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).
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.
To learn more, read: Leveraging Natural Gas to Reduce Greenhouse Gas Emissions, a report by the Center for Climate and Energy Solutions (C2ES). The report was supported, in part, by a grant from ACSF.
See also this oped by C2ES president Eileen Claussen and Tomas E. Farrell, Chairman and CEO of Dominion Resources. They say:
“America’s newly abundant natural gas supplies offer the opportunity to address two goals at once — increasing the amount of affordable, reliable energy powering the world economy, and making progress on reducing greenhouse gas emissions.”.
Potomac River Green
Potomac River Green is an innovative $450 million plan to transform the waterfront site of a coal-fired power plant in Alexandria, VA into an environmentally friendly, mixed-use community. This redevelopment concept is designed to provide a catalyst for a market-based solution to the plant’s retirement. Potomac River Green features extraordinary river access and open space amenities; includes hundreds of new riverfront housing units; greatly improves community connectivity to the city’s Old Town community; and, at the heart of the site, creates a world-class new energy center for the Washington region. Read the full report at the Potomac River Green website.
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.
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.
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.
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.
For more information, contact ACSF’s Geoff Bromaghim.
Some of our work on the future of the electricity sector is also reflected in “The Business Case for Integrating Clean Energy Resources to Replace Coal,” by Joel N. Swisher, Ph.D., PE, a senior consultant to ACSF. This presentation was delivered at the June 2013 Renewable Finance Forum Wall Street. (Download presentation, PDF)
Workshop I
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.
Workshop II
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.
Workshop III
The 3rd workshop in this series, held on April 19-20, 2012, was co-hosted at the National Renewable Energy Laboratory in Golden, Colorado with the Joint Institute for Strategic Energy Analysis.
Presentations
Paul Denholm, National Renewable Energy Laboratory, How PV and CSP with Thermal Storage Can Work Together
Craig Turchi, National Renewable Energy Laboratory, CSP and Natural Gas Hybrids
Easan Drury, National Renewable Energy Laboratory, U.S. PV Market Landscape
Russell Young, GE Energy, Concentrated Solar Power
Cara Libby, Electric Power Research Institute, Utility Perspective: Solar Thermal Hybrid Projects
Greg Brinkman, National Renewable Energy Laboratory, Impacts of Renewable Generation on Fossil Fuel Unit Cycling: Costs and Emissions
Paul Hibbard, Analysis Group, Variable Resources in Capacity Markets, Market Rule Adjustments and Balancing Resource Options
Christopher Carr, C2E2 Strategies, EPA Power Plant Regulations and Clean Energy: A New Paradigm?
Ron Binz, Public Policy Consulting, Progress Under the Clean Air Clean Jobs Act
Austin Whitman, M.J. Bradley & Associates, Energy Sector Modeling and Fuel Price Assumptions
Patrick Bean, American Clean Skies Foundation, Locking In the Benefits to Fuel Switching
David Hart, Center for Science and Technology Policy at George Mason University, Unlocking Energy Innovation
Workshop IV
The 4th workshop in this series was held on November 8-9, 2012, near the headquarters of the PJM Interconnection in Valley Forge, Pennsylvania.
Presentations
M. Gary Helm, PJM Interconnection, Coal Plant Retirements: Potential Impacts of Reduced Energy Demand, Low Natural Gas Prices and the Mercury & Air Toxics Standards Rule
Susan Covino, PJM Interconnection, Resource Adequacy Planning
Paul McGlynn, PJM Interconnection, PJM’s Compliance With FERC Order 1000
Allison Clements, The Sustainable FERC Project, Natural Resources Defense Council, FERC Priorities
Michael Goggin, American Wind Energy Association, Wind Integration and FERC
Ken Schuyler, PJM Interconnection, Paying for System Flexibility: Status of New Ancillary Services
Shucheng Liu, California ISO, System Flexibility for Integrating 33% Renewable Generation in California ISO
Nivad Navid, Midwest ISO, Managing Flexibility in MISO Markets
James T. Gallagher, New York ISO, Integrating Renewable and Variable Energy Resources in the New York Electricity Market
Jonathan Lowell, ISO New England, Paying for System Flexibility
Paul McGlynn, PJM Interconnection, Incorporating State Energy Policy Goals into Regional Electricity Market
Regulatory Filings
Federal Energy Regulatory Commission (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.
Environmental Protection Agency (EPA)
Transportation — Tailpipe Emission and Mileage Stardards
On August 28, 2012 ACSF and other alternative fuel champions won a significant victory when the Obama Administration decided to include both natural gas vehicle (NGV) and electric vehicle (EV) manufacturing incentives in groundbreaking new U.S. fuel economy and tailpipe emission standards. These new rules will cover tens of millions of cars and light-duty trucks produced for the 2017-2025 model years. The rules are designed to increase each manufacturer’s corporate average fuel economy (CAFE) to the equivalent of 54.5 mpg by 2025 and cut CO2 emissions by approximately 40 percent to 163 grams/mile.
Read the February 2012 filing (PDF)
Electric Power — Power Plant Rules
On January 7, 2013, ACSF submitted comments on EPA’s recent proposed rule that addresses, inter alia, the “Reconsideration of Certain New Source and Startup/Shutdown Issues: National Emissions Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units.”
On June 25, 2012, ACSF submitted comments to EPA to support their proposed standards for greenhouse gas emissions from new fossil fuel-fired power plants. The Foundation also suggested multiple approaches for EPA to strengthen the rule’s implementation.
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.
Department of Energy (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 January 30, 2012, ACSF filed comments on DOE’s forthcoming transmission congestion study and urged DOE to take into account future increases in gas-fired generation. ACSF noted that gas-fired units can be located close to load and, thus, can provide a key means of alleviating transmission constraints. Congress has directed DOE to conduct a study every three years on electric transmission congestion and constraints, and ACSF similarly advised DOE to better consider the role of natural gas in complementing renewables, and as a cleaner alternative to coal for their 2009 study.
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.
Oil Shift
Oil Shift
When it comes to reducing America’s oil dependency, we think the federal government should redouble its own efforts to shift away from imported fuel.
Energy security should start at every federal loading dock and overnight drop box. That’s the main message of our landmark 2012 Oil Shift report.
The report calls for alternative fuel and other petroleum reducing preferences for federal contractors providing high volume shipping and transportation services to the federal government. This could have very large multiplier benefits nationwide in reducing the trucking sector’s oil consumption and associated tailpipe emissions.
Our Oil Shift plan requires no new legislation and no new federal spending. Existing laws and executive orders give the Administration all the authority it needs to kick start a new generation of alternative fuel transportation services.
ACSF is currently working with the General Services Administration, Defense Logistics Agency and the U.S. Postal Service to implement its plan. See our recent letter to the GSA regarding the upcoming $1.5 billion government-wide small package delivery contract.