Title: Environmental Issues in Electricity Demand Response
1Environmental Issues in Electricity Demand
Response
New England Demand Response Initiative July 17,
2002, Holyoke, MA
- Nancy L. Seidman
- Massachusetts Dept of Environmental Protection
- Bill White
- U.S. Environmental Protection Agency, Region 1
- Ken Colburn
- Northeast States for Coordinated Air Use
Management
2Topics to Cover
- Background
- Pollutants of concern and their impacts
- Progress to date
- Remaining Environmental Challenges
- Regulatory outlook and timeline
- Regulatory framework state and federal
permitting - Distributed generation
- EconomyEnvironment Convergence?
3Pollutant of Concern and Regulatory Standards
- 7 federal (US-EPA) public health standards
- four important for power generation
- SO2, NOx, CO and PM2.5
- Ozone and PM2.5
- levels and trends
- next steps in federal programs
- next steps in state programs
- CO2 and Hg - emerging issues
4Health Effects of Exposure to Ozone
- Nose, and throat irritation
- Increased susceptibility to respiratory illnesses
- Children and people with chronic lung diseases
are particularly at risk
5Health Effects of Exposure to Fine Particles
- Respiratory related hospital admissions and
emergency room visits for cardiac and other
conditions
- Acute respiratory symptoms
- Decreased lung function (shortness of breath)
- People with existing heart and lung disease, as
well as the elderly and children, are
particularly at risk
6Fine particles, or haze, impairs health and
visibility
7CO2 emissions contribute to global climate change
which is projected to have serious and
wide-ranging impacts on human health and the
environment
8Mercury poses serious risks to human health and
the environment
- Mercury bioaccumulates concentrates in fish
and animals that eat them including humans - 41 states now have mercury-based health
advisories for fresh-water fish, including all
New England states - High dose exposures can cause serious
neurological and developmental effects - Mental retardation, limb deformities
- Blindness, cerebral palsey, seizures
- Low dose exposures can cause
- Adverse developmental effects on attention,
fine-motor functions, visual-spatial abilities
and verbal memory - Other possible effects carcinogen, heart
disease, adult immune system, and reproductive
system
9Air Programs Have Made Great Progress
- Automobile tailpipe, inspection maintenance,
and cleaner gasoline programs - VOC NOx control requirements for industry
- Power plant control strategies
- Acid rain program SO2 and NOx
- NOx RACT in 1995
- OTCs NOx budget program -- 1999 and 2003 caps
- Section 126 petitions and NOx - - SIP call
reductions in 2004 - State multi-pollutant power plant programs MA,
CT and NH
10Ozone Downward Trend for Both Old 1-Hr and New
8-Hr Standards
11SO2 Emissions From New England Power Plants
12NOX Emissions From New England Power Plants
13Improvement in U.S. New Car Emission
Standards, 1965 - 2005
Source NESCAUM
14Outlook Environmental Challenges yet to be
Addressed
- Implementation of eight-hour ozone national
ambient air quality standard - Implementation of fine particulate standard and
regional haze program - Acid rain
- Mercury from coal burning
- Greenhouse gas emissions
15Fine Particles are a Significant Problem in
California and in the East
16Areas Recommended by the States as Not Meeting
EPAs Ozone Standard
Based on 1997-1999 ozone data
17Timeline for Implementing New Ozone and PM
Standards
- 2003 EPA finalizes implementation guidance
- 2003-4 States recommend nonattainment
designation and boundaries - 2004-5 EPA finalizes nonattainment
designations and boundaries - 2007-8 States submit control strategy SIPs
- Mercury MACT requirements take effect?
- 2009-15 Attainment deadlines for ozone and PM
- 2015?-18? Requirements for CO2, and additional
- reductions in NOx and SOx?
- ISO NE projects peak electricity demand to
increase by 13-20 in 2009-2015
18Prognosis for Clear Skies / 4-P?
- Key Issues
- Carbon in or out?
- Levels and timetables re-opener
- Allocation approaches (input, output, permanence,
etc.) - Trading constraints?
- Theres a deal here
- Compared to 1990 Clean Air Act Amendments?
- President Much less committed...
- Industry Enviros Much more committed...
- Best Guess
- Clear Skies and S.556 (Jeffords) are DOA in the
Senate - Development of a 3rd Way is underway
- 2003 Session or Someday
19How Does Permitting Work Today?
- State and Federal permitting roles
- Federal rules (large new sources New Source
Review/Prevention of Significant Deterioration) - State delegation other sources
- Federal Air Quality Standards link to permit
limits - For large power plants dispersion modeling used
to determine ground level impact - Differences among states in how small sources are
handled
20SIP State Implementation Plan Links federal
and state efforts
- SIP state implementation plan
- EPA designates areas that dont meet health
standards - SIP state regulations and programs to bring
areas into compliance with federal standards - Some measures are required, others are optional,
i.e. up to each state - Approved by EPA
21A State Implementation Plan
22Whats in a SIP
- Plans
- Commitments
- Regulations
- Letters and Attestations
- Administrative Documentation
- Technical Support and Background Documentation
23Considering Control Strategies
- Review Emission Inventory
- Review available Control Technologies
- Provide costs (for regulated community, for
state) - Determine Effectiveness of Controls and Programs
24What is distributed generation and why is it
growing?
- Distributed Generation (DG) is electric
generation on site - lt 1 MW and up to 10 MW
- DG is growing because
- Need for greater reliability and power quality-
tiny outages can cost millions of dollars - Load/demand response programs pay customers to
shed load - often switching to on-site generators - High electricity prices mean on-site options more
attractive
25DG has the potential to create environmental
benefits by . . .
- Achieving efficiencies of 80 and higher through
Combined Heat and Power (CHP) - Increasing the contribution of low to zero
emissions technologies to power generation - Reducing the need to run older, dirtier reserve
generating plants - Reducing line losses
26But, current DG trends present an environmental
challenge
- Diesel internal combustion (IC) engines make up
more than 90 of existing DG and a similarly
large share of new sales - Diesel IC engines pollute at much higher rates
than new electric generating plants - Even a few hours of operation can have big
impacts on air quality - Regulations need to catch up with market changes
and new technologies
27Diesel IC engines are far worse polluters than
new gas plants
(10 lbs/ MWh) (10 lbs/ MWh)
(tons/ MWh)
(0.0000001 lbs/ MWh)
28Even low levels of DG use can have big impacts on
air quality
Potential Emissions Impact in Connecticut(NOx
tons on a given ozone season day)
Source Chris James, CT DEP
(post-contingency)
(price-driven)
(price-driven)
(capacity shortfall)
29Some evidence that use of and emissions from DG
are rising
- New Hampshire 1996 - 1999
- Share of electric generation ozone season NOx
emissions grew from 3.8 to 14 - nearly a four
fold increase - Total NOx emissions from small diesel IC engines
doubled - from 278 tons to 576 tons - even as
total NOx emissions from all electric generators
were nearly halved, from 7314 tons to 3986 tons
Source Andy Bodnarik, NH DEP
30Regulations did not anticipate todays DG trends
- Most on-site generators are emergency
generators exempted from emissions requirements - Emergency exemption assumed narrowly defined
circumstances for use - emergencies - not load
response or peak shaving - Modification in CA, EPA has no plans to broadly
expand guidance for these units - Many new units fall outside existing state and
federal permitting requirements
31Permitting Requirements - MA
- No permit required lt 3 MMBtu/hr fuel input - 300
kw - gt 3 MMBtu/hr fuel input - best available control
technology (BACT) - Emergency engine limits
- See 310 CMR 7.02, 7.03
32Permitting Requirements - CT
- General permit language for emergency engines -
valid until 12/03 - units gt 500 hp
- Annual tons per year limits - 5 tpy NOx, SOx, 3
tpy PM - Ultra low sulfur fuel required
- SW CT - 52 towns can participate in load response
33States and EPA are taking steps to meet the DG
challenge
- Ozone Transport Commission (OTC) Model Rule
lowers applicability thresholds for DG - EPA and NESCAUM developing inventory of installed
on-site capacity in the Northeast - Connecticut General Permit for Distributed
Generation issued earlier this year - RAP model regulation
34Bottom line DG can be good for the air, as long
as its clean
- Update regulations to capture diesel IC engines
generating electricity - Dont increase use of emergency backup generators
- Level the playing field for clean, efficient DG
by removing regulatory and market barriers and
creating incentives - Clean DG can help add capacity while reducing
emissions
35How Will EPA and States Meet New Air Quality
Challenges?
- Upcoming emission reduction programs
- 2004 automobile tailpipe and clean fuel stds
- 2007 heavy duty diesel standards
- Local emission reduction measures
- E.g., diesel retrofit and low sulfur diesel fuel
programs - Reduction of regional transport from power plant
emissions Clear Skies Initiative
36Simultaneous Economic Growth and Environmental
Improvement
Sources 1970 - 1999 emissions data is from the
National Air Pollutant Emissions Trend Report,
(EPA, March 2000). Projections for SO2 and NOx
are derived from the Integrated Planning Model
(IPM). GDP data through 2000 is from the Bureau
of Economic Analysis, GDP projections follow
EIAs assumptions in AEO 2001 of 3 growth per
year.