building Block 2: Increased NGCC Utilization

Recent Trends in Louisiana Gas-Fired Generation



NGCC Utilization

Louisiana’s natural gas heat rates have fallen 9.7 percent in the last 10 years (at an average annual rate of one percent); and natural gas-fired emissions have fallen 11.2

percent (at an average annual rate of 1.2 percent).

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Natural Gas Heat Rate Natural Gas Emissions

Hea

t Rat

e (B

tu/k

Wh)

Source: 2012 EPA Clean Air Markets database.

Louisiana NGCC Efficiencies and Utilization



NGCC Utilization

On average, Louisiana’s NGCC units operate at heat rates that are 29 percent lower than Louisiana’s steam units and emit 30 percent less emissions.

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issions (lbs/MW

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Building Block 2, Natural Gas CC Dispatch



NGCC Utilization

EPA assumes all natural gas-fired combined cycle units can be re-dispatched at a rate of 70 percent. This increases the NGCC generation from 19.8 million

MWh to over 40 million MWh, an increase of 102 percent.

Source: 2012 EPA Clean Air Markets database.

EPA EPA Highest HighestNameplate 2012 Estimated Assumed in Last in Last

Capacity Generation Generation Increase 10 Years 5 Years(MW) (%)

Louisiana 1 406.3 2,949,067 2,498,257 -12.6% 99.5% 99.3%Coughlin Power Station 922.8 1,434,842 5,674,113 52.3% 26.9% 26.3%Sterlington 226.3 4,610 1,391,473 69.8% 15.6% 1.4%Acadia Energy Center 1,376.0 4,785,503 8,460,749 30.4% 40.8% 40.8%Carville Energy LLC 570.0 2,899,630 3,504,816 12.1% 62.6% 62.6%Ouachita 903.9 1,658,025 5,557,900 49.1% 20.8% 20.8%Washington Parish Energy Center 655.0 - 4,027,464 70.0% 0.0% 0.0%Perryville Power Station 824.1 2,486,523 5,067,226 35.7% 29.4% 29.4%J Lamar Stall Unit 624.0 3,552,982 3,836,851 5.2% 43.0% 43.0%

Total 6,508 19,771,182 40,018,850 34.7%

Capacity Factor

------ (MWh) ------

Building Block 2 Deficiencies



NGCC Utilization

There are a number of errors and problems with the EPA methodology:• Incorrect data. For instance, the EPA includes Washington Parish Energy Center

(655 MW) in Louisiana’s NGCC capacity totals. Other items include Louisiana 1, Perryville’s 2 CT unit and the omission of NGCCs under construction (Ninemile 6 and Morgan City 14-01).

• The EPA incorrectly uses nameplate capacity rather than net summer capacity to estimate the total NGCC potential.

• Fails to understand the gravity of the change on the use and operation of these units.

• Fails to examine ripple impacts to natural gas markets. The EPA does not consider the increased use of natural gas associated with a 102 percent increase in natural-gas fired capacity (in Louisiana alone).

• Does not adequately examine transmission constraints.• Fails to examine or consider stranded generator costs (rate impacts).


Building Block 3a: “At Risk” Nuclear Power Generation

Building Block 3a, “At Risk” Nuclear Capacity



At-Risk Nuclear

• In Building Block 3a, the EPA assumes 5.8 percent of the current nuclear fleet is “at risk.” This nuclear capacity is incorporated into state goals as zero emitting generation (at a 90 percent capacity factor).

• Nuclear is not considered a “dispatchable” resource as is NGCC capacity; and instead of redispatching from coal to nuclear like in Building Block 2, the expected generation is simply added to the state goal denominator – lowering the state goal emission rate.

• For Louisiana, this amounts to 985,225 MWh being added to the denominator (generation) to calculate the emissions rate.

Historic Trends in Nuclear Generation, Operating Plants and Generation



At-Risk Nuclear

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Number of Operating Plants Generation

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Wh

Source: Energy Information Administration, U.S. Department of Energy.

The number of operating nuclear plants in the U.S. remained constant until this year, when four plants were retired. Nuclear generation has been falling in

the last five years.

Historic Trends in Nuclear Generation, Average Annual Capacity Factor



At-Risk Nuclear

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%)

The average annual capacity factor of nuclear facilities has been between 86 percent and 92 percent.


Nuclear Power Plant Operating Challenges: Zero Dispatch



At-Risk Nuclear

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Building Block 3a Deficiencies



At-Risk Nuclear

• EPA’s allowance for “at risk” nuclear capacity effectively subsidizes unprofitable generation

• The basis for EPA’s “at risk” nuclear capacity estimates is weak and not well supported

• EPA’s “at risk” nuclear proposals are ambiguous on how nuclear generation will be treated for compliance purposes

• Unintended consequences of EPA’s Proposed Rule on nuclear generation.

• EPA should not expand its definition of “at risk” nuclear capacity.



Building Block 3b: Renewable Generation

Building Block 3b, RE Potential



Renewables

EPA assigns the states to one of six regions and sets a RE target for each, based on an average of all 2020 RPS requirements of the states in that region.

20%by 2020

10%by 2020

10%by 2020

33%by 2020

30%by 2020

20%by 2020

15%by 2020

15%by 2020

20%by 2020

22%by 2020

West Average: 22%

South Central Average: 20%

South East Average: 10%

DE: 19% by 2020DC: 20% by 2020MD: 18% by 2020NJ: 22% by 2020PA: 8% by 2020OH: 9% by 2020

East CentralAverage: 16%

CT: 23% by 2020ME: 40% by 2020MA: 22% by 2020NH: 20% by 2020NY: 29% by 2020RI: 16% by 2020

NortheastAverage:

25%

16%by 2020

10%by 2020

30%by 2020

10%by 2020

North Central Average: 15%

10%by 2020

Louisiana’s Existing Biomass Capacity



Renewables

Louisiana’s biomass capacity totals 445 MW. However, almost 60 percent of this capacity (262 MW) is over 30 years old.


Online FacilityCompany Name Generator Id Capacity Date Age Fuel

(MW) (years)

Agrilectric Power Partners Ltd GEN1 12.1 1984 30 Agricultural ByproductBoise Packaging & Newsprint LLC TG 61.5 1969 45 Wood/Waste WoodTemple-Inland Corp NO10 37.0 1999 15 Wood/Waste WoodTemple-Inland Corp NO8 25.0 1981 33 Wood/Waste WoodTemple-Inland Corp NO9 37.5 1979 35 Wood/Waste WoodIPC-Mansfield Mill GEN1 40.0 1981 33 Black LiquorIPC-Mansfield Mill GEN2 40.0 1981 33 Black LiquorIPC-Mansfield Mill GEN3 30.0 1981 33 Black LiquorM A Patout & Sons Ltd 1000 1.0 1981 33 Agricultural ByproductM A Patout & Sons Ltd 2000 2.0 1981 33 Agricultural ByproductGeorgia-Pacific Consr Ops LLC-Port Hudson GEN1 67.7 1986 28 Black LiquorKPAQ Industries LLC GEN2 12.5 1966 48 Black LiquorRed River Mill Intl Paper Company 3 T-G 78.8 2008 6 Black Liquor

Total 445.1

NREL Estimated Technical Potential for Onshore Wind Power by State



Renewables

Source: National Renewable Energy Laboratory, U.S. Department of Energy.

Thousand GWh

< 5050 – 100100 – 500500 – 1,000> 1,000

Louisiana is not likely to be installing much onshore wind power.

NREL Estimated Technical Potential for Utility-Scale Solar PV by State



Renewables

Thousand GWh

< 1010 – 5050 – 7575 – 100> 100

Large amounts of solar is unlikely as well.


NREL Estimated Technical Potential for Biopower by State



Renewables


Thousand GWh

< 11 – 55 – 1010 – 15> 15

Biomass is Louisiana’s most likely option for increasing renewable generation.

Building Block 3b, Louisiana Renewable Requirements



Renewables

Under Building Block 3, the EPA expects Louisiana to be able to increase current renewable generation to 7 percent of total generation by 2030, an increase of 184 percent from current levels.

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Target Baseline

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Building Block 3: Renewable Energy Growth



Renewables

Under Building Block 3, the EPA expects Louisiana to be able to increase current renewable generation to 7 percent of total generation by 2030, an increase of 184 percent from current levels.

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2012 Renewable Percentage 2030 Goal Percentage

Building Block 3b Deficiencies



Renewables

There are a number of problems with the EPA methodology:• The EPA targets are based upon an erroneous method of averaging..• Louisiana’s RE potential differs considerably from other states in this region.• EPA’s calculations are in error (capacity vs. generation). The Kansas RPS is a

capacity based goal, and correcting for this will change generation based targets significantly.

• It is well documented the Louisiana has limited technical RE capabilities. • The EPA’s proposed rule is ambiguous on the degree to which states will be

allowed to use biomass to meet RE generation targets.• EPA fails to recognize the age of existing RE facilities in Louisiana. Most of the

State’s non-hydro RE generation was developed in the late 1970s and 1980s.• EPA assumptions are inconsistent with the findings of the LPSC RPS

proceeding. The LPSC has already analyzed the opportunities for RE in the State.

• The EPA fails to consider lost fixed cost recovery (lost revenues or rate impacts).



Building Block 4: Increased End-Use Energy Efficiency

Building Block 4, Energy Efficiency Deployment



Energy Efficiency

EPA determines the total MWh sales that could potentially be avoided through demand-side energy efficiency measures.

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ulat

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ings

as

a P

erce

nt o

f Sal

es

0.0% 0.2%0.6%

1.1%1.9%

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2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Incremental EE Savings Cumulative EE Savings

0.2 percent increase per year

1.5 percent increase per year

Building Block 4 Deficiencies

Energy Efficiency

There are a number of problems with the EPA methodology:

• Inappropriate method of determining technical potentials.

• Fails to examine cost-effectiveness.

• Fails to recognize that prior potentials arose in high-cost energy environment.

• Fails to consider rate impacts and lost base revenues.

• Fails to consider CHP potentials at industrial facilities.

• Fails to examine total rate and ratepayer impacts adequately (cumulative impacts).


Building Block 4, Energy Efficiency

Energy Efficiency

Source: 40 C.F.R. Part 60, pp. 34873-34874.

Under Building Block 4, the EPA assumes it is practical for all states to implement demand-side portfolios such that 1.5 percent of annual sales growth per year are reduced. The compounded effect results in a full 1.1 percent of total annual sales being avoided by Louisiana in 2020, and 9.3 percent

of total annual sales being avoided by 2029. This is an increase

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The increase is actually greater than 5,000 percent




Conclusions

EPA Rulemaking Timeline

Conclusions

June 2014

EPA issuesproposed

Clean PowerPlan

Commentsdue on

proposedplan

December2014

Target datefor EPA to

issue Final Rule

Target datefor states to

submit proposedImplementation plans

June2015

June2016

December2015

December2016

States develop individual implementation plans


Conclusions

Conclusions

• Regardless of your opinion on carbon regulation, there are a number of problems and challenges with the EPA rule.

• Inefficient way to regulate carbon emissions: fails to examine cost-effectiveness, represents the worst in command and control regulation by (a) not utilizing market-based approaches and (b) forcing resource decisions on state regulators.

• This rule has very little to do with environmental regulation, and everything to do with utility regulatory resource planning.

• The costs to Louisiana ratepayers could be considerable. Some concerns this could create a significant near-term reliability challenge as well.


Questions, Comments & Input

Conclusions

CAVEAT: The views and opinions provided in this presentation are those of the author and do not necessarily reflect the official position of the State of Louisiana nor any Louisiana executive agency.

Comments, Questions
