I finally got around to reading the comments submitted by utilities to
DEP's request for input on their CPP feasibility study and SIP. Here are
some notes. These documents are posted at:
.http://www.eenews.net/stories/1060030942
In summary, everyone agrees that WV should seek a 2-year extension, and
utilities see trading emissions credits as the main way to comply, unless
HB 2004 is amended.
Note: It appears the utilities got the input request Aug. 18, with
supplemental request Sept. 18. Comments were filed Nov. 6. That may
explain the timing of Patton's remarks last fall. Our letter from DEP was
dated Oct. 7, so they got a two-month head start.
*AEP*
AEP says that a SIP is not feasible under HB 2004 because "may' is
interpreted to mean "may only" consider inside the fence controls, etc.
The only option is to trade ERCs with other states. But 22-5-18 which
authorizes trading is limited to criteria pollutants and would not
authorize a trading program for CO2.
Existing statutes, 22-5-4(a)(15) and (16), limit ability of DEP to require
monitoring of EE or renewables on homeowners.
AEP says they cannot give specific details on costs without knowing what
will be required from DEP.
AEP says none of their units (Amos, Mitchell or Mountaineer) will retire
before 2030 deadline for the CPP.
Recommends changes to HB 2004 and prefers a SIP to a FIP.
*FE*:
FE cites Texas study to say rates will increase, but has no WV-specific
information.
FE cites NY study that higher electric rates negatively affect health of
low-income populations (Children's Health Watch, "The Impacts of Increasing
Household Energy Prices on Health and Health Care Cost in New York State,"
May 2013. )
FE says costs cannot be predicted until state rules have been established.
FE (and AEP) says many plants have shifted from base-load operation to
:"load-following" which adversely affects heat rate.
FE says their pants typically have a 70-year lifespan. (But Hatfields Ferry
closed at 43 years old, Albright and Willow Island closed at 63). FE
currently operates Pleasants, Harrison and Fort Martin plants in WV
(currently 35-45 years old).
FE says the emissions rates are not feasible, but WV should seek an
extension to 2018.
*Dominion*
Operates Mount Storm plant.(3 units- 42-50 years old)
Says HB 2004 precludes outside the fence controls. Would need to rely on
ERCs from trading. Increasing costs and lower utilization increases
likelihood of plant closings. Closings will lead to higher "Capacity"
costs.
Recommends trading with other states and multi-year averaging of emissions.
WV should allow fuel switching etc.
*Longview*
Currently operates newest and lowest heat rate of any WV plant (8700
btu/kwh). Would need to acquire ERCs to keep operating. Recommends they
be allocated to EGUs "without cost".
Since Longview transports coal via conveyor belt, not trucks, that )house
load" electricity would count against its calculated generation and point
of transmission,effectively penalizing Longview for avoiding impacts of
truck traffic.
No comments on limits of HB 2004, or on preference for SIP versus FIP.
*UMWA (Cecil Roberts)*
Recommends DEP seek 2-year extension and avoid a FIP.
Recommends state use bonding authority through PEA to create new base-load
gas-coal co-fired plants. Also wants legislation to assure cost recovery
for developers.
Prefers mass-based approach to take advantage of coal plant retirements
since 2012.. Recommends "in-state" trading and renewables to meet targets.
Says HB 2004 imposes "constraints" on fuel switching, etc.
Says legislature should beef up EE programs for utilities.
Says the endangerment finding means a lower carbon future regardless of
which party wins the White House.
*Dept. of Commerce (Keith Burdette)*
Developers are bringing gas plants on-line that will meet CPP standards.
But America will need WV's existing base load power for the foreseeable
future.
Estimates that compliance will reduce WV generating capacity by 4200 MW and
cost 435 power plant job and 3770 mining jobs.
Low electric rates is one of the advantages WV has to recruit new industry.
Recommends allowances be allocated to EGUs based on current generation.
Recommends using credits form CEI program and EE from Low Income EE
programs. Rate increases will incentivize EE and RE.
Recommends using forests for carbon mitigation. Existing forests take up 10
% of CO2 emitted, and SIP should take advantage of this.
*Attorney General Morrisey*
WV should seek 2-year extension, "under protest" as CPP is unlawful.
Repeated their legal objections.
Jim Kotcon