Category: Animal Rights & Environment

On December 27th, Ohio Governor John Kasich vetoed House Bill 554, a bill that would have effectively extended the freeze[…]

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By Mina Badtke-Berkow

The need to plan for and design a more efficient, cleaner, and resilient electricity grid has never been greater. Our aging grid is ill-prepared to keep pace with rapid technological advances and an increasingly distributed, dynamic energy system. A greater number of customers are producing electricity themselves, demanding expanded energy choice and a more interactive relationship with their utilities. In the meantime, an increased number of severe storms in recent years keep pressing the need for resilience. In order to meet these challenges, we need to look beyond traditional planning solutions for how we make, use, and distribute electricity.

This year has seen a flurry of activity on grid modernization in states across the U.S. As 2016 comes to a close, the spotlight is on Maryland as it joins the ranks of states investigating how to transform our electric system.

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How Maryland Tackles Grid Modernization Could Have Big Impact
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Environmental Defense Fund (EDF) recently noted that as President-elect Trump threatens to roll back federal environmental protections, state victories are more critical than ever. Regardless of future federal action, markets and technology are on our side: the U.S. is experiencing an unprecedented convergence of clean energy innovation and economic growth. As the Midwest has shown, states can work across the aisle to create policies that grow the economy and help people save money, while protecting the planet.

It’s still too early to gauge how bold Maryland’s foray into this grid modernization inquiry will be; the state’s Commission has made it clear this is a “targeted review” of specific topics – rate design, distributed energy resource valuation, smart meter benefits and costs, protection of low-income customers. But the scope of the topics suggests the state is thinking big. And if last week’s public hearing is any indication, key players are keeping an eye on the grid modernization newcomer.

The stakes

Maryland’s presence in the PJM Interconnection market (the largest wholesale electricity market in the U.S.) provides unique challenges to the state’s reform process and will have many states watching closely as it charts its own path.

Earlier this fall, Maryland’s Public Service Commission (PSC) requested comments on specific issues to kick off its grid modernization proceeding in an effort to “ensure that electric distribution systems in Maryland are customer-centered, affordable, reliable, and environmentally sustainable.”

The proceeding builds on two earlier technical conferences on rate design and distributed energy resources. It also reflects the 2015 approved merger of Exelon Corp. and Pepco Holdings LLC. The merger required the companies to file a plan for revamping the electricity distribution system. 

The proceeding has already drawn an impressive amount of attention ranging from utilities to system operators, to renewable energy companies, energy management service and technology providers, consumer advocates, and the environmental community. This signals the growing importance of, and action around, modernizing our outdated electric grid.

8 steps Maryland should consider

Bringing our outdated electric grid into the 21^st century is an enormous task that can take many shapes and forms, as indicated by the Grid Modernization Index.  Hardware upgrades can only takes us so far. Tomorrow’s grid requires modernizing processes as well because utilities, regulators, and customers need new policies to support this new system and “encourage innovation and reward performance.”

Leveraging EDF’s experience with grid modernization efforts across the country, we offered a set of guidelines for Maryland regulators to consider as they begin to orchestrate grid modernization efforts:

1. Create strong stakeholder engagement: Engage stakeholders to develop a shared understanding and pave the way for a comprehensive and transparent grid modernization process. Such collaboration can help ensure all the various decisions Maryland’s regulators make – potentially in separate forums (the Commission may decide rate design process and grid upgrades in separate proceedings for example) – work together.
2. Use guiding priorities and principles: Assess state-specific guiding principles and priorities at the outset to serve as a foundation on which the reform process can be built. Distributed energy penetration, like encouraging growth of rooftop solar, is a hot topic these days. Action plans will vary greatly depending on whether distributed energy integration is a pressing issue in the state and where these resources will provide the most value to the grid.
3. Develop solid rate design process: Good rate design process is just as important finding the right rate design. Carefully consider the pace of adoption, and apply data to use the opportunity to investigate, learn, and probe changes against policy goals.
4. Value distributed energy resources with data: Utilize granular data to indicate when and where energy generation is most beneficial to the grid and the environment. This is essential to ensuring the societal benefits of distributed energy resources like solar are maximized.
5. Ensure data access: Simply deploying smart technology does not equal value maximization. In order to unlock smart meter benefits, regulators, utilities, and energy service providers need to design and implement policies that deliver secure access to meaningful energy usage data to customers and authorized third-parties.
6. Engage customers: Craft a broad customer engagement strategy that incorporates proactive customer education and outreach efforts; periodic customer surveys to gauge satisfaction; and awareness of benefits before, during, and after the roll out of smart grid technologies.
7. Deploy voltage optimization: Voltage optimization is a cost-effective energy technology that represents a unique ability to more efficiently operate the grid by ensuring customers receive only the amount of voltage they need to power their homes and appliances. Additionally, it helps customers save energy and money while reducing pollution. Evaluate its capabilities and how smart meters can enhance this tool.
8. Employ performance metrics: Using metrics to assess and incent utility investments, in a way that is transparent to all stakeholders, is key to defining and measuring outcomes. These measurable outcomes will be foundational to achieving desired policy objectives.

While it is too early to tell how successful Maryland will be in developing its own grid modernization roadmap that other states can follow, it is clear that states are exploring ways to build a smarter and more sustainable energy future. Here at EDF, along with the other interested parties, we will be watching Maryland regulators in hopes they move forward ambitiously to modernize the grid and become leaders in the process. In doing so, they would be doing their part to create a more flexible, efficient grid that is responsive to diverse customer needs, while protecting our communities.

Photo credit: joseph.gruber

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By EDF Blogs

By Jon Goldstein and Peter Zalzal

The legal fight to defend the Bureau of Land Management’s (BLM) recent efforts to prevent oil and gas companies from wasting methane on public and tribal owned land continued yesterday.

EDF and a coalition of local, regional, tribal and national allies filed a brief opposing efforts by industry organizations and a handful states to block BLM’s protections before they even come into effect. 

The states of New Mexico and California also sought to participate in the legal challenges, likewise stepping up to defend BLM’s common sense standards. Notably, New Mexico is the largest producer of oil from public lands in the U.S. and the second largest producer of natural gas.

In seeking to stay BLM’s protections, the industry associations have claimed the standards have no benefits – so blocking them won’t have any impacts on the communities they are designed to protect.

But BLM’s oil and gas waste standards are about ensuring that operators use common sense technologies to capture natural gas that would otherwise be wasted. That preserves a valuable natural resource and cleans up the air, all while putting additional royalty payments in the pockets of Western communities that can be used to fund schools, roads and important infrastructure.

For example, a recent analysis found that in 2013, oil and gas companies operating on public and tribal lands wasted more than $330 million worth of gas – more than $100 million of that from New Mexico alone. This translates to lost royalty revenues for local communities. One report estimates that without action to reduce this waste, taxpayers could lose out on more than $800 million in royalties over the next decade.

The challengers’ legal claims stand in stark contrast to the facts on the ground. Evidence of the broad-based benefits of BLM’s Waste Prevention Rule was readily apparent in yesterday’s court filings supporting the protections..  Current and former state and county officials and everyday Westerners alike let their voices be heard about the importance of common sense measures to preserve public resources and protect the environment.

For example, in their filing seeking to participate in the case, the states of New Mexico and California emphasized:

“Implementation of the Rule will benefit the States of California and New Mexico by generating more annual royalty revenue . . . . In addition, the Rule will benefit the health of the states’ citizens who are exposed to harmful air contaminants leaked, vented and flared from federally-managed oil and gas operations . . . . The People of California and New Mexico have a strong interest in preventing the waste of public resources, as well as in reducing the emission of harmful air pollutants that threaten the health of the states’ citizens, the integrity of their infrastructure, protection of their unique environments and ecosystems, and the continued viability of their economies.” ( Filing, pages 2 and 3)

And in their filing opposing the preliminary injunction, these states claimed:

“Because the Rule is likely to result in the stronger protection of federal lands and greater prevention of the waste of natural resources, which belong to the People, the public interest weighs strongly in favor of denying the injunction.” (Filing, page 16)

The benefits that New Mexico and California identified are broadly shared and were likewise reflected in declarations submitted by county officials and former state officials in support of the standards.

Current La Plata County Colorado Commissioner Gwen Lachelt identified both the problem of resource waste on public lands and the benefits for Western counties like hers in addressing it:

“The San Juan Basin, in which La Plata County is situated, has one of the highest rates of wasted gas and methane loss in the country, accounting for nearly 17% of U.S. methane losses.

“In addition to wasted methane, oil and gas sites in La Plata County and the San Juan Basin release dangerous pollutants such as benzene and ozone-forming pollutants that can lead to asthma attacks and worsen emphysema . . . . This air pollution continues to be a regional public health hazard, and has contributed to La Plata County receiving a low grade for poor ozone air quality from the American Lung Association…

“The Rule will benefit La Plata County by providing additional royalties that we can use to fund key County priorities—including infrastructure, roads, and education—while also helping to clean up the air in the San Juan Basin, which will have health benefits for our citizens.” (Filing, page 4 and 5)

Lachelt points out that unlike other leading oil and gas states like Colorado, New Mexico has no policies to reduce methane waste and other pollution from oil and gas wells, and that BLM’s efforts will help to provide uniformity across state lines.

Sandra Ely, a former Chief of the New Mexico Environment Department’s Air Quality Bureau likewise submitted a declaration describing the importance and benefits of the BLM standards. She particularly focused on the long-standing problem of resource loss in the San Juan Basin. The region made headlines in recent years when NASA scientists discovered a 200-square-mile methane cloud over the region – the largest methane cloud uncovered in the U.S. Subsequent studies determined that oil and gas emissions were the main contributor to the methane “hot spot.”

“I am aware of a recent study, focused on the San Juan Basin, which suggested that BLM’s proposed leak detection and repair requirements alone would result in anywhere from $1–$6 million dollars of additional revenue for New Mexico… Absent the Waste Prevention Rule, I am concerned that resource loss and poor air quality associated with oil and gas development will continue unabated in New Mexico” (Sandra Ely, Filing, page 7)

Western leaders have been vocal in their support for BLM’s sensible standards that take an important energy resource out of the air and deliver it responsibly to the American public. At public hearings that the BLM held across the west these rules were supported by more than 3 to 1 margins. More than 80 local officials across the West, including county commissions in La Plata, Park and San Miguel counties in Colorado and Bernalillo, Rio Arriba and San Miguel counties and the Santa Fe city council in New Mexico, all support the protections. And these rules enjoy broad bipartisan public support as well (more than 80 percent of Westerners in a recent poll).

Given this cross-cutting support and yesterday’s forceful legal filings, it’s no wonder that industry challengers in this case don’t even want the judge to hear the views of New Mexicans and Californians. Yesterday, they indicated that they would oppose these states’ efforts to protect the interests of their citizens by participating in the case. While this reflexive obstructionism isn’t surprising—industry petitioners filed their legal challenges within 40 minutes of the rule being finalized and tried to block the standards’ effectiveness shortly thereafter—it certainly reveals their very one-sided view of what is in the public’s interest.

The Wyoming Court is scheduled to hear oral argument in this case on January 6. We look forward to continuing to defend these standards that will clean the air and prevent waste.

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By Nicholas Bianco

By Pam Kiely and Nicholas Bianco

Earlier today the U.S. Environmental Protection Agency (EPA) released several draft  documents designed to provide additional information for states and other stakeholders as they work together to reduce emissions of carbon pollution from power plants.

EPA notes that making these working drafts available:

[A]llows us to share our work to date and to respond to the states that have requested information prior to the end of the Administration.

The materials provide valuable insights that can be used by states currently implementing or considering developing their own programs for reducing carbon pollution, and can be leveraged as states evaluate ongoing state policy efforts to achieve pollution reductions under the Clean Power Plan.

The Clean Power Plan establishes America’s first ever limits on carbon pollution from power plants. Once implemented, it will provide essential protections for public health and the environment – saving up to 3,600 lives each year and delivering up to $54 billion in annual climate and health benefits – while also reducing electricity bills for American families.

These documents reflect extensive public input and engagement as well as decades of practical experience reducing air pollution at the state and federal level. They provide constructive information in response to direct requests for this type of material made by states who are interested in having the best information available as they undertake their own planning, public engagement, and regulatory initiatives.

A letter submitted to EPA by 14 states  requested “additional information and assistance” to help states “prudently plan for and implement a variety of state and federal obligations” because many states, as well as their stakeholders, understand that continuing to navigate the dynamic transition underway today in the power sector requires comprehensively evaluating and integrating state policy priorities with their best understanding of existing and future federal policy.

While the Supreme Court has stayed enforcement of the Clean Power Plan, EPA’s provision of helpful information in response to this letter is entirely consistent with actions taken by past Republican and Democratic Administrations to provide clarification and information on Clean Air Act rules that had been stayed by the courts.

States such as Pennsylvania and Colorado have recently underscored their commitment to continuing state-driven efforts to address climate change and greenhouse gas emissions, while more than a dozen power companies have continued to affirm that the transition to cleaner energy resources and progress toward de-carbonization of the electric sector is ongoing.

State officials and many companies keenly understand that prudent evaluation of the federal policy landscape, and ongoing deployment of no-regrets strategies and investments that well-position them to meet declining limits on carbon pollution, make sense. Additional information about options for Clean Power Plan implementation will only facilitate sensible alignment of state efforts already underway.

EPA released four draft documents today:

1. Draft state models to help policymakers and regulators develop state-specific strategies to realize the benefits and achieve the emissions reduction targets in the Clean Power Plan. The draft models outline two highly flexible approaches for reducing carbon pollution in a cost-effective manner. By providing these models, EPA is helping to facilitate state innovation and the realization of pollution reductions aligned with state policies and prerogatives. These models provide greater clarity about practical implementation considerations so that states have the best information available about cost-effective opportunities to reduce climate pollution as they move ahead navigating, and helping to facilitate, the transition underway in the power sector.
2. Draft EM&V Guidance for Demand-Side Energy Efficiency. EPA published draft guidance that states can use if they decide to implement demand-side energy efficiency projects. This guidance details methods for ensuring that project developers deliver high quality projects by providing options for monitoring and verification procedures that states can adopt if they are interested. Such support is extremely valuable, particularly when one considers that energy efficiency projects routinely deliver $2 in savings for Americans for every $1 invested, and in some cases up to $5 for every $1 invested.
3. Draft Clean Power Plan Tracking Systems White Paper. EPA released draft materials designed to further assist states by providing information about how a tracking system could be designed to facilitate administration of the program. In so doing, EPA further demonstrates the relative ease with which a state can administer a flexible, cost-effective program to achieve carbon pollution reductions.
4. Draft Technical Support Document: Leakage Requirement. If choosing to adopt a mass-based emission budget trading program instead of other program alternatives, this document  provides valuable information for addressing emissions leakage and securing the emissions reductions contemplated by the Best System of Emission Reduction. In addition to the streamlined approach for leakage mitigation that EPA finalized in the Clean Power Plan (using larger state budgets with the “new source complement” and including all fossil sources in the program), the working draft helpfully outlines a set of sample strategies that states could potentially use to guarantee the expected emissions outcome of their program, depending on particular state circumstances. The draft document notes the expectation that any strategy will include a process for performing periodic evaluations and look-backs that states and EPA could use to ensure the effectiveness of those measures. It also discusses the value of establishing mechanisms to address any shortcomings in performance. Together these measures underscore the importance of continuing to ensure on an ongoing basis that state program design secures the expected level of emissions reductions, and highlights the many options available to do so.

These draft materials build on decades of experience that EPA and states have in successfully implementing flexible compliance programs to reduce air pollution and drive innovation, and they show how these approaches can be applied for the Clean Power Plan. These same flexible frameworks have been used to reduce emissions under other Clean Air Act standards at a fraction of the cost that opposing parties have claimed –  and there is strong evidence that this will hold true for the Clean Power Plan as well (for examples see here, here, and here).

Climate pollution from the electricity sector has already fallen 21 percent below 2005 levels – which means America is already almost two-thirds of the way towards the 2030 Clean Power Plan emission targets. Emissions reductions and clean energy investments are widespread across states and power companies – even those that may be opposed to the Clean Power Plan itself. Analysis conducted for EDF by M.J. Bradley & Associates found that all 27 litigating states can comply with the Clean Power Plan just by leveraging already planned investments coupled with flexible compliance programs. Many of the power companies litigating against the Clean Power Plan are also well positioned to reach their targets, thanks to the increasingly low cost of lower- and zero-carbon generation.

While this progress is encouraging, the analyses also show that the Clean Power Plan has an essential role to play in ensuring that reasonable protections from climate pollution are realized. With the release of today’s draft documents, EPA is responding to the request by states, power companies, and other stakeholders to share lessons learned for flexible cost-effective implementation of the Clean Power Plan. These insights will prove to be valuable to states at all stages of planning for a low-carbon future.

 

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