Legalectric

Where to start… in addition to just one day’s notice, look at the presenters, skewed towards “Coal on the Wires” where they can explain how it’s all about wind, an important concept as we consider what these EPA regulations mean.  From this vantage point, it’s my understanding that with the new regulations, it might have an impact of maybe 7% decrease in use of coal for electrical generation.  Bears more review.

Here are the EPA regs they’ll be talking about, and it’s open for Comment until some time n September:

Proposed power plant regulations

Clean Power Plan Proposed Rule – June 2, 2014

Proposed Carbon Pollution Standards for Modified and Reconstructed Power Plants – June 2, 2014

TOMORROW, at the EQB (click for larger version):

From the looks of it, it sure looks like more of a “talking session” to me.  And note those last three!

Brad Crabtree, Great Plains Institute

Scott Wilensky, Xcel Energy

Eric Olsen, Great River Energy

All promoters of transmission, “Coal on the Wires,” otherwise known as CapX 2020 plus.  Here’s CapX 2020, look at those North Dakota references:

And the map, again, look where it starts:

Add this:

And the MISO Multi-Value Project list of 17 transmission projects:

And folks, with all that transmission, here in the Midwest, we’re most of the way to JSCP:

As Xcel’s Tim Carlsgaard argued the other day, there are no plans for new coal… Well, when CapX 2020 was at the PUC for the Certificate of Need, MISO’s Jeff Webb testified that there was 3,441 of new coal in ND, SD, IA and MN in the MISO queue (and over 7,000 MW of wind in the Illinois queue).  And we know that transmission for coal pays, and oh, how it pays:

ICF-IndependentAssessmentMISOBenefits

But that’s different now… OH?  How so?  Because it’s not different.  It’s “Coal on the Wires.”

First, there’s no talk of closing the coal plants in the area where CapX 2020 transmission starts.  Minnesota Power did buy a transmission line and will convert it to wind, but what will happen to the coal on that line:

Oh, right, CapX 2020 will be up and running by then.  And after all, additional transmission for coal has been in the works for a long, long time, well over the 15 years that I know of:

Lignite Vision 21 Transmission Study

You can see how the “new” CapX 2020, JCSP, and MISO MVP plans have built on the foundation of Lignite Vision 21 and WRAO/WIREs.  Yea, but that’s still old news.  Sure, but there’s a lot to be said about learning from history.  And then there’s this matter of trajectory, we can see where this is going.

As I noted on No CapX2020 not long ago, here’s what’s up with coal right now:

• Not one North Dakota coal plant has been shut down.
• Minnesota Power has purchased the “coal line” coming from North Dakota into Northern Minnesota, and once CapX 2020 is up and running at the western end, they’ll put that coal generation on CapX.
• Read the federal judge’s decision on the Next Generation Energy Act, declaring it unconstitutional.  First, the decision notes that the Dry Fork coal plant has been moved from the West into the Eastern Interconnect (it’s “new coal” now on transmission heading our way that wasn’t coming here before).
• Also in that decision, it discusses plans for a new coal fired plant in South Dakota.
• And also the potential for an additional unit at Dry Fork, which is now in Eastern Interconnect (coming our way).
• AND it discusses the surplus at Milton Young, which would be exacerbated by transmission prohibitions of the Next Generation Energy Act.

What else is planned?  Let’s all start looking, particularly since the federal judge’s decision on the Next Generation Energy Act.

Don’t forget that there is not one single Renewable Energy Standard/Mandate that requires any coal be shut down.  It only requires addition of “renewable” generation.  Think about that.  If we shut down the coal, for instance the North Dakota coal where CapX starts, there would be plenty of transmission capacity for wind and the back up gas or hydro to firm it up.  DOH!  So if the enviros and those supporting RES across the country are serious about stopping coal, why aren’t they including requirements to shut down coal, and why are they promoting transmission?  It doesn’t reduce emissions, doesn’t reduce CO2 or anything else, it just adds wind generation on top of an admitted surplus.  Why support and promote transmission, and not require shut down of coal?  Well, they are getting paid to support and promote transmission.

And speaking of Great Plains Institute…. GPI has long been trying, as Bill Grant did, to “find a way forward for coal” (Walton’s Bill Grant and “low carbon coal”).  Remember Great Plains and all they did for money on coal gasification?  Here’s just a bit of it:

Great Plains Institute for Sustainable Development
To support the efforts of its Coal Gasification Working Group.
Minneapolis, MN $437,500
21 mos. 2006

Great Plains Institute for Sustainable Development Inc.
To brief Midwest lawmakers and regulators about how advanced coal technologies are currently deployed in Europe and encourage their support for similar adoption here.
Minneapolis, MN $99,400
1 yr. 2007

Here’s more:

IGCC toadies in Pierre, SD

And speaking of the EPA, here’s a settlement where they caved in exclusion of coal gasification as BACT (DOH, how could it be when it’s not happening?  The EPA was right, and the IGCC toadies pushed for inclusion of coal gasification and got this settlement, and how much money was attached to that?  Furthering the IGCC: Pipedreams of Clean and Green is not in anyone’s interest.):

EPA Settlement re: IGCC – Coal Gasification

The proposed settlement involves an EPA pronouncement last year that pointedly excluded mere consideration of advanced coal gasification technology or Integrated Gasification Combined Cycle (IGCC) as “best available control technology” for a proposed new coal plant. IGCC plants gasify coal and then burn the gas to produce electricity. The Clean Air Act calls for proposed new coal plants to use the “best available control technology” including available methods to maximize pollution reductions. In addition to Environmental Defense, the Montana Environmental Information Center and several other organizations are parties to the proposed settlement, which must undergo public notice and comment before it is finalized.

We must remember history and hopefully not repeat it.  There’s the established history of transmission planning for coal, and there’s the established history of “environmental” NGOs supporting coal gasification and transmission for money.  As they discuss these new EPA regulations and the potential impact, remember that they put their mouth where their money is.

Meanwhile, about those Comments to the EPA?  Again, here’s what’s at issue:

Proposed power plant regulations

Clean Power Plan Proposed Rule – June 2, 2014

Proposed Carbon Pollution Standards for Modified and Reconstructed Power Plants – June 2, 2014

And read Charlie Komanoff’s views:

Next to Nothing for Climate in Obama Plan

How to file Comments?  From the fed website, the pre-publication version I have doesn’t state the deadline, but it’s September sometime:

Submit your comments, identified by DocketID No. EPA-HQ-OAR-2013-0602, by one of the following methods:

• Federal eRulemaking portal: http://www.regulations.gov

• Email: A-and-R-Docket@epa.gov. Include docket ID No. EPA-HQ-OAR-2013-0602 in the subject line of the message.

• Facsimile: (202) 566-9744. Include docket ID No. EPA-HQ-OAR-2013-0602 on the cover page.

• Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mail code 28221T, Attn: Docket ID No. EPA-HQ-OAR-2013-0602, 1200 Pennsylvania Ave., NW, Washington, DC 20460. In addition, please mail a copy of your comments on the information collection provisions to the Office of Information and Regulatory Affairs, OMB, Attn: Desk Officer for the EPA, 725 17th St. NW, Washington, DC 20503.