Federal Energy and Environmental Policy | Clean Energy Regulatory Forum | Task Force on Ensuring Stable Natural Gas Markets | MIT Future of Gas Study | Climate Change

Federal Energy and Environmental Policy

ACSF regularly comments on U.S. government proposals that impact the electric power sector and associated air emissions.  Comments have been filed with the Federal Energy Regulatory Commission (FERC); the Department of Energy’s Office of Energy Efficiency and Renewable Energy (EERE); and the Environmental Protection Agency (EPA).

FERC

• On February 29, 2012, ACSF provided comments on FERC’s Staff White Paper on the Commission’s Role Regarding Environmental Protection Agency’s Mercury and Air Toxics Standards (MATS). ACSF suggested adjustments to EPA’s and FERC’s proposed MATS extension procedures to avoid unnecessary reliability problems, urging the adoption of an order (or orders) to require early, open and transparent planning that meaningfully involves state regulators and informed stakeholders.
• On March 2, 2011, ACSF commented on a Notice of Proposed Rulemaking regarding Integration of Variable Energy Resources (VERs).  ACSF’s response focused on the fair allocation of costs for the ancillary services needed to support more renewable energy.  The Foundation also supported Chairman Wellinghoff’s goal of encouraging VERs and natural gas to partner as a means of creating a cleaner baseload system for electricity generation.
• On May 13, 2010, ACSF responded to FERC’s request for comment on a proposal to pay market prices for energy demand response resources.  In its submission, ACSF voiced concern over the unintended consequences for air emissions and the impact on cleaner supply side resources.

EPA

• On August 4, 2011, the Foundation filed comments supporting EPA’s proposed rules to reduce the emission of hazardous air pollutants (HAPs), such as mercury and acid gases, from power plants.  ACSF urged the EPA to spell out how existing power plants could comply with the new rules by burning more natural gas which does not produce the same harmful pollutants.  ACSF said substituting gas for more polluting fuels should qualify as one of the “maximum achievable control technology” (MACT) choices that would be mandated by the new EPA rules.
• On October 1, 2010, ACSF provided comments to support EPA’s proposed Clean Air Transport Rule and explained how its emission allocation method and other components of the proposal could be improved.
• On March 22, 2010, ACSF replied to the agency’s request for comment on its proposal to tighten National Ambient Air Quality Standards (NAAQS).  ACSF urged EPA to move forward on its proposal and to explicitly recognize the major role natural gas can play in enabling regulated parties to comply with more stringent ozone standards in a cost-effective and timely way.

DOE

• On April 11, 2012, ACSF submitted comments on DOE’s proposed “Petroleum Reduction and Alternative Fuel Consumption Requirements for Federal Fleets,” strongly supporting the Proposed Rule’s goals but explaining how it could better encourage consumption of alternative transportation fuels like natural gas.
• On October 29, 2010, the Foundation answered DOE’s request for comments on a proposal to modify the methods it uses to measure the energy use and emissions from consumer appliances.  ACSF supported DOE’s adoption of full fuel-cycle measures for benchmarking the energy efficiency of appliances.  The Foundation also urged more widespread use of fuel-cycle principles in DOE’s standards setting so as to provide the public more complete information in the greenhouse gas footprint of appliances.
• In response to DOE’s 2009 National Electric Transmission Congestion Study, ACSF advised DOE to better consider the role of natural gas in complementing renewables, and as a cleaner alternative to coal.

Clean Energy Regulatory Forum (CERF)

ACSF has established a biannual workshop for industry professionals and environmental advocates to develop new regulatory options for promoting a cleaner, low carbon electricity sector.  The workshops have been supported by the Energy Foundation, and the William and Flora Hewlett Foundation.

Selected papers available from the first workshop (held at the Aspen Wye River conference center in February 2011):

Clean First: Aligning Power Sector Regulation with Environmental and Climate Goals.  Richard Sedano, The Regulatory Assistance Project.

Choices in Air Regulation: A Review of Alternative Air Emissions Policy Structures for the Electric Sector, Chris Van Atten, M.J. Bradley & Associates.

The Business Case for Integrating Clean Energy Resources to Replace Coal, Joel Swisher, Consulting Professor at Stanford University and former Technical Director, Camco International.

A Brief Survey of State Integrated Resource Planning Rules and Requirements, Rachel Wilson and Paul Peterson, Synapse Energy Economics.

Selected papers available from the second workshop (co-hosted with the Environmental Law and Policy Center in Chicago, IL in October 2011):

System Flexibility and Clean Energy Integration, Matt Schuerger, Energy Systems Consulting Services.

Resource Incentives: Valuing Resources in PJM’s Wholesale Markets, Paul Peterson, Matthew Wittenstein, and Jean Ann Ramey, Synapse Energy Economics.

For more information, contact ACSF’s Geoff Bromaghim.

Forum on CCS for Natural Gas

While combined cycle gas turbine facilities emit roughly 60% less CO2 per kilowatt hour than conventional coal generators, over the long term controlling the CO2 footprint of gas-fired power via carbon capture and storage (CCS) will be essential for achieving our carbon reduction goals.

Today, however, U.S. RD&D efforts have concentrated almost exclusively on developing and deploying CCS for coal. To address this shortfall in power sector planning, and in view of the expanded demand likely for gas-fired generation (See this 2010 ACSF report),  ACSF convened a full-day program in November 2011 in Washington D.C. This event brought together top experts from the power sector, equipment manufacturers, Wall Street, research institutes, the government and the environmental community.

Click here to view presentations or video recordings from this important event

Task Force on Ensuring Stable Natural Gas Markets

ACSF and the Bipartisan Policy Center jointly convened this Task Force in March 2010 to examine historic causes of instability in natural gas markets and to explore potential remedies.  Task Force members represented natural gas producers and distributors, consumer groups and large industrial users, as well as independent experts, state regulatory commissions and environmental groups.  Following a yearlong set of workshops and meetings, the Task Force released its final 70-page report in March 2011.

Click here for the press release and key recommendations.

MIT Future of Natural Gas Study

ACSF is a co-sponsor of a comprehensive three-year study on the role of natural gas in the American economy initiated by the MIT Energy Initiative (MITEI).  The study, launched in 2008, was carried out by a multidisciplinary team of 30 MIT faculty members, researchers and graduate students, with advice from 16 leaders from industry, government and environmental groups.  Their final report reviews the future of natural gas through 2050 from the perspectives of technology, economics, politics, national security and the environment.

The final report was released in June 2011 and is available from MITEI.  See also this New York Times story.

Climate Change

Because natural gas can generate electricity with 50% less greenhouse gas (GHG) emissions than coal, the expanded use of natural gas could be a “game changer” for U.S. climate action.

Climate Change Legislation

Major cap-and-trade bills considered by Congress generally did not seek to leverage the potential of gas-fired electricity to reduce GHG emissions.  ACSF therefore proposed to award a tranche of emission allowances for GHG reductions based on fuel switching in the electricity sector, thereby accelerating overall emissions reductions.

For details about ACSF’s proposal, see this two-page summary.  Several examples of how capped entities would earn emission allowances for using natural gas can be found here.

Copenhagen Forum

ACSF, together with the Worldwatch Institute and the UN Foundation, brought the role of natural gas to the center of the landmark UN COP-15 climate negations in Copenhagen in December 2009.  ACSF and its co-sponsors hosted a major Side Event, and ACSF released a comprehensive working paper entitled “North America’s New Natural Gas Resources and their Potential Impact on Energy and Climate Security.”  In addition, ACSF and RPSEA (Research Partnership to Secure Energy for America) jointly released the following report “Worldwide Gas Shales and Unconventional Gas: A Status Report.”

ACSF’s Copenhagen event was also covered by the Sopris Foundation.  See the interview with CEO Gregory C. Staple.