Reliability versus sustainability: Inside the debate over the EPA’s proposed carbon rules

Amid the turmoil, the US Environmental Protection Agency earlier this year dropped a proposal to try again to regulate carbon from power plants, which are responsible for about a quarter of all US greenhouse gas emissions.

Since they were introduced in May, the proposed rules have been a lightning rod for Republicans in Congress, drawing criticism from competitive power generation companies, as well as concerns from federal and state energy regulators and grid operators that the regulations go too far, too quickly.

But the EPA and clean energy advocates say the timeframes are workable and critical for cutting carbon emissions while allowing time for compliance and the flexibility needed to keep the lights on during the transition.

What is the EPA proposing?

The EPA draft rule creates different emissions targets for gas and coal plants depending on their planned retirement date and capacity factors, a measure of how much energy a plant produces over time compared to how much energy it would have produced at full operation.

“We have committed to designing and implementing regulations to serve the public’s dual needs of healthy air quality and reliable, affordable electricity,” Joseph Goffman, EPA’s principal deputy administrator, said at a Nov. 9 FERC technical conference on electric reliability. “These emissions are helping to fuel the escalating climate crisis that is already having devastating effects on Americans across the country.”

The general approach, according to Carrie Jencks, executive director of the Environmental and Energy Law Program at Harvard Law School, is to require more stringent action to be taken by coal and gas units that do not plan to retire in the near term and that operate with higher capacity factors. Carbon reductions.

“If you work a lot, a lot throughout the year, really frequently, you should be doing more to reduce your emissions from those plants,” Jenks said at a press conference organized by Energy Innovation, a nonpartisan energy and climate policy organization. It works either as peak or intermediate, i.e. not all the time, there are different options available for those stations,” said the think-tank.

For example, for a coal-fired plant that intends to operate after 2040, the EPA suggests that the facility would need to capture 90% of its carbon emissions by 2030.

For a plant that will be retired by 2040, its emissions rate is based on burning natural gas at a rate of 40%. A coal unit that plans to retire by 2035 could agree to operate at 20% capacity and not be bound by any new carbon restrictions, Jenks said. If he retires before 2032, he can work as is.

“2030 is really the decision point for units on how they plan to operate in the future,” Jencks said, noting that the exact limits and standards could change in response to feedback the EPA receives. There are similar requirements for gas plants (although they differ slightly between new and existing plants) to either blend with hydrogen to reduce emissions or capture emissions depending on whether they are base load (above 50% capacity factor) or so-called “peaking” plants.” Which ignite during periods of high demand.

However, the EPA’s reliance on carbon capture and storage as well as hydrogen blending has drawn much criticism, mainly because both sets of technologies are still relatively in their infancy and have not yet been deployed on any scale.

Anthony Campbell, president and CEO of East Kentucky Power Cooperative, speaking on behalf of the National Rural Electric Cooperative, said the EPA rule is “illegal and unenforceable” at the FERC technical conference. Under the proposed rule, the EPA is scheduled to have plans in place by 2026, making it impossible for plant operators to make compliance decisions given the uncertainty surrounding carbon capture and hydrogen production, Campbell said.

“They will have to either retire core dispatchable coal units or reduce those to capacity factors of less than 20% by 2032 and fully retire by 2035,” Campbell said. “Disorderly retirement and elimination of base load generation will leave the power grid with a significant deficit of dispatchable generation that cannot be replaced with intermittent resources, especially during a period of economic growth.”

“Accounts don’t work”

Discussions about electrical reliability can get complicated. But the fundamental problem facing America’s electric grid is as simple as two lines on a graph, FCC Commissioner Mark Christie, a former Virginia utility regulator, said at a Nov. 9 technical conference on reliability. The first is the demand for power.

“That line is going to go up,” Christie said. “It could go up astronomically if ‘electrification of everything’ happens – electrification of the transport sector, electrification of the home heating sector.”

The other line is the power supply.

“And that line is not going to go up, or it certainly won’t go up nearly as quickly,” he said. “The account is not working. This is the main issue.”

According to the Alliance of Clean Energy States, a coalition of state energy agencies, 23 states, plus the District of Columbia and Puerto Rico, have 100% clean energy goals. Coupled with federal policy such as the historic Inflation Reduction Act, and market conditions, utilities, many of which have their own decarbonization goals, are being urged to retire older coal and gas plants.

(At Thursday’s FERC meeting, Christie warned that two of the nation’s largest regional carriers, MISO and PJM, are “essentially depleting dispatchable resources.”)

Jim Robb, president and CEO of the North American Electric Reliability Corporation — which first began listing “energy politics” as a risk to reliability — told panelists at the Reliability Conference that expanding so-called inverter dependence introduces resources like wind, solar and batteries New diversity in grid management, especially as it becomes a larger part of the energy mix.

“This country has not proven that it can develop the infrastructure to support that,” Robb said. “We’re going to need to figure out how to build transmission, we’re going to have to figure out how to accelerate the development of new resources on the grid, and most importantly we need to figure out how to keep the stuff we have going to have to achieve any of these policy goals.”

Goffman, the EPA official, said the agency is committed to continuing to work with regulators and grid operators “over the coming weeks and months so that we can ensure we reach a final rule to reduce greenhouse gas emissions from power plants that is effective and enforceable.” And fully compatible to maintain reliable and affordable electricity.

“Completely reliable network”

Rick O’Connell, executive director of GridLab, which he described as a public interest organization that provides technical expertise on the electric grid to policymakers, told the FERC conference that the EPA’s rules and reliability assurance are compatible.

“The grid is certainly reliable under the proposed EPA rules, but we will need to plan and take action,” he said, adding that the rules codify “what actually happens because of economic and political forces.” He noted that 2 terawatts (2 million megawatts) of energy resources, mostly wind, solar and battery resources, are stuck in interconnection queues across the country.

At a press conference hosted by Energy Innovation, O’Connell said there is a “tremendous wealth of academic and industry literature” that shows the way to dramatically reduce carbon from the energy sector over the next decade.

“We do this with a very simple playbook. It spreads wind, solar and batteries over the next decade,” he said. O’Connell added that along with maintaining carbon-neutral sources such as hydropower and nuclear plants and using existing gas fleets at low levels to provide Critical balancing services required by large amounts of renewable energy sources.

He pointed out that the UK went from 71% of its energy relying on coal in 1990 to less than 1% this year, and that electrical grids in California and New England are already largely coal-free. Even Texas is “on its way to looking like this, too,” he noted. MISO forecasts envision a similar network being created, with natural gas plants operating at very low capacity by 2040, he noted.

“Can we run our grid without coal? The simple answer is yes.”