The Report Card for America’s Infrastructure, released by the American Society for Civil Engineer’s (ASCE), revealed failing grades for much of the system that consists of the roads, bridges, ports and the energy infrastructure. The infrastructure, that is made up of the power generation plants and the electrical transmission and distribution systems, brought home a D+ on its report card. The US power grid, that is the entire combination of these elements, is in dire need of upgrades and rebuilding.
Suffering through a lengthy power outage will make any person aware of the importance of the grid and how it can have a devastating, negative, economic impact when rendered inoperable. The aging system becomes more compromised due to increased demand and reliance by consumers. Power outage occurrences of significant proportion increased dramatically from 76 in 2007 to 307 in 2011. Operational failures were not far behind weather related failures as the cause. The introduction of new energy sources, while retiring older ones, has also strained the reliability.
Hurricane Sandy alone cost the economy $30 billion to $50 billion in economic loss. Service interruptions are expected to be near $200 billion per year if investments in the system are inadequate. The ASCE puts the required investment figure at a minimum of $1 billion, which is an apparently small price in comparison. In addition these costs are being passed on to the consumer, even though the actual cost of power has decreased, as reported in a recent article in Power Engineering Magazine.
There are many hurdles and obstacles, even where improvement agreements have been reached. Red tape is threatening progress in many areas. Simply creating new energy sources, combined with the rapid expansion of natural gas production, will not have much of a positive effect on the overall electrical transmission system if there are little or no improvements to the infrastructure.
Fortunately there are some potential heroes that are poised to enter the arena. Private financing is used for electrical transmission upgrades, unlike other forms of infrastructure that relies on funding through government. Investments in the grid system are always focused where required and can have a positive affect in a relatively short time. This is accomplished through targeted investment in competitive markets that reduce the cost of electrical transmission delivered to the consumer. As Sandy had a negative impact on the economy, investing in the nation’s energy infrastructure can have long term, positive results. Improving the grid with the necessary investments would prevent the loss of $656 billion in personal income losses, save over 500 thousand jobs and retain over $500 billion in GDP that would be otherwise lost.
Government is still required to keep us on the right path. Even though funding is primarily private, policies must be in place that are long term and are geared to advance economic growth. Our electric grid is the single most important system that keeps our economy motivated and moving forward. Bringing it up to modern standards of security and efficiency are paramount to our national overall growth. (Power Engineering, 3/6/2013)
The Center, founded in 1985, is an environmental organization dedicated to protecting the environment, enhancing human, animal and plant ecologies, promoting the efficient use of natural resources and expanding participation in the environmental movement.
Tuesday, April 30, 2013
Monday, April 29, 2013
Federal Register Notice On Request To Restart San Onofre
San Onofre Nuclear Generating Station |
[Federal Register Volume 78, Number 73 (Tuesday, April 16, 2013)]
NUCLEAR REGULATORY COMMISSION
[Docket No. 50-361; NRC-2013-0070]
Application and Amendment to Facility Operating License Involving Proposed No Significant Hazards Consideration Determination; San Onofre Nuclear Generating Station, Unit 2
AGENCY: Nuclear Regulatory Commission.
ACTION: License amendment request; opportunity to comment, request a hearing, and petition for leave to intervene.
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is considering issuance of an amendment to Facility Operating License No. NPF-10, issued to Southern California Edison (SCE, the licensee), for operation of the San Onofre Nuclear Generating Station (SONGS), Unit 2. The
proposed amendment makes a temporary change to the steam generator management program and the license condition for maximum power. For the duration of Unit 2, Cycle 17, the proposed amendment would change the terms ``full range of normal operating conditions'' and ``normal steady state full power operation'' and restricts operation to 70 percent of the maximum authorized power level. ``Full range of normal operating conditions'' and ``normal steady state full power operation'' shall be based upon the steam generators being operated under conditions associated with reactor core power levels up to 70 percent Rated Thermal Power (2406.6 megawatts thermal).
DATES: Submit comments by May 16, 2013. Requests for a hearing or petition for leave to intervene must be filed by June 17, 2013.
ADDRESSES: You may submit comments by any of the following methods (unless this document describes a different method for submitting comments on a specific subject):
Saturday, April 27, 2013
EPA Critical of Bristol Bay Pebble Mine
The U.S. Environmental Protection Agency's (EPA) revised draft assessment of the Pebble Mine project’s potential impact on the aquatic ecosystem in Bristol Bay, Alaska determined the mine would destroy 90 miles of streams and up to 4,800 acres of wetland salmon habitat.
“Indirect effects of stream and wetland losses would include reductions in the quality of downstream habitat for coho salmon, sockeye salmon, Chinook salmon, rainbow trout, and Dolly Varden trout. These indirect effects cannot be quantified, but likely would diminish fish production downstream of the mine site,” the EPA said in its summary of the report.
If it gets developed, the southwestern Alaska copper and gold mine would be one of the world's largest. The mine is controversial in both in Washington, D.C., and Alaska, where it pits supporters of the state’s vast mineral resources against conservationists and an established commercial fishing industry.
The draft assessment now enters a public comment period that ends May 31. The EPA will review those comments before it finalizes the study, which will be used to inform the agency on whether to issue a permit needed to construct the mine.
Industry groups have said the EPA is overstepping its authority by conducting environmental reviews before mine builders Anglo American and Northern Dynasty have submitted a formal blueprint.
The builders, who teamed up as the Pebble Partnership, said Friday that EPA "has not changed its deeply flawed approach" for the review. They, along with industry groups, worry the EPA’s evaluation means it may render a “preemptive” veto of the required permit based on hypothetical parameters for the mine. A preemptive veto, they say, could cool investment near waterways.
Pebble Mine’s opponents — which include commercial fishermen, native tribes and environmentalists — say the EPA has plenty of information to conduct a valid environmental assessment. Opponents say a mine of that size would conflict with Bristol Bay’s sockeye salmon population, which accounts for a little less than half of the world’s total.
The EPA affirmed that in its draft assessment, saying the mine would inhibit salmon reproduction and negatively impact salmon habitat.
Pebble Partnership estimates its proposed mine would yield 80.6 billion tons of copper, 107.4 million ounces of gold and 5.6 billion pounds of molybdenum, which is used in alloys.
If it gets developed, the southwestern Alaska copper and gold mine would be one of the world's largest. The mine is controversial in both in Washington, D.C., and Alaska, where it pits supporters of the state’s vast mineral resources against conservationists and an established commercial fishing industry.
The draft assessment now enters a public comment period that ends May 31. The EPA will review those comments before it finalizes the study, which will be used to inform the agency on whether to issue a permit needed to construct the mine.
Industry groups have said the EPA is overstepping its authority by conducting environmental reviews before mine builders Anglo American and Northern Dynasty have submitted a formal blueprint.
The builders, who teamed up as the Pebble Partnership, said Friday that EPA "has not changed its deeply flawed approach" for the review. They, along with industry groups, worry the EPA’s evaluation means it may render a “preemptive” veto of the required permit based on hypothetical parameters for the mine. A preemptive veto, they say, could cool investment near waterways.
Pebble Mine’s opponents — which include commercial fishermen, native tribes and environmentalists — say the EPA has plenty of information to conduct a valid environmental assessment. Opponents say a mine of that size would conflict with Bristol Bay’s sockeye salmon population, which accounts for a little less than half of the world’s total.
The EPA affirmed that in its draft assessment, saying the mine would inhibit salmon reproduction and negatively impact salmon habitat.
Pebble Partnership estimates its proposed mine would yield 80.6 billion tons of copper, 107.4 million ounces of gold and 5.6 billion pounds of molybdenum, which is used in alloys.
EPA's revised version of the Bristol Bay Assessment is now available for peer review follow-up and public comment until May 31, 2013. The revised assessment reflects feedback from the initial peer review report and 233,000 public comments EPA received when it released the original assessment.
Key changes to the assessment include: Refinement and better explanation of the mine scenarios assessed, including the role in developing these scenarios of worldwide industry standards for porphyry copper mining and specific preliminary mine plans submitted to state and federal agencies related to the Pebble Mine Project.
- Incorporation of modern conventional mining practices into mine scenarios and clarification that some of the projected impacts assume that those practices are in place and working properly.
- Addition of an appendix describing methods to compensate for impacts to wetlands, streams and fish.
- Reorganization of the assessment to better reflect the ecological risk assessment approach and to clarify the purpose and scope.
- Additional details about projected water loss and water quality impacts on stream reaches, drainage of waste rock leachate to streams, and mine site water balance to assessment of potential mine impacts.
EPA released the draft Bristol Bay Assessment on May 18, 2012. The agency held a series of public meetings concurrent with the release and received feedback from 12 independent expert peer reviewers. In February 2011, in response to growing interest in large-scale mining in the watershed from a number of stakeholders and local communities with a range of views, EPA launched the Bristol Bay assessment to gain a better understanding of the watershed and the potential impacts of large-scale mining in the area. (EPA, The Hill, 4/26/2013)
Wednesday, April 24, 2013
EPA Critiques State Department EIS on Keystone XL Pipeline
WASHINGTON. DC
APR 22, 2013
ASSISTANT ADMINISTRATOR FOR ENFORCEMENT AND COMPLIANCE ASSURANCE
Mr. Jose W. Fernandez
Assistant Secretary Economic, Energy and Business Affairs
U.S. Department of State
Washington, DC 20520
Dr. Kerri-Arm Jones
Assistant Secretary Oceans and International Environmental and Scientific Affairs
U.S. Department of State
Washington, DC 20520
Dear Mr. Fernandez and Dr. Jones:
In accordance with our authorities under the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act, EPA has reviewed the Department of State's draft Supplemental Environmental Impact Statement (DSEIS) for a Presidential Permit application by TransCanada Keystone Pipeline, LP (TransCanada) to construct and operate the Keystone XL Project (Project). This DSEIS builds on the Department of State's August 201 1 Final EIS, and includes information regarding a new proposed route in Nebraska.
NEPA serves an important role in the decision making process for federal actions that may have environmental effects. Through the NEPA process, federal agencies disclose and analyze the potential impacts ofa proposed action and reasonable alternatives, as well as measures that could mitigate any potential harmful effects. NEPA brings transparency to the federal decision making process, requiring that other federal, state, tribal and local agencies, as well as citizens, are given a meaningful opportunity to provide comments, helping to ensure federal decisions are better informed.
EPA believes this DSEIS strengthens the analysis presented to date in the NEPA process. While we appreciate this effort, we also have several recommendations for improving the analysis and considering additional mitigation as you move forward to complete the NEPA process.
Greenhouse Gas Emissions
We commend the Department of State's efforts to estimate the lifecycle greenhouse gas (GHG) emissions associated with oil sands development and the proposed Project, to analyze the effect ofthe Project on Canadian oil sands production and to ,consider measures to reduce GHG emissions. As recognized by the DSEIS, oil sands erude is significantly more GHG intensive than other crudes, and therefore has potentially large climate impacts. The DSEIS reports that lifecycle GHG emissions from oil sands crude could be 81% greater than emissions from the average crude refmed in the U.S. in 2005 on a well-to-tank basis, and 17% greater on a well-to-wheels basis.
The market analysis and the conclusion that oil sands crude will find a way to market: with or without the Project is the central finding that supports the DSEIS's conclusions regarding the Project's potential GHG emissions impacts. Because the market analysis is so central to this key conclusion, we think it is important that it be as complete and accurate as possible. We note that the discussion in the DSEIS regarding energy markets, while informative, is not based on an updated energy-economic modeling effort. The DSEIS includes a discussion of rail logistics and the potential growth ofrail as a transport option, however we recommend that the Final EIS provide a more careful review ofthe market analysis and rail transport options. This analysis should include further investigation ofrail capacity and costs, recognizing the potential for mu,ch higher per barrel rail shipment costs than presented in the DSEIS. This analysis should consider how the level and pace of oil sands crude production might be affected by higher transportation costs and the potential for congestion impacts to slow rail transport of crude.
In its discussion of practicable options for mitigating GHG emissions, the DSEIS outlines ongoing efforts by the government ofAlberta to reduce the GHG emissions associated with development ofoil sands crude in Alberta. EPA recommends that the Final EIS complement this discussion with an exploration ofspecific ways that the U.S. might work with Canada to promote further efforts to reduce GHG emissions associated with the production ofoil sands crude, including a joint focus on carbon capture and storage projects and research, as well as ways to improve energy efficiency associated with extraction technologies. With regard to the estimated GHG emissions from construction and operation of the proposed Project -primarily emissions associated with electrical generation for the pumping stations -we recommend that the Department of State explore specific commitments that TransCanada might make to implement the mitigation measures recommended in the DSEIS. This would complement the significant efforts already made to reduce the risk ofspills and ensure community safety. Specifically, we recommend a focus on pumping station energy efficiency and use of renewable energy, as well as investment in other carbon mitigation options.
Pipeline Safety
We have learned from the 2010 En bridge spill of oil sands crude in Michigan that spills of diluted bitumen (dilbit) may require different response actions or equipment from response actions for conventional oil spills. These spills can also have different impacts than spills ofconventional oil. We recommend that these differences be more fully adldressed in the Final EIS, especially as they relate to the fate and transport ofthe oil and the remediation that will be required. The Enbridge spill involved a 30-inch diameter pipeline, smaller than the 36-inch diameter pipeline for proposed Project, and 20,000 barrels ofoil sands crude were released. In that spill, oil sands crude sank to the bottom of the Kalamazoo River, mixing with the river bottom's sediment and organic matter, making the oil difficult to find and recover. After almost three years of recovery >efforts, EPA recently determined that dredging of bottom sediments will be required to protect public health and welfare and the environment. This determination was based in large part on demonstrations that the oil sands crude associated with the Enbridge spill will not appreciably biodegrade.
We recommend that the Final EIS more clearly acknowledge that in the event of a spill to water, it is possible that large portions of dilbit will sink and that submerged oil significantly changes spill response and impacts. We also re·commend that the Final EIS include means to address the additional risks of releases that may be greater for spills of dilbit than other crudes. For example, in the Enbridge spill, the local health department issued voluntary evacuation notices based on the level ofbenzene measured in the air. Given these concerns, it is important to ensure that the future response and remediation plans will protect communities from impacts due to spills.
The DSEIS also outlines specific measures that the Department of State would require: TransCanada to undertake to prevent and detect oil discharges. The measures include commissioning an independent engineering analysis to review TransCanada's risk assessment ofthe potential impacts from oil discharges to surface and groundwater resources, as well as TransCanada's current proposals for placing mainline valves along the pipeline route and installing leak detection equipment. The DSEIS also notes that the Department ofState will obtain concurrence from both EPA and PHMSA on both the scope ofthe engineering analysis and decisions regarding the need for any additional mitigation measures. We recommend that the Department ofState provide an opportunity for public review and comment on the scope of the analysis, and opportunity for public comment on a draft ofthe analysis when it is completed. We also recommend that the Final ElS consider requiring TransCanada to establish a network of sentinel or monitoring wells along the length ofthe pipeline, especially in sensitive or ecologically important areas, as well as where water supply wells are located and at stream crossings to provide a practical means for early detection of leaks that are below the proposed detection limit.
In addition to prevention measures, we agree with the DSEIS's suggestion that additio1nal mitigation measures regarding preparedness to reduce the impacts ofa spill may be appropriate (DSEIS, p. 4.13-79). For example, we recommend including the following measures as permit conditions:Requiring that the emergency response plan, as well as contingency plans address submerged oil, as well as floating oil, including in a cold weather response;
Requiring pre-positioned response assets, including equipment that can address submerged oil;
Requiring spill drills and exercises that include strategies and equipment deployment to address floating and submerged oil; and
Requiring that emergency response and oil spill response plans be reviewed by EPA.
The DSEIS also recognizes that dissolved components of the dilbit that may be transp.:>rted through the pipeline, such as benzene, polycyclic aromatic hydrocarbons (P AHs), and heavy metals, could be slowly released back to the water column for many years after a release and could cause long-term chronic toxicological impacts to organisms in both the benthic and pelagic portions ofthe aquatic environment. We recommend that the Final EIS more clearly recognize that this characteristic ofdilbit is different from the fate and transport ofoil contaminants associated with conventional crude oil and refined product spills from pipelines. For that reason we recommend that as a permit condition TransCanada be required to develop a plan for long tenn sampling/monitoring in the event ofan oil discharge to assess and monitor these impacts as part ofthe spill response plan. In addition, we recommend that the permit require TransCanada to provide detailed Material Safety Data Sheets and information about the diluent: and the source crude oil to support response preparations and address safety concerns in advance ofany spills.
Alternative Pipeline Routes
CEQ regulations implementing NEPA require the consideration of project alternatives The DSEIS has been significantly improved by considering more alternative routes, including an alternative that would avoid crossing the Sand Hills Region in Nebraska, reducing impacts to this fragile ecosystem. Another significant issue in the consideration ofalternative routes for this Project has been the potential for impacts to the Ogallala Aquifer in the event ofa spill. The alternative route in Nebraska has avoided most ofthe impacts to the Sand Hills Region, but still crosses the Ogallala Aquifer. The alternative laid out in the DSEIS that would avoid the Ogallala Aquifer is the I-90 Corridor Alternative, which largely follows the path of existing pipelines. The I-90 Corridor Alternative would significantly reduce the length ofpipeline crossing the Northern High Plains Aquifer system, which includes the Ogallala formation, and would further reduce the pot1ential for adverse impacts to critical groundwater resources.
We are concerned, however, that the DSE1S does not provide a detailed analysis ofthe Keystone Corridor Alternative routes, which would parallel the existing Keystone Pipeline and likely further reduce potential environmental impacts to groundwater resources. By determining that these routes are not reasonable, the DSEIS does not provide an analysis oftheir potential impacts sufficient to enable a meaningful comparison to the proposed route and other alternatives. The Keystone Corridor Alternatives were determined not to be reasonable alternatives primarily on the basis that these routes are longer than the proposed Project's route, and that additional pipeline miles would be needed to connect to Bakken Market Link project, which would allow the proposed Project to also transport crude from North Dakota and Montana. As we have indicated in the past, we believe these alternative routes could further reduce risks to groundwater resources. We recommend that the Final EIS either provide more detailed information as to why these alternatives were not considered reasonable or analyze these alternatives in more detail.
Community and Environmental Justice Impacts
The DSEIS provides a comprehensive analysis of community demographics, including minority, low-income, and tribal populations, along TransCanada's proposed pipeline route. We are especially appreciative ofthe effort to identify and contact each of the Local Emergency Planning Committees regarding the status oftheir emergency response plans, and to provide that information in the OSEIS. We also commend your recognition that environmental justice communities may be more vulnerable to health impacts from a spill, and appreciate your efforts to consider communities' access to health care, including consideration of "Health Professional Shortage Areas and Medically Underserved Areas" located along the proposed pipeline route.
EPA appreciates TransCanada's commitment to conduct cleanup and restoration and to provide alternative water supplies to affected communities in the event ofan oil discharge affecting not only surface waters, but also groundwater. We recommend that these commitments be clearly documented as proposed permit conditions. We believe this would give important assurances to potentially affected communities of TransCanada's responsibilities in the event of an oil discharge that affects either surface or groundwater resources.
Conclusion
Based on our review, we have rated the DSEIS as E0-2 ("Environmental Objections-Insufficient Information") (see enclosed "Summary ofRating Defmitions and Follow-up Actions"). We look forward to continuing to work with you and to provide assistance as you prepare the Final EIS. We also look forward to working with you as you determine whether approving the proposed project serves the national interest under Executive Order 13337 "Issuance of Permits With Respect to Certain Energy-Related Facilities and Land Transportation Crossings on the International Boundaries of the United States".
Please feel free to contact me or have your staff contact Susan Bromm, Director, Office ofFederal Activities, at (202) 564-5400 if you have any questions or would like to discuss our comments.
Sincerely,
Cynthia Giles
Summary of Rating Definitions and Follow-up Action
Environme:ntal Impact of the Action
LO--Lack of Objections. The EPA r.eview has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application ofmitigation measures that could be accomplished with no more than minor changes to the proposal.
EC~Environmental. The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application ofmitigation measures tlhat can reduce the environmental impact. EPA would like to work with the lead agency to reduce these impacts.
EO--Envil'onmental Objections. The EPA r.eyiew has identified significant environmental impacts that must be avoided in order to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration ofsome other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.
EU--Envir'onmentally Unsatisfactory. The EPA r·eview has identified adverse environmental impacts that are ofsufficient magnirude that they are unsatisfact•Oi)' from the standpoint ofpublic health or welfare or environmental quality. EPA intends to work with the lead agency to reduce these impacts. If the potentially unsatisfactory impacts are not corrected at the fin11l EIS stage, this !Proposal will be recommended for referral to the CEQ.
Adequacy of the Impact Statement
Category 1--Adequate. EPA believes the draft ETS adequately sets forth the environmental impact(s) ofthe preferred alternative and those ofthe alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition ofclarifying language or information.
Category 2--lnsufficient Information. The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternative: that are within tbe spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts ofthe action. The EPA reviewer identified additional information, data, analyses, or discussion should be included in the final EIS. Category 3--Inadequate. EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts ofthe action, or the EPA reviewer has identified reasonably available alternatives that are outside ofthe spectrum of alternatives analyzed in the draft ElS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EfS is adequate fN the purposes ofthe NEPA and/or Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft E1S. On the basis ofthe potential significant impacts involved, this proposal could be a candidate for referral to the CEQ. (EPA)
APR 22, 2013
ASSISTANT ADMINISTRATOR FOR ENFORCEMENT AND COMPLIANCE ASSURANCE
Mr. Jose W. Fernandez
Assistant Secretary Economic, Energy and Business Affairs
U.S. Department of State
Washington, DC 20520
Dr. Kerri-Arm Jones
Assistant Secretary Oceans and International Environmental and Scientific Affairs
U.S. Department of State
Washington, DC 20520
Dear Mr. Fernandez and Dr. Jones:
In accordance with our authorities under the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act, EPA has reviewed the Department of State's draft Supplemental Environmental Impact Statement (DSEIS) for a Presidential Permit application by TransCanada Keystone Pipeline, LP (TransCanada) to construct and operate the Keystone XL Project (Project). This DSEIS builds on the Department of State's August 201 1 Final EIS, and includes information regarding a new proposed route in Nebraska.
NEPA serves an important role in the decision making process for federal actions that may have environmental effects. Through the NEPA process, federal agencies disclose and analyze the potential impacts ofa proposed action and reasonable alternatives, as well as measures that could mitigate any potential harmful effects. NEPA brings transparency to the federal decision making process, requiring that other federal, state, tribal and local agencies, as well as citizens, are given a meaningful opportunity to provide comments, helping to ensure federal decisions are better informed.
EPA believes this DSEIS strengthens the analysis presented to date in the NEPA process. While we appreciate this effort, we also have several recommendations for improving the analysis and considering additional mitigation as you move forward to complete the NEPA process.
Greenhouse Gas Emissions
We commend the Department of State's efforts to estimate the lifecycle greenhouse gas (GHG) emissions associated with oil sands development and the proposed Project, to analyze the effect ofthe Project on Canadian oil sands production and to ,consider measures to reduce GHG emissions. As recognized by the DSEIS, oil sands erude is significantly more GHG intensive than other crudes, and therefore has potentially large climate impacts. The DSEIS reports that lifecycle GHG emissions from oil sands crude could be 81% greater than emissions from the average crude refmed in the U.S. in 2005 on a well-to-tank basis, and 17% greater on a well-to-wheels basis.
The market analysis and the conclusion that oil sands crude will find a way to market: with or without the Project is the central finding that supports the DSEIS's conclusions regarding the Project's potential GHG emissions impacts. Because the market analysis is so central to this key conclusion, we think it is important that it be as complete and accurate as possible. We note that the discussion in the DSEIS regarding energy markets, while informative, is not based on an updated energy-economic modeling effort. The DSEIS includes a discussion of rail logistics and the potential growth ofrail as a transport option, however we recommend that the Final EIS provide a more careful review ofthe market analysis and rail transport options. This analysis should include further investigation ofrail capacity and costs, recognizing the potential for mu,ch higher per barrel rail shipment costs than presented in the DSEIS. This analysis should consider how the level and pace of oil sands crude production might be affected by higher transportation costs and the potential for congestion impacts to slow rail transport of crude.
In its discussion of practicable options for mitigating GHG emissions, the DSEIS outlines ongoing efforts by the government ofAlberta to reduce the GHG emissions associated with development ofoil sands crude in Alberta. EPA recommends that the Final EIS complement this discussion with an exploration ofspecific ways that the U.S. might work with Canada to promote further efforts to reduce GHG emissions associated with the production ofoil sands crude, including a joint focus on carbon capture and storage projects and research, as well as ways to improve energy efficiency associated with extraction technologies. With regard to the estimated GHG emissions from construction and operation of the proposed Project -primarily emissions associated with electrical generation for the pumping stations -we recommend that the Department of State explore specific commitments that TransCanada might make to implement the mitigation measures recommended in the DSEIS. This would complement the significant efforts already made to reduce the risk ofspills and ensure community safety. Specifically, we recommend a focus on pumping station energy efficiency and use of renewable energy, as well as investment in other carbon mitigation options.
Pipeline Safety
We have learned from the 2010 En bridge spill of oil sands crude in Michigan that spills of diluted bitumen (dilbit) may require different response actions or equipment from response actions for conventional oil spills. These spills can also have different impacts than spills ofconventional oil. We recommend that these differences be more fully adldressed in the Final EIS, especially as they relate to the fate and transport ofthe oil and the remediation that will be required. The Enbridge spill involved a 30-inch diameter pipeline, smaller than the 36-inch diameter pipeline for proposed Project, and 20,000 barrels ofoil sands crude were released. In that spill, oil sands crude sank to the bottom of the Kalamazoo River, mixing with the river bottom's sediment and organic matter, making the oil difficult to find and recover. After almost three years of recovery >efforts, EPA recently determined that dredging of bottom sediments will be required to protect public health and welfare and the environment. This determination was based in large part on demonstrations that the oil sands crude associated with the Enbridge spill will not appreciably biodegrade.
We recommend that the Final EIS more clearly acknowledge that in the event of a spill to water, it is possible that large portions of dilbit will sink and that submerged oil significantly changes spill response and impacts. We also re·commend that the Final EIS include means to address the additional risks of releases that may be greater for spills of dilbit than other crudes. For example, in the Enbridge spill, the local health department issued voluntary evacuation notices based on the level ofbenzene measured in the air. Given these concerns, it is important to ensure that the future response and remediation plans will protect communities from impacts due to spills.
The DSEIS also outlines specific measures that the Department of State would require: TransCanada to undertake to prevent and detect oil discharges. The measures include commissioning an independent engineering analysis to review TransCanada's risk assessment ofthe potential impacts from oil discharges to surface and groundwater resources, as well as TransCanada's current proposals for placing mainline valves along the pipeline route and installing leak detection equipment. The DSEIS also notes that the Department ofState will obtain concurrence from both EPA and PHMSA on both the scope ofthe engineering analysis and decisions regarding the need for any additional mitigation measures. We recommend that the Department ofState provide an opportunity for public review and comment on the scope of the analysis, and opportunity for public comment on a draft ofthe analysis when it is completed. We also recommend that the Final ElS consider requiring TransCanada to establish a network of sentinel or monitoring wells along the length ofthe pipeline, especially in sensitive or ecologically important areas, as well as where water supply wells are located and at stream crossings to provide a practical means for early detection of leaks that are below the proposed detection limit.
In addition to prevention measures, we agree with the DSEIS's suggestion that additio1nal mitigation measures regarding preparedness to reduce the impacts ofa spill may be appropriate (DSEIS, p. 4.13-79). For example, we recommend including the following measures as permit conditions:
The DSEIS also recognizes that dissolved components of the dilbit that may be transp.:>rted through the pipeline, such as benzene, polycyclic aromatic hydrocarbons (P AHs), and heavy metals, could be slowly released back to the water column for many years after a release and could cause long-term chronic toxicological impacts to organisms in both the benthic and pelagic portions ofthe aquatic environment. We recommend that the Final EIS more clearly recognize that this characteristic ofdilbit is different from the fate and transport ofoil contaminants associated with conventional crude oil and refined product spills from pipelines. For that reason we recommend that as a permit condition TransCanada be required to develop a plan for long tenn sampling/monitoring in the event ofan oil discharge to assess and monitor these impacts as part ofthe spill response plan. In addition, we recommend that the permit require TransCanada to provide detailed Material Safety Data Sheets and information about the diluent: and the source crude oil to support response preparations and address safety concerns in advance ofany spills.
Alternative Pipeline Routes
CEQ regulations implementing NEPA require the consideration of project alternatives The DSEIS has been significantly improved by considering more alternative routes, including an alternative that would avoid crossing the Sand Hills Region in Nebraska, reducing impacts to this fragile ecosystem. Another significant issue in the consideration ofalternative routes for this Project has been the potential for impacts to the Ogallala Aquifer in the event ofa spill. The alternative route in Nebraska has avoided most ofthe impacts to the Sand Hills Region, but still crosses the Ogallala Aquifer. The alternative laid out in the DSEIS that would avoid the Ogallala Aquifer is the I-90 Corridor Alternative, which largely follows the path of existing pipelines. The I-90 Corridor Alternative would significantly reduce the length ofpipeline crossing the Northern High Plains Aquifer system, which includes the Ogallala formation, and would further reduce the pot1ential for adverse impacts to critical groundwater resources.
We are concerned, however, that the DSE1S does not provide a detailed analysis ofthe Keystone Corridor Alternative routes, which would parallel the existing Keystone Pipeline and likely further reduce potential environmental impacts to groundwater resources. By determining that these routes are not reasonable, the DSEIS does not provide an analysis oftheir potential impacts sufficient to enable a meaningful comparison to the proposed route and other alternatives. The Keystone Corridor Alternatives were determined not to be reasonable alternatives primarily on the basis that these routes are longer than the proposed Project's route, and that additional pipeline miles would be needed to connect to Bakken Market Link project, which would allow the proposed Project to also transport crude from North Dakota and Montana. As we have indicated in the past, we believe these alternative routes could further reduce risks to groundwater resources. We recommend that the Final EIS either provide more detailed information as to why these alternatives were not considered reasonable or analyze these alternatives in more detail.
Community and Environmental Justice Impacts
The DSEIS provides a comprehensive analysis of community demographics, including minority, low-income, and tribal populations, along TransCanada's proposed pipeline route. We are especially appreciative ofthe effort to identify and contact each of the Local Emergency Planning Committees regarding the status oftheir emergency response plans, and to provide that information in the OSEIS. We also commend your recognition that environmental justice communities may be more vulnerable to health impacts from a spill, and appreciate your efforts to consider communities' access to health care, including consideration of "Health Professional Shortage Areas and Medically Underserved Areas" located along the proposed pipeline route.
EPA appreciates TransCanada's commitment to conduct cleanup and restoration and to provide alternative water supplies to affected communities in the event ofan oil discharge affecting not only surface waters, but also groundwater. We recommend that these commitments be clearly documented as proposed permit conditions. We believe this would give important assurances to potentially affected communities of TransCanada's responsibilities in the event of an oil discharge that affects either surface or groundwater resources.
Conclusion
Based on our review, we have rated the DSEIS as E0-2 ("Environmental Objections-Insufficient Information") (see enclosed "Summary ofRating Defmitions and Follow-up Actions"). We look forward to continuing to work with you and to provide assistance as you prepare the Final EIS. We also look forward to working with you as you determine whether approving the proposed project serves the national interest under Executive Order 13337 "Issuance of Permits With Respect to Certain Energy-Related Facilities and Land Transportation Crossings on the International Boundaries of the United States".
Please feel free to contact me or have your staff contact Susan Bromm, Director, Office ofFederal Activities, at (202) 564-5400 if you have any questions or would like to discuss our comments.
Sincerely,
Cynthia Giles
Summary of Rating Definitions and Follow-up Action
Environme:ntal Impact of the Action
LO--Lack of Objections. The EPA r.eview has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application ofmitigation measures that could be accomplished with no more than minor changes to the proposal.
EC~Environmental. The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application ofmitigation measures tlhat can reduce the environmental impact. EPA would like to work with the lead agency to reduce these impacts.
EO--Envil'onmental Objections. The EPA r.eyiew has identified significant environmental impacts that must be avoided in order to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration ofsome other project alternative (including the no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.
EU--Envir'onmentally Unsatisfactory. The EPA r·eview has identified adverse environmental impacts that are ofsufficient magnirude that they are unsatisfact•Oi)' from the standpoint ofpublic health or welfare or environmental quality. EPA intends to work with the lead agency to reduce these impacts. If the potentially unsatisfactory impacts are not corrected at the fin11l EIS stage, this !Proposal will be recommended for referral to the CEQ.
Adequacy of the Impact Statement
Category 1--Adequate. EPA believes the draft ETS adequately sets forth the environmental impact(s) ofthe preferred alternative and those ofthe alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition ofclarifying language or information.
Category 2--lnsufficient Information. The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternative: that are within tbe spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts ofthe action. The EPA reviewer identified additional information, data, analyses, or discussion should be included in the final EIS. Category 3--Inadequate. EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts ofthe action, or the EPA reviewer has identified reasonably available alternatives that are outside ofthe spectrum of alternatives analyzed in the draft ElS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EfS is adequate fN the purposes ofthe NEPA and/or Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft E1S. On the basis ofthe potential significant impacts involved, this proposal could be a candidate for referral to the CEQ. (EPA)
Monday, April 22, 2013
EPA Honors Winners of First-Ever Campus RainWorks Challenge
University of Florida and Illinois Institute of Technology lead in design of green infrastructure on campus
The U.S. Environmental Protection Agency (EPA) today announced the four winners of the Campus RainWorks Challenge, a new design challenge created to inspire the next generation of landscape architects, planners and engineers to develop innovative green infrastructure systems that reduce stormwater pollution and support sustainable communities.
Stormwater is one of the most widespread challenges to water quality in the nation. Large volumes of stormwater pollute our nation’s streams, rivers and lakes, posing a threat to human health and contributing to downstream flooding.
The Campus RainWorks Challenge engages students and faculty members at colleges and universities to apply green infrastructure principles and design, encourage interdisciplinary collaboration, and increase the use of green infrastructure on campuses across the nation. Teams of undergraduate and graduate students, working with a faculty advisor, developed innovative green infrastructure designs for a site on their campus showing how managing stormwater at its source can benefit the campus community and the environment.
The selected challenge winners are:
- University of Florida, Gainsville, Fl. (1st prize, large institution)
The team’s design plan centers on the redevelopment of Reitz Lawn, an 11-acre open area and pedestrian corridor on campus. The plan aims to remove pollutants from stormwater before they reach nearby Lake Alice, which drains directly into the Floridian Aquifer. The team’s plan incorporated student input into the project design and will include an educational component to raise awareness about how water travels through the urban environment.
- Illinois Institute of Technology, Chicago, Ill. (1st prize, small institution)
The team’s design plan centers on the redevelopment of a 1,200-foot long section of Dearborn Street on campus. The plan incorporates a number of green infrastructure design elements, including rain gardens that double as outdoor seating areas and permeable walkways. The plan estimates that, through collection, infiltration, and storage, stormwater runoff will be reduced from the site by 70 – 80 percent.
- University of Arizona, Tuscon, Ariz. (2nd prize, large institution)
The team’s design plan centers on the redevelopment of a 70,000-square-foot parking lot located within a cluster of academic buildings. The design will replace the parking lot with a campus common area featuring two rings of retention basins to infiltrate stormwater runoff, five underground cisterns to harvest runoff and HVAC condensate from the adjacent buildings, and a translucent shade structure with an ephemeral water feature. Water collected in the underground cisterns is used to irrigate the landscape, reducing potable water use from 700,000 to 90,000 gallons/year.
- Missouri University of Science and Technology, Rolla, Mo. (2nd prize, small institution)
The team’s design plan focuses on three green infrastructure projects: green roof, rain garden, and permeable pavement projects. Phased implementation will take advantage of existing plans for university projects, allowing for cost-effective improvements in campus stormwater managment that will mitigate eutrophication and sedimentation in Frisco Lake.
-Teams from Kansas State University, Columbia University, California State Polytechnic Institute at Pomona and University of Texas-Arlington were recognized as honorable mentions for their entries.
The challenge received submissions from 218 teams, which were reviewed by more than 30 expert judges from EPA, the American Society of Landscape Architects, the Water Environment Federation, and the American Society of Civil Engineers. Many of the submissions proposed transformative additions to the campus landscape that would reduce stormwater impacts while educating students about the movement of water through the urban environment. The winning teams were selected based on six criteria: analysis and planning; preservation or restoration of natural features; integrated water management; soil and vegetation management; value to campus; and likelihood of implementation.
Green infrastructure helps communities to maintain healthy waters, support sustainable communities, and provide multiple environmental benefits. Green infrastructure captures and filters pollutants by passing stormwater through soils and retaining it on site. Example of effective green infrastructure include green roofs, permeable materials, alternative designs for streets and buildings, trees, rain gardens and rain harvesting systems. (EPA)
More information
The U.S. Environmental Protection Agency (EPA) today announced the four winners of the Campus RainWorks Challenge, a new design challenge created to inspire the next generation of landscape architects, planners and engineers to develop innovative green infrastructure systems that reduce stormwater pollution and support sustainable communities.
Stormwater is one of the most widespread challenges to water quality in the nation. Large volumes of stormwater pollute our nation’s streams, rivers and lakes, posing a threat to human health and contributing to downstream flooding.
The Campus RainWorks Challenge engages students and faculty members at colleges and universities to apply green infrastructure principles and design, encourage interdisciplinary collaboration, and increase the use of green infrastructure on campuses across the nation. Teams of undergraduate and graduate students, working with a faculty advisor, developed innovative green infrastructure designs for a site on their campus showing how managing stormwater at its source can benefit the campus community and the environment.
The selected challenge winners are:
- University of Florida, Gainsville, Fl. (1st prize, large institution)
The team’s design plan centers on the redevelopment of Reitz Lawn, an 11-acre open area and pedestrian corridor on campus. The plan aims to remove pollutants from stormwater before they reach nearby Lake Alice, which drains directly into the Floridian Aquifer. The team’s plan incorporated student input into the project design and will include an educational component to raise awareness about how water travels through the urban environment.
- Illinois Institute of Technology, Chicago, Ill. (1st prize, small institution)
The team’s design plan centers on the redevelopment of a 1,200-foot long section of Dearborn Street on campus. The plan incorporates a number of green infrastructure design elements, including rain gardens that double as outdoor seating areas and permeable walkways. The plan estimates that, through collection, infiltration, and storage, stormwater runoff will be reduced from the site by 70 – 80 percent.
- University of Arizona, Tuscon, Ariz. (2nd prize, large institution)
The team’s design plan centers on the redevelopment of a 70,000-square-foot parking lot located within a cluster of academic buildings. The design will replace the parking lot with a campus common area featuring two rings of retention basins to infiltrate stormwater runoff, five underground cisterns to harvest runoff and HVAC condensate from the adjacent buildings, and a translucent shade structure with an ephemeral water feature. Water collected in the underground cisterns is used to irrigate the landscape, reducing potable water use from 700,000 to 90,000 gallons/year.
- Missouri University of Science and Technology, Rolla, Mo. (2nd prize, small institution)
The team’s design plan focuses on three green infrastructure projects: green roof, rain garden, and permeable pavement projects. Phased implementation will take advantage of existing plans for university projects, allowing for cost-effective improvements in campus stormwater managment that will mitigate eutrophication and sedimentation in Frisco Lake.
-Teams from Kansas State University, Columbia University, California State Polytechnic Institute at Pomona and University of Texas-Arlington were recognized as honorable mentions for their entries.
The challenge received submissions from 218 teams, which were reviewed by more than 30 expert judges from EPA, the American Society of Landscape Architects, the Water Environment Federation, and the American Society of Civil Engineers. Many of the submissions proposed transformative additions to the campus landscape that would reduce stormwater impacts while educating students about the movement of water through the urban environment. The winning teams were selected based on six criteria: analysis and planning; preservation or restoration of natural features; integrated water management; soil and vegetation management; value to campus; and likelihood of implementation.
Green infrastructure helps communities to maintain healthy waters, support sustainable communities, and provide multiple environmental benefits. Green infrastructure captures and filters pollutants by passing stormwater through soils and retaining it on site. Example of effective green infrastructure include green roofs, permeable materials, alternative designs for streets and buildings, trees, rain gardens and rain harvesting systems. (EPA)
More information
EARTH DAY: Invisible In 2013 and Date Should Be Moved
PRESIDENT'S CORNER
By Norris McDonald
It is really cold today. Welcome to Earth Day 2013. Usually it is cold AND rainy. Who came up with this date anyway. Well I know but let's leave them out of it for the moment. April 22 is a horrible date for Earth Day. It is too early. It should be on May 22 or June 22. The weather is always more conducive to outdoor activities a month or two later in the year. Now I am not trying to disparage the original founders of Earth Day (Denis Hayes and Gaylord Nelson), but I am suggesting that it might be time for an official change. Anybody out there with me on this? Speak up. Let's change the date.
Earth Day received almost no attention this year. Sometimes it gets a lot of attention and some years it does not. Clearly the Boston Marathon bombing incident domoinated the news cycle right up through today. Yet, I think the sluggish economy has the collective mind elsewhere. Has the public tired of hearing about global warming? Do they care? And is the Keystone XL Pipeline the best top environmental issue the movement can come up with as a motivating issue? It reminds me of the Arctic National Wildlife Refuge (ANWR) issue. Most regular Americans simply will not get too worked up over it. Without a compelling issue or issues to inspire the public, Earth Day does not seem to have juice.
Alas, Earth Day is invisible this year.
By Norris McDonald
It is really cold today. Welcome to Earth Day 2013. Usually it is cold AND rainy. Who came up with this date anyway. Well I know but let's leave them out of it for the moment. April 22 is a horrible date for Earth Day. It is too early. It should be on May 22 or June 22. The weather is always more conducive to outdoor activities a month or two later in the year. Now I am not trying to disparage the original founders of Earth Day (Denis Hayes and Gaylord Nelson), but I am suggesting that it might be time for an official change. Anybody out there with me on this? Speak up. Let's change the date.
Earth Day received almost no attention this year. Sometimes it gets a lot of attention and some years it does not. Clearly the Boston Marathon bombing incident domoinated the news cycle right up through today. Yet, I think the sluggish economy has the collective mind elsewhere. Has the public tired of hearing about global warming? Do they care? And is the Keystone XL Pipeline the best top environmental issue the movement can come up with as a motivating issue? It reminds me of the Arctic National Wildlife Refuge (ANWR) issue. Most regular Americans simply will not get too worked up over it. Without a compelling issue or issues to inspire the public, Earth Day does not seem to have juice.
Alas, Earth Day is invisible this year.
Saturday, April 20, 2013
EPA Publishes 18th Annual U.S. Greenhouse Gas Inventory
The U.S. Environmental Protection Agency (EPA) has released its 18th annual report of overall U.S. greenhouse gas (GHG) emissions showing a 1.6 percent decrease in 2011 from the previous year. Recent trends can be attributed to multiple factors including reduced emissions from electricity generation, improvements in fuel efficiency in vehicles with reductions in miles traveled, and year-to-year changes in the prevailing weather.
EPA has taken a number of common sense steps to help reduce GHG emissions. This includes increasing fuel efficiency for cars that will reduce America’s dependence on oil by an estimated 12 billion barrels by 2025, and increasing energy efficiency through the Energy Star program that saved Americans $24 billion in utility bills in 2012.
GHGs are the primary driver of climate change, which can lead to hotter, longer heat waves that threaten the health of the sick, poor or elderly; increases in ground-level ozone pollution linked to asthma and other respiratory illnesses; as well as other threats to the health and welfare of Americans. GHG emissions in 2011 showed a 6.9 percent drop below 2005 levels.
Total emissions of the six main greenhouse gases in 2011 were equivalent to 6,702 million metric tons of carbon dioxide. These gases include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.
The Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2011 is the latest annual report that the United States has submitted to the Secretariat of the United Nations Framework Convention on Climate Change since it was ratified by the United States in 1992. The treaty sets an overall framework for intergovernmental efforts to address the challenge posed by climate change. EPA prepares the annual report in collaboration with other federal agencies and after gathering comments from stakeholders across the country.
The inventory tracks annual GHG emissions at the national level and presents historical emissions from 1990 to 2011. The inventory also calculates carbon dioxide emissions that are removed from the atmosphere through the uptake of carbon by forests, vegetation, soils, and other natural processes (called carbon “sinks”). (EPA)
For a graphic illustrating total U.S. GHG emissions by year
More on the greenhouse gas inventory report.
EPA has taken a number of common sense steps to help reduce GHG emissions. This includes increasing fuel efficiency for cars that will reduce America’s dependence on oil by an estimated 12 billion barrels by 2025, and increasing energy efficiency through the Energy Star program that saved Americans $24 billion in utility bills in 2012.
GHGs are the primary driver of climate change, which can lead to hotter, longer heat waves that threaten the health of the sick, poor or elderly; increases in ground-level ozone pollution linked to asthma and other respiratory illnesses; as well as other threats to the health and welfare of Americans. GHG emissions in 2011 showed a 6.9 percent drop below 2005 levels.
Total emissions of the six main greenhouse gases in 2011 were equivalent to 6,702 million metric tons of carbon dioxide. These gases include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.
The Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2011 is the latest annual report that the United States has submitted to the Secretariat of the United Nations Framework Convention on Climate Change since it was ratified by the United States in 1992. The treaty sets an overall framework for intergovernmental efforts to address the challenge posed by climate change. EPA prepares the annual report in collaboration with other federal agencies and after gathering comments from stakeholders across the country.
The inventory tracks annual GHG emissions at the national level and presents historical emissions from 1990 to 2011. The inventory also calculates carbon dioxide emissions that are removed from the atmosphere through the uptake of carbon by forests, vegetation, soils, and other natural processes (called carbon “sinks”). (EPA)
For a graphic illustrating total U.S. GHG emissions by year
More on the greenhouse gas inventory report.
Friday, April 19, 2013
EPA Proposes To Cut Pollutants Into Waterways By Power Plants
In accordance with a consent decree and in line with requirements under the Clean Water Act, the U.S. Environmental Protection Agency (EPA) today will propose a range of options to help reduce dangerous pollutants, including mercury, arsenic, lead, and selenium that are released into America’s waterways by coal ash, air pollution control waste and other waste from steam electric power plants. Today’s proposal includes a variety of options for whether and how these different waste streams should be treated. EPA will take comment on all of these options, which it will use to help inform the most appropriate final standard.
Steam electric power plants currently account for more than half of all toxic pollutants discharged into streams, rivers and lakes from permitted industrial facilities in the United States. High exposure to these types of pollutants has been linked to neurological damage and cancer as well as damage to the circulatory system, kidneys and liver.Toxic heavy metals do not break down in the environment and can also contaminate sediment in waterways and impact aquatic life and wildlife, including large-scale die-offs of fish.
The proposal updates standards that have been in place since 1982, incorporating technology improvements in the steam electric power industry over the last three decades as required by the Clean Water Act. The proposed national standards are based on data collected from industry and provide flexibility in implementation through a phased-in approach and use of technologies already installed at a number of plants. Under the proposed approach, new requirements for existing power plants would be phased in between 2017 and 2022, and would leverage flexibilities as necessary.
Fewer than half of coal-fired power plants are estimated to incur costs under any of the proposed preferred options, because many power plants already have the technology and procedures in place to meet the proposed pollution control standards.
The four preferred options differ in the number of waste streams covered (such as fly ash handling systems, treatment of air pollution control waste and bottom ash), the size of the units controlled and the stringency of the treatment controls to be imposed. EPA estimates that the regulations would reduce pollutant discharges by 470 million to 2.62 billion pounds annually and reduce water use by 50 billion to 103 billion gallons per year.
EPA also announced its intention to align this Clean Water Act rule with a related rule for coal combustion residuals (CCRs, also known as “coal ash”) proposed in 2010 under the Resource Conservation and Recovery Act. The two rules would apply to many of the same facilities and would work together to reduce pollution associated with coal ash and related wastes. EPA is seeking comment from industry and other stakeholders to ensure that both final rules are aligned to reduce pollution efficiently and minimize regulatory burdens.
There are approximately 1,200 steam electric power plants that generate electricity using nuclear fuel or fossil fuels such as coal, oil, and natural gas in the U.S. Approximately 500 of these power plants are coal fired units which are the primary source of the pollutants being addressed by the proposed regulation. Power plants that are smaller than 50 megawatts would not be impacted by these new standards, and the majority of coal-fired power plants would incur no costs under the proposed standards.
The public comment period on the proposed rule will be open for 60 days after publication in the Federal Register. The agency is under a consent decree to take final action by May 22, 2014. (EPA)
More information
Steam electric power plants currently account for more than half of all toxic pollutants discharged into streams, rivers and lakes from permitted industrial facilities in the United States. High exposure to these types of pollutants has been linked to neurological damage and cancer as well as damage to the circulatory system, kidneys and liver.Toxic heavy metals do not break down in the environment and can also contaminate sediment in waterways and impact aquatic life and wildlife, including large-scale die-offs of fish.
The proposal updates standards that have been in place since 1982, incorporating technology improvements in the steam electric power industry over the last three decades as required by the Clean Water Act. The proposed national standards are based on data collected from industry and provide flexibility in implementation through a phased-in approach and use of technologies already installed at a number of plants. Under the proposed approach, new requirements for existing power plants would be phased in between 2017 and 2022, and would leverage flexibilities as necessary.
Fewer than half of coal-fired power plants are estimated to incur costs under any of the proposed preferred options, because many power plants already have the technology and procedures in place to meet the proposed pollution control standards.
The four preferred options differ in the number of waste streams covered (such as fly ash handling systems, treatment of air pollution control waste and bottom ash), the size of the units controlled and the stringency of the treatment controls to be imposed. EPA estimates that the regulations would reduce pollutant discharges by 470 million to 2.62 billion pounds annually and reduce water use by 50 billion to 103 billion gallons per year.
EPA also announced its intention to align this Clean Water Act rule with a related rule for coal combustion residuals (CCRs, also known as “coal ash”) proposed in 2010 under the Resource Conservation and Recovery Act. The two rules would apply to many of the same facilities and would work together to reduce pollution associated with coal ash and related wastes. EPA is seeking comment from industry and other stakeholders to ensure that both final rules are aligned to reduce pollution efficiently and minimize regulatory burdens.
There are approximately 1,200 steam electric power plants that generate electricity using nuclear fuel or fossil fuels such as coal, oil, and natural gas in the U.S. Approximately 500 of these power plants are coal fired units which are the primary source of the pollutants being addressed by the proposed regulation. Power plants that are smaller than 50 megawatts would not be impacted by these new standards, and the majority of coal-fired power plants would incur no costs under the proposed standards.
The public comment period on the proposed rule will be open for 60 days after publication in the Federal Register. The agency is under a consent decree to take final action by May 22, 2014. (EPA)
More information
Natural Gas Replacing Coal Produces CO2 Reduction in USA
U.S. carbon-dioxide emissions have fallen dramatically in recent years, in large part because the country is making more electricity with natural gas instead of coal. Energy-related emissions of carbon dioxide, the greenhouse gas that is widely believed to contribute to global warming, have fallen 12% between 2005 and 2012 and are at their lowest level since 1994, according to a recent estimate by the Energy Information Administration, the statistical arm of the U.S. Energy Department.
While other factors, including a sluggish U.S. economy and increasing energy efficiency, have contributed to the decline in carbon emissions from factories, automobiles and power plants, many experts believe the switch from coal to natural gas for electricity generation has been the biggest factor. Carbon-dioxide emissions account for nearly 84% of greenhouse-gas emissions, while methane—the main ingredient in natural gas—makes up 8.8%, according to a recent Environmental Protection Agency report.
Natural gas emits half as much carbon dioxide as coal when used to make electricity, though the calculation fails to take into account the release of methane from natural-gas wells and pipelines, which also contributes to climate change.
Last year, 30% of power in the U.S. came from burning natural gas, up from 19% in 2005, driven by drilling technologies that have unlocked large and inexpensive new supplies of the fuel.
The U.S. trend hasn't led to a global decline in carbon emissions, which increased 15% from 2005 China's rising reliance on coal to fuel economic growth jeopardizes progress toward what the IEA calls "a low-carbon future." But the U.S., which has decreased its carbon-dioxide output tonnage more than any other nation, demonstrates that market forces can have an impact on greenhouse gases even as politicians continue to disagree over what, if any, federal regulations are needed to force industries to reduce their emissions. (WSJ, 4/18/2013)
through 2011, according to federal statistics. An International Energy Agency report this week concluded that
While other factors, including a sluggish U.S. economy and increasing energy efficiency, have contributed to the decline in carbon emissions from factories, automobiles and power plants, many experts believe the switch from coal to natural gas for electricity generation has been the biggest factor. Carbon-dioxide emissions account for nearly 84% of greenhouse-gas emissions, while methane—the main ingredient in natural gas—makes up 8.8%, according to a recent Environmental Protection Agency report.
Natural gas emits half as much carbon dioxide as coal when used to make electricity, though the calculation fails to take into account the release of methane from natural-gas wells and pipelines, which also contributes to climate change.
Last year, 30% of power in the U.S. came from burning natural gas, up from 19% in 2005, driven by drilling technologies that have unlocked large and inexpensive new supplies of the fuel.
The U.S. trend hasn't led to a global decline in carbon emissions, which increased 15% from 2005 China's rising reliance on coal to fuel economic growth jeopardizes progress toward what the IEA calls "a low-carbon future." But the U.S., which has decreased its carbon-dioxide output tonnage more than any other nation, demonstrates that market forces can have an impact on greenhouse gases even as politicians continue to disagree over what, if any, federal regulations are needed to force industries to reduce their emissions. (WSJ, 4/18/2013)
Thursday, April 18, 2013
No Progress Made In Reducing CO2
The world has made almost no progress over the past 20 years in reducing the carbon content of its energy supplies, despite more than $2 trillion of investment into renewable-energy projects such as wind and solar power, according to the International Energy Agency (IEA). The lack of CO2 reduction is largely because of coal's continued dominance as a fuel for electricity generation, the IEA said. As energy consumption has grown, this means total global emissions of CO2 rose 44% from 1990 to 2010.
The IEA estimates that a cut in carbon emissions per unit of energy of more than 60% is needed to prevent global average temperatures rising by more than 3.6 degrees Fahrenheit in the long term, and maintaining current levels would yield a temperature rise of 10.8 degrees Fahrenheit.
Coal has been preferred in fast-growing Asian economies for decades because it is relatively
inexpensive and abundant, the IEA said, and coal-fired generation "has far outpaced" the significant increase from non-fossil energy. China and India accounted for 95% of the growth in global coal demand in 2000 to 2011, the IEA said.
Even in Europe, which has some of the world's most ambitious emissions-reduction targets, coal use is rising, the IEA said. In Europe's largest economy, Germany, CO2 emissions edged higher last year as more coal was burned because it was cheaper than natural gas, according to the government's federal environmental agency.
The IEA warned that little is happening to mitigate the environmental impact of coal's continued dominance in power generation. Many new coal-fired power plants continue to use inefficient technologies, offsetting measures to close some older and dirtier plants. Projects to develop the technology that would allow the capture and storage of carbon emitted by power plants have made little progress, it added. (WSJ, 4/17/2013)
The IEA estimates that a cut in carbon emissions per unit of energy of more than 60% is needed to prevent global average temperatures rising by more than 3.6 degrees Fahrenheit in the long term, and maintaining current levels would yield a temperature rise of 10.8 degrees Fahrenheit.
Coal has been preferred in fast-growing Asian economies for decades because it is relatively
inexpensive and abundant, the IEA said, and coal-fired generation "has far outpaced" the significant increase from non-fossil energy. China and India accounted for 95% of the growth in global coal demand in 2000 to 2011, the IEA said.
Even in Europe, which has some of the world's most ambitious emissions-reduction targets, coal use is rising, the IEA said. In Europe's largest economy, Germany, CO2 emissions edged higher last year as more coal was burned because it was cheaper than natural gas, according to the government's federal environmental agency.
The IEA warned that little is happening to mitigate the environmental impact of coal's continued dominance in power generation. Many new coal-fired power plants continue to use inefficient technologies, offsetting measures to close some older and dirtier plants. Projects to develop the technology that would allow the capture and storage of carbon emitted by power plants have made little progress, it added. (WSJ, 4/17/2013)
Peabody Energy (Coal) 1st Quarter Earnings
Coal miner Peabody Energy Corp. profits slid in the first three months of the year on lower U.S. shipments and prices for its Australian coal. The world’s biggest private-sector coal company said Thursday that its net loss attributable to common shareholders was $23.4 million, or a loss of 9 cents per share. That compares to a profit of $172.7 million, or 63 cents per share, a year earlier.
Revenue fell 14 percent to $1.75 billion. (Wash Post, 4/18/2013)
Revenue fell 14 percent to $1.75 billion. (Wash Post, 4/18/2013)
12 States To Sue EPA Over Delayed CO2 Rule
A dozen states and cities are jointly threatening to sue the Environmental Protection Agency over its failure to impose carbon emissions standards on power plants. New York is among the states and environmental groups that reached a late 2010 settlement with EPA in which the agency committed to setting rules for new and existing plants. The 11 other parties signing the notice include the states of Connecticut, Vermont, Oregon, Delaware, Maine, Massachusetts, and the cities of New York and the District of Columbia.
The formal notice of intent to sue delivered Wednesday comes after EPA missed a mid-April deadline to complete already-delayed emissions standards for new power plants. EPA has not provided a timetable for completing the rule. This 60-day notice is required under the Clean Air Act before an enforcement lawsuit may be filed.
While the Obama Administration has pledged to combat climate change, the Environmental Protection Agency has now missed the deadline for adopting New Source Performance Standards (NSPS) to limit greenhouse gas emissions from new fossil fuel power plants
In addition to missing the deadline for rules for existing plants, EPA has also not moved ahead with emissions guidelines for existing power plants, which are on a slower track.
Green groups sent a separate notice to EPA this week that similarly threatened litigation to force EPA’s hand. (The Hill, 4/17/2013)
The formal notice of intent to sue delivered Wednesday comes after EPA missed a mid-April deadline to complete already-delayed emissions standards for new power plants. EPA has not provided a timetable for completing the rule. This 60-day notice is required under the Clean Air Act before an enforcement lawsuit may be filed.
While the Obama Administration has pledged to combat climate change, the Environmental Protection Agency has now missed the deadline for adopting New Source Performance Standards (NSPS) to limit greenhouse gas emissions from new fossil fuel power plants
In addition to missing the deadline for rules for existing plants, EPA has also not moved ahead with emissions guidelines for existing power plants, which are on a slower track.
Green groups sent a separate notice to EPA this week that similarly threatened litigation to force EPA’s hand. (The Hill, 4/17/2013)
Wednesday, April 17, 2013
House Subcommittee Passes Bill To By-Pass President on Keystone XL Pipeline Decision
A bill to bypass President Obama’s authority to decide the Keystone XL oil sands pipeline’s fate passed a House Energy and Commerce subcommitteel on Tuesday.
The Northern Route Approval Act (H.R. 3) passed the Energy and Power subcommittee with a 17-9 vote. All Republicans voted in favor of the bill, with Democratic Reps. John Barrow (Ga.) and Gene Green (Texas) joining them. The bill would strip the need for pipeline builder TransCanada Corp. to receive a cross-border permit from the State Department to construct its northern leg, which would stretch into Canada.
The legislation now proceeds to the full House Energy and Commerce Committee, where it will likely pass. Committee Chairman Fred Upton (R-Mich.) has said he wants to get the bill called on the House floor before Memorial Day. (The Hill, 4/16/2013)
The Northern Route Approval Act (H.R. 3) passed the Energy and Power subcommittee with a 17-9 vote. All Republicans voted in favor of the bill, with Democratic Reps. John Barrow (Ga.) and Gene Green (Texas) joining them. The bill would strip the need for pipeline builder TransCanada Corp. to receive a cross-border permit from the State Department to construct its northern leg, which would stretch into Canada.
The legislation now proceeds to the full House Energy and Commerce Committee, where it will likely pass. Committee Chairman Fred Upton (R-Mich.) has said he wants to get the bill called on the House floor before Memorial Day. (The Hill, 4/16/2013)
Tuesday, April 16, 2013
In 5th Year, RGGI CO2 Allowance Market Remains Competitive
2012 Annual Market Monitor Report
No evidence of anti-competitive conduct has been found in the market for Regional Greenhouse Gas Initiative (RGGI) CO2 allowances, according to the independent market monitor’s 2012 Annual Report on the Market for RGGI CO2 Allowances, released today.
The independent market monitor, Potomac Economics, continues to find no material concerns regarding the auction process, barriers to participation in the auctions, competitiveness of the auction results, or in the competitiveness of the secondary market for RGGI allowances.
The report evaluates activity in the market for RGGI CO2 allowances in 2012, focusing on allowance prices, trading and acquisition of allowances in the auctions and secondary market, participation in the market by individual firms, and market monitoring.
Compliance entities consistently acquired the majority of CO2 allowances in each auction in 2012, purchasing 98 percent of the allowances sold.
According to the independent market monitor, the average auction clearing price was $1.93 in 2012. CO2 allowances have cleared at the reserve price in each auction since September 2010 through December 2012, reflecting the excess supply of first control period allowances. The price of CO2 allowance transfers in the secondary market were stable and remained close to the auction reserve price of $1.93 throughout 2012. Monthly average prices ranged from a high of $2.01 in February to a low of $1.93 in October.
(The Report)
The independent market monitor, Potomac Economics, continues to find no material concerns regarding the auction process, barriers to participation in the auctions, competitiveness of the auction results, or in the competitiveness of the secondary market for RGGI allowances.
The report evaluates activity in the market for RGGI CO2 allowances in 2012, focusing on allowance prices, trading and acquisition of allowances in the auctions and secondary market, participation in the market by individual firms, and market monitoring.
Compliance entities consistently acquired the majority of CO2 allowances in each auction in 2012, purchasing 98 percent of the allowances sold.
According to the independent market monitor, the average auction clearing price was $1.93 in 2012. CO2 allowances have cleared at the reserve price in each auction since September 2010 through December 2012, reflecting the excess supply of first control period allowances. The price of CO2 allowance transfers in the secondary market were stable and remained close to the auction reserve price of $1.93 throughout 2012. Monthly average prices ranged from a high of $2.01 in February to a low of $1.93 in October.
(The Report)
California Wind Power
California saw a surge in new wind farms last year, taking its wind power capacity to 5,544 megawatts. That put it second in the nation behind Texas, which has more than 12,000 MW of installed wind capacity. The total system peak electricity requires are about 27,426 megawatts. One megawatt provides enough electricity for about 1,000 homes. (Grist, 4/16/2013)
Old Oil Pipeline Welds Vulnerable To Failure
Exxon Mobil pipeline spill in Mayflower, Ark. |
An Exxon Mobil Corp. pipeline rupture caused a major oil spill last month spilled about 5,000 barrels of oil that ran through a Mayflower, Ark., development after a 22-foot split opened.
A Chevron Corp. pipeline in Utah last month that spilled 600 barrels of diesel near the Great Salt Lake, segments of the pipes were made about 60 years ago by bending metal sheets to form a tube, then heating the edges with a low-frequency electric current to weld them lengthwise. Such welds can leave defects in seams that make them vulnerable to corrosion and cracks, risks that have been known for decades. By 1970, most pipe manufacturers began using a high-frequency current to weld, which produced seams less prone to fractures.
The Exxon pipeline gushed about 5,000 barrels of crude into a residential neighborhood through a 22-foot, incision-like break.
Of the 1,151 accidents on liquids pipelines since 2010 reported to federal regulators, 78% don't show what kind of weld was involved, and 85% don't show when the pipe was manufactured, according to a Wall Street Journal review of government data. The Pipeline and Hazardous Materials Safety Administration (PHMSA) says most of the accidents involved very small spills, or weren't related to pipe welds, so operators weren't required to furnish detailed information about them.
But the number of pipeline accidents has been rising; the 364 accidents on liquids pipelines last year were the most since 2008, but fewer than in 2002, according to federal data.
Clean-up crew removing crude oil from a Mayflower, Ark., Associated Press
|
Federal regulators are questioning the adequacy of inspection methods. The surest way to identify a weld defect is to pump water through the pipe at high pressure. Such tests are costly, requiring a company to shut down the line, and in some cases apparently led to failures when placed back in service.
Online Nonprofit InsideClimate News Wins Pulitzer
Lisa Song |
Elizabeth McGowan |
David Hasemyer |
InsideClimate News is five-year-old non-profit, non-partisan news organization that covers clean energy, carbon energy, nuclear energy and environmental science. Its mission is to produce objective stories that give the public and decision-makers the information they need to navigate the heat and emotion of the climate and energy debates. It has grown from a founding staff of two to a mature virtual newsroom of seven full-time professional journalists and a growing network of contributors. (ABC News, 4/15/2013, Inside Climate News)
Monday, April 15, 2013
Pipeline Company Use of Eminent Domain
Private pipeline companies can use eminent domain to seize land-use rights for pipelines at one price, deemed fair by the courts, and can turn around and sell those rights at a substantial profit. Conversely, federal government and some Indian tribes, who by law are not subject to eminent domain, usually do not grant perpetual rights of way. Instead they grant 10-year leases with rights of renewal and charge rent accordingly. Pipeline rights of way are bought and sold on the open market by the linear foot among private pipeline companies. State law determines just compensation in eminent-domain proceedings.
Rental is advantageous to the landowner and eminent-domain leases are advantageous to the pipeline companies.
Gas gathering lines are not allowed the right of eminent domain under New York law.
In many states, the courts use a system of "before and after" to determine the value to be paid for the right of way. The courts determine the highest and best use of the land underneath the right of way, then they value the land before the right of way is applied and after it is in place. The difference is paid to the landowner as his "just compensation."
Valuing the right of way in this manner results in an extraordinary double-standard. Because a farmer can grow crops on the land again once the pipeline is in place, the loss to a farmer is deemed temporary and the land is worth, for all intents and purposes, the same before and after. Effectively the farmer receives a pittance for the right of way while the pipeline company enjoys a windfall of economic opportunity.
Clearly, the real value is not in the land but in the economic opportunity the right of way grants to the business entity. How is it "just compensation" that the farmer should be paid a fraction of the acreage value of his portion of the right of way, when anytime after eminent domain the pipeline company could sell the farmer's right of way on a linear-foot basis at a substantial profit?
If s landowners must suffer the indignity of being denied the opportunity to develop their natural-gas deposits in states with fracking moratoria, they should at least be fairly compensated for the economic opportunity taken from them as other states' gas passes through their lands. (WSJ, 4/12/2013)
Rental is advantageous to the landowner and eminent-domain leases are advantageous to the pipeline companies.
Gas gathering lines are not allowed the right of eminent domain under New York law.
In many states, the courts use a system of "before and after" to determine the value to be paid for the right of way. The courts determine the highest and best use of the land underneath the right of way, then they value the land before the right of way is applied and after it is in place. The difference is paid to the landowner as his "just compensation."
Valuing the right of way in this manner results in an extraordinary double-standard. Because a farmer can grow crops on the land again once the pipeline is in place, the loss to a farmer is deemed temporary and the land is worth, for all intents and purposes, the same before and after. Effectively the farmer receives a pittance for the right of way while the pipeline company enjoys a windfall of economic opportunity.
Clearly, the real value is not in the land but in the economic opportunity the right of way grants to the business entity. How is it "just compensation" that the farmer should be paid a fraction of the acreage value of his portion of the right of way, when anytime after eminent domain the pipeline company could sell the farmer's right of way on a linear-foot basis at a substantial profit?
If s landowners must suffer the indignity of being denied the opportunity to develop their natural-gas deposits in states with fracking moratoria, they should at least be fairly compensated for the economic opportunity taken from them as other states' gas passes through their lands. (WSJ, 4/12/2013)
Electricity Lines: Underground or Overhead?
"Should Utilities Be Required to Bury Power Lines to Protect Them?"
The Wall Street Journal
4/12/2013
Millions of homes and businesses in Connecticut, New Jersey and New York were left in the dark for weeks after superstorm Sandy ravaged the area in October, prompting renewed questions about whether utilities should be forced to relocate power lines underground to keep them safer.
Logical? Yes. But also very costly.
Those who favor power-line burial say it's worth the expense. They believe climate change is going to bring bigger and more violent storms to the U.S., and they say our cities can't afford to be without power for weeks on end. If we don't demand underground power, they say, we'll never get it.
Opponents argue that there are easier and more cost-effective ways to prevent blackouts from storms.
They believe decisions about burying power lines should be made on a case-by-case basis by utilities and regulators. Otherwise, they say, consumers could end up paying more without getting a commensurate increase in reliability.
Roger Anderson argues in favor of requiring utilities to put power lines underground. He is senior research scientist at the Center for Computational Learning Systems of the Fu Foundation School of Engineering and Applied Science, and at the Lamont-Doherty Earth Observatory of the Earth Institute, both at Columbia University in New York. Making the opposing case is Theodore J. Kury, director of energy studies at the University of Florida's Public Utility Research Center.
Yes: It May Be Costly, but Not As Costly as Business as Usual
By Roger AndersonThe reason is always the same: cost. Utilities quote the same economic analyses year after year, in state after state, that say relocating power lines underground to make them less vulnerable to damage would be far too expensive for their customers—who ultimately pay the entire cost of restoration of electric service. Yet, most of these economic models don't take into account the cost to those same customers of lost business, lost property, lost lives from prolonged blackouts after bad storms. Sandy left more than 8.5 million customers without power in 16 states.
The truth is, most of the outages—and a lot of misery—that occurred after Sandy could have been avoided if more power lines had been underground.
An Integrated Solution
After the great blizzard of 1888 destroyed the maze of wires above Manhattan, the lines were relocated underground—and at great cost at the time of that decision. Just like that, blackouts plummeted. Today, the reliability of the utility that serves that area, Consolidated Edison Co. of New York, is estimated to be 10 times the national average.
Granted, moving power lines underground won't protect them from all threats. That's why power-line burial needs to be part of an integrated solution that includes the construction, wherever possible, of sea walls and subway flood gates. Keeping trees trimmed and using electrical poles made of stronger material are good steps to take in the interim, but they aren't a long-term solution to preventing storm-related blackouts.
My challenge to all of those arguing that it is too costly to bury power lines and that underground infrastructure is too difficult to repair: How long did it take to return underground power after Sandy (about three days or so in most cases) versus overhead power (two to 12 weeks and more in some places)? Clearly, the reduced accessibility of underground lines hasn't stopped crews from completing repairs quickly in past storms in New York City.
Stakes Are High
Many scientists are predicting that climate change will bring more frequent and ferocious storms to our shores.
Yet with the exception of Con Ed—which is proposing to bury more power lines—most electric utilities aren't considering upgrading their above-ground technologies much beyond smarter meters. Historically, utilities have been late to new technologies, even those that their suppliers champion. General Electric Co. and Siemens AG (the old Westinghouse) were leaders in adopting lean management, smart systems, integrated solutions and machine learning, technologies that have only just arrived in the utility world. So it is natural that if we leave power-line burial decisions to local utilities, same-old, same-old will dominate.
We must demand underground power and other climate-proof infrastructure nationwide. The price to our national economic well-being of business as usual is too high.
Dr. Anderson is senior research scientist at the Center for Computational Learning Systems of the Fu Foundation School of Engineering and Applied Science, and at the Lamont-Doherty Earth Observatory of the Earth Institute, both at Columbia University in New York City. He can be reached at reports@wsj.com.
No: Too Often, It Would Be a Waste of Consumers' Dollars
By Theodore J. Kury
There are two major reasons why moving electrical wires underground isn't the panacea many people think it is.
Costs vs. Benefits
First, it is a significant capital expense. A rule of thumb is roughly $1 million per mile, but the particular geography or population density of an area can halve this cost or triple it. Since this is an investment that must be repaid by electricity consumers, it is crucial that they receive an increase in the quality of service commensurate with the cost. The utility and its regulator are staffed with professionals trained to make that kind of assessment.
In 2003, the state regulator and electric utilities in North Carolina looked into relocating the state's power lines underground and concluded that it would take 25 years and increase electricity prices by 125%. All parties agreed that the consumer wouldn't receive fair value for that price increase, and the project was scrapped.
A 2010 study of a portion of the District of Columbia's electricity system for the Public Service Commission reviewed 16 reports from eight states that studied "undergrounding" from 2000 to 2009. None of those reports identified a quantifiable net benefit from relocating existing power lines systemwide. The study also found that the marginal costs of moving parts of D.C.'s system underground varied widely. It concluded that a strategic $1.1 billion investment (in 2006 dollars) could improve the reliability for 65% of the customers in the project area, but an additional $4.7 billion would be needed for the remaining 35% to see any benefit.
If the marginal value that a customer receives for increased reliability is less than the marginal cost required to increase reliability for that customer, then a systemwide relocation of lines would likely lead to wasted resources.
A good cost-benefit analysis should factor in the customer cost of outages, and the ones I cite do. They also must take into account that moving electrical lines underground makes routine maintenance of the system more difficult, and thus more expensive. Further, the reduced accessibility can make it more difficult to fix outages when they do occur, often prolonging their duration. This may not have been the case after superstorm Sandy, since other factors play into repair times, but it is the case on average, all else being equal.
Shifting the Risk
Second, moving power lines underground doesn't necessarily make them less vulnerable to storms. Those who support power-line burial because they believe bigger, more frequent storms are inevitable due to climate change need to keep this in mind.
Relocating power lines may mitigate some damage from wind events, principally flying debris and falling trees, but there are other things utilities can do to accomplish that. Tree trimming and replacing traditional wood poles with steel, concrete or composite ones, or reinforcing existing poles with guy wires, may be nearly as effective as moving infrastructure underground, but at a fraction of the cost. Further, burying power lines increases the risk of damage from corrosive storm surge and flooding, so in areas where that is a concern, customers may actually experience more outages if electrical infrastructure is underground.
Let local-distribution utilities and their regulators make power-line burial decisions on a case-by-case basis. Otherwise, electricity consumers could end up paying more and getting less.
Mr. Kury is director of energy studies at the University of Florida's Public Utility Research Center. He can be reached at reports@wsj.com.
Saturday, April 13, 2013
EPA Delaying GHG Rule
EPA is delaying the rule for greenhouse gas limits on new power plants. EPA claims they are still reviewing more than 2 million comments on its proposal. The rule, which the EPA proposed a year ago, would require any new power plant to emit no more than 1,000 pounds of carbon dioxide per megawatt hour of electricity produced. The average U.S. natural gas plant, which emits 800 to 850 pounds of carbon dioxide per megawatt, meets that standard; coal plants emit an average of 1,768 pounds of carbon dioxide per megawatt.
Some utilities have objected to the restrictions, complaining that even some natural gas plants will not be able to meet the new standards easily.
EPA will start working on a rule for existing plants sometime in fiscal year 2014. (Wash Post, 4/12/2013)
Some utilities have objected to the restrictions, complaining that even some natural gas plants will not be able to meet the new standards easily.
EPA will start working on a rule for existing plants sometime in fiscal year 2014. (Wash Post, 4/12/2013)
Friday, April 12, 2013
CEO Salaries: EEI & U.S. Chamber of Commerce
Tom Kuhn, left, president of the Edison Electric Institute gets $6,736,627 a year, according to CEO Update’s survey.
Tom Donohue, right, president and CEO of the U.S. Chamber of Commerce, receives $4,916,571. (Wash Post, 4/11/2013)
Tom Donohue, right, president and CEO of the U.S. Chamber of Commerce, receives $4,916,571. (Wash Post, 4/11/2013)
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