The Environmental Protection Agency’s proposed greenhouse gas emissions standards for power plants could hurt grid reliability, with the potential for “significant power shortages,” according to major U.S. grid operators.
“The joint [independent system operators/regional transmission organizations] are concerned that the proposed rule could result in material, adverse impacts to the reliability of the power grid,” four of the largest U.S. grid operators said in joint comments to the agency Tuesday.
Their reliability concerns mainly stem from the chance that the EPA is overestimating how quickly technological advances may occur in “green” hydrogen production, transport and generation, as well as in carbon capture and storage, or CCS…
Gas-fired combustion turbines larger that 300 MW and with at least a 50% capacity factor have two compliance options: CCS with 90% carbon capture by 2035, or co-firing of 30% low-GHG hydrogen beginning in 2032 and co-firing 96% starting in 2038, according to the agency.
I’m skeptical of these claims. In the Texas winter storm that took down large parts of our grid the oil-friendly governor blamed renewables, even though renewables were OVER PERFORMING at that time and it was fossil fuels that had serious trouble. Natural gas pipeline infrastructure freezing for crying out loud. Infrastructure that they were warned to winterize a decade prior and never did because profits.
The grid operators here do include Texas but also all of the Midwest and the MidAtlantic states. But, I doubt it’s a national conspiracy. What they are talking about is a required switch to untested methods.
We already know there are significant grid problems. Mandating on top of that a switch to technologies that hardly exist at present is asking for trouble.
One summer afternoon at the pump seal company, I heard a phone ringing and ringing, off somewhere. I hit *7 and picked up the line (Dimension PBX). It was a field rep, looking for one of the honchos, who was out of the office. The field rep asked me to transfer him somewhere else. I then went back to work.
Some minutes later, I heard a phone ringing and ringing off somewhere. *7 again. It was the same field rep, looking for a different honcho. Out of office. He asked to be transferred someplace else. I then went back to work.
Some minutes later, I heard a phone ringing and ringing off somewhere. *7 again. It was the same field rep, again, looking for a different honcho. Out of office. The field rep asked me “are you the only person working?”, then blew his stack about not being able to get hold of any of the honchos of the company, when he needed some help.
This was a Thursday afternoon. All the honchos left early on Thursdays, to play golf together, which they all insisted was very, very, important.
Is that the talking point they are promoting at the Heartland Institute? It is a good talking point, as long as you don’t include too much reality.
We’re in the comment period of a proposed rule. The Clean Air Act requires “best system of emission reduction” (BSER) that has been “adequately demonstrated.” By law, EPA cannot require use of untested methods to comply with the Clean Air Act. The stakeholders are commenting as they should be.
Even though we are still in the comment phase, these rules didn’t come out of nowhere. EPA knows it is going to get sued by all sides once the rules are promulgated. So they are carefully designed to be defensible in court. Despite what the professional liars at the Heartland Institute say, I find it extremely implausible that EPA is deviating from BSER requirement.
To be clear, not all EPA rules survive court challenges. Just last year, anti-science lobbyists successfully challenged Obama’s EPA rules about restricting carbon emissions.
However, it was a bit of a pyrrhic victory, because industry had already exceeded all of EPAs targets a decade earlier.
No, those were the comments submitted to the EPA on the proposed rule making as you are aware. These are the professionals responsible for the electrical grids of almost half of the US.
Here is the article from the PJM website:
On August 8, PJM joined MISO, ERCOT and SPP in submitting comments in response to a proposed EPA rule on New Source Performance Standards for Greenhouse Gas Emissions. The geographic reach of the Joint ISOs/RTOs encompasses an area of approximately 2 million square miles, in all or parts of 30 states and the District of Columbia, providing electric service to 154 million Americans.
In their Joint Comments, the Joint ISO/RTOs explained their concern with the potential reliability impacts of the proposed greenhouse gas rule.
…the Joint ISO/RTOs are concerned about a scenario in which, similar to that stated above, needed technologies are not widely commercialized in time to balance out large amounts of retirements.”
Throw us a bone here. You started off at “untested methods” and now we’re at “not widely commercialized.” But “not widely” implies it is commercialized. How is commercialized technology–even if only on a small scale–the same as an untested method?
The industry comments don’t sound nearly as hysterical as the Heartland institute’s spin. And in most ways sound pretty reasonable. They say might need more time because the commercial technology they need won’t be available in the quantities they need it. That’s possible but they aren’t saying it that it is a problem for sure, either.
And they have some other neutral comments like requesting a carbon trading system, and the like (I don’t know if EPA has the power to do that, but sounds reasonable to explore that option), as well as a few technical points which I don’t know enough to evaluate, but sounded like they would make it easier to advance EPA’s goal.
I straight up didn’t see anything about a requirement to implement untested methods.
AFAIK, the hydrogen technology is untested at scale. As you know, R&D projects are quite different from commercial scale projects.
As for carbon capture and storage…
“Boundary Dam’s underwhelming performance is a foreboding sign of broader issues with CCS technology in general. In May 2021 a team of researchers studied 263 CCS projects undertaken between 1995 and 2018 and found that the majority failed, while 78 percent of the largest projects were cancelled or put on hold.”
And from that Wang et al. paper:
“The results indicate that larger plant sizes increase the risk of CCUS projects being terminated or put on hold; increasing capacity by 1 Mt CO2/y increases the risk of failure by nearly 50%.”
Maui County sues utility, alleging negligence over fires that ravaged Lahaina, August 24, 2023
“Had the utility heeded weather service “warnings and de-energized their powerlines during the predicted high-wind gusts, this destruction could have been avoided,” the lawsuit said.”
AEMO CEO Daniel Westerman said…“Over the 10-year outlook, we continue to forecast reliability gaps, which are mostly due to the expectation that 62% of today’s coal fleet will retire by 2033…"
Considering only existing, committed and anticipated projects as per the ESOO’s ‘central scenario’, reliability risks are forecast to exceed the relevant reliability standard in Victoria from this summer, in New South Wales from 2025-26, South Australia this summer and then again from 2028-29 and Queensland from 2029-30.
And, at least in Michigan, the utility companies want the government to pay them to increase generation capacity. A few years ago, the Michigan utility companies were running an ad campaign against buying any power from out of state, spreading FUD that “out of state” power sources could not be trusted. Their solution was to have the (L&Ses) pass a law requiring the state to guarantee the utility company’s profits on every bit of new capacity they built in-state.