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Environmental 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
Topics 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?
Pollutant 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
Health Effects of
             Exposure to Ozone
 Coughing
 Nose, and throat irritation
 Chest pain
 Reduced lung function
 Increased susceptibility to respiratory illnesses
 Aggravation of asthma
 Children and people with chronic lung diseases
  are particularly at risk
Health Effects of Exposure
          to Fine Particles
 Premature death
 Respiratory related hospital admissions and emergency
  room visits for cardiac and other conditions
 Aggravated asthma
 Acute respiratory symptoms
 Chronic bronchitis
 Decreased lung function (shortness of breath)
 People with existing heart and lung disease, as well as
  the elderly and children, are particularly at risk
Fine particles, or haze, impairs
                        health and visibility

                                               Hourly conc. of
The Boston
                                               fine particles in
skyline on a
                                               the 9-11 袖g/m3
clear day
(Jan. 12, 2001)                                range




The Boston                                     Hourly conc. of
skyline on a                                   fine particles
hazy day                                       55.4 袖g/m3
(March 8, 2001)
CO2 emissions contribute to global climate change 
which is projected to have serious and wide-ranging
  impacts on human health and the environment
Mercury 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
Air 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
Ozone: Downward Trend for Both
Old 1-Hr and New 8-Hr Standards
SO2 Emissions From New
       England Power Plants
45 0000
400000
35 0000
300000
2 5 0000
2 00000
1 5 0000
1 00000
 5 0000
      0
           1 980   1 990             1 995   2 000

                           Y ear s
NOX Emissions From
      New England Power Plants
1 60000

1 40000
1 2 0000
1 00000
 80000

 60000
 40000
 2 0000
      0
           1 990   1 995    2 000

                   Y ears
Improvement in U.S. New Car Emission Standards,
                                            1965 - 2005
Composite Relative Emissions
 of a New Light-Duty Vehicle




                               25

                               20

                               15

                               10

                                5

                                0
                                1965   1970   1975   1980   1985   1990   1995   2000   2005

                                                      Source: NESCAUM
Outlook: 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
Fine Particles are a Significant
Problem in California and in the East
                 1999-2001 Annual Mean PM 2.5
                   Preliminary Estimates Without Consideration of Data Completeness
                                       (Data from AQS - 4/5/02)




                                                                                                  Virgin
                                                                                                 Islands




        Alaska       Hawaii                                                        Puerto Rico
                      well above the level of the standard
                      at or above the level of the standard
                      approaching the level of the standard
                                                              EPA
                                                              Terence FitzSimons
                                                                   AQTAG
                       well above the level of the standard
Areas Recommended by the States as
Not Meeting EPAs Ozone Standard




                  Based on 1997-1999 ozone data
Timeline 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?
測   ISO NE projects peak electricity demand to increase
    by 13-20+% in 2009-2015
Prognosis 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
How 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
SIP  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
A State Implementation Plan
Whats in a SIP
   Plans
   Commitments
   Regulations
   Letters and Attestations
   Administrative Documentation
   Technical Support and Background
    Documentation
Considering Control Strategies
 Review Emission Inventory
 Review available Control Technologies
 Provide costs (for regulated community,
  for state)
 Determine Effectiveness of Controls and
  Programs
What is distributed generation
    and why is it growing?
 Distributed Generation (DG) is electric generation
  on site
    < 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
DG 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
But, 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
Diesel IC engines are far worse
       polluters than new gas plants
 3           SO2             NOx           CO2               Mercury
         (10 lbs/ MWh)    (10 lbs/ MWh)   (tons/ MWh)       (0.0000001 lbs/ MWh)


2.5


 2


1.5


 1


0.5


 0
      Conventional Coal          Diesel Engine          Modern Gas Plant
           Plant
Even 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)
90
80
70
60
50
40                                                                                     tons/day
30
20
10
 0
     200MW x           200MW x         450 MW x         900 MW x OTC Budget
       2 hrs             24 hrs          12 hrs           12 hrs
                                                                              Source: Chris James, CT DEP
 (post-contingency)                    (price-driven)   (price-driven)
                   (capacity shortfall)
Some 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
Regulations 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
Permitting Requirements - MA
 No permit required < 3 MMBtu/hr fuel
  input - 300 kw
 > 3 MMBtu/hr fuel input - best available
  control technology (BACT)
 Emergency engine limits
 See 310 CMR 7.02, 7.03
Permitting Requirements - CT
 General permit language for emergency
  engines - valid until 12/03
   units > 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
States 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
Bottom 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
How 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
Simultaneous 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.

More Related Content

Nedri enviro presentation-15jul02

  • 1. Environmental 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
  • 2. Topics 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?
  • 3. Pollutant 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
  • 4. Health Effects of Exposure to Ozone Coughing Nose, and throat irritation Chest pain Reduced lung function Increased susceptibility to respiratory illnesses Aggravation of asthma Children and people with chronic lung diseases are particularly at risk
  • 5. Health Effects of Exposure to Fine Particles Premature death Respiratory related hospital admissions and emergency room visits for cardiac and other conditions Aggravated asthma Acute respiratory symptoms Chronic bronchitis Decreased lung function (shortness of breath) People with existing heart and lung disease, as well as the elderly and children, are particularly at risk
  • 6. Fine particles, or haze, impairs health and visibility Hourly conc. of The Boston fine particles in skyline on a the 9-11 袖g/m3 clear day (Jan. 12, 2001) range The Boston Hourly conc. of skyline on a fine particles hazy day 55.4 袖g/m3 (March 8, 2001)
  • 7. CO2 emissions contribute to global climate change which is projected to have serious and wide-ranging impacts on human health and the environment
  • 8. Mercury 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
  • 9. Air 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
  • 10. Ozone: Downward Trend for Both Old 1-Hr and New 8-Hr Standards
  • 11. SO2 Emissions From New England Power Plants 45 0000 400000 35 0000 300000 2 5 0000 2 00000 1 5 0000 1 00000 5 0000 0 1 980 1 990 1 995 2 000 Y ear s
  • 12. NOX Emissions From New England Power Plants 1 60000 1 40000 1 2 0000 1 00000 80000 60000 40000 2 0000 0 1 990 1 995 2 000 Y ears
  • 13. Improvement in U.S. New Car Emission Standards, 1965 - 2005 Composite Relative Emissions of a New Light-Duty Vehicle 25 20 15 10 5 0 1965 1970 1975 1980 1985 1990 1995 2000 2005 Source: NESCAUM
  • 14. Outlook: 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
  • 15. Fine Particles are a Significant Problem in California and in the East 1999-2001 Annual Mean PM 2.5 Preliminary Estimates Without Consideration of Data Completeness (Data from AQS - 4/5/02) Virgin Islands Alaska Hawaii Puerto Rico well above the level of the standard at or above the level of the standard approaching the level of the standard EPA Terence FitzSimons AQTAG well above the level of the standard
  • 16. Areas Recommended by the States as Not Meeting EPAs Ozone Standard Based on 1997-1999 ozone data
  • 17. Timeline 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? 測 ISO NE projects peak electricity demand to increase by 13-20+% in 2009-2015
  • 18. Prognosis 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
  • 19. How 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
  • 20. SIP 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
  • 22. Whats in a SIP Plans Commitments Regulations Letters and Attestations Administrative Documentation Technical Support and Background Documentation
  • 23. Considering Control Strategies Review Emission Inventory Review available Control Technologies Provide costs (for regulated community, for state) Determine Effectiveness of Controls and Programs
  • 24. What is distributed generation and why is it growing? Distributed Generation (DG) is electric generation on site < 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
  • 25. DG 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
  • 26. But, 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
  • 27. Diesel IC engines are far worse polluters than new gas plants 3 SO2 NOx CO2 Mercury (10 lbs/ MWh) (10 lbs/ MWh) (tons/ MWh) (0.0000001 lbs/ MWh) 2.5 2 1.5 1 0.5 0 Conventional Coal Diesel Engine Modern Gas Plant Plant
  • 28. Even 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) 90 80 70 60 50 40 tons/day 30 20 10 0 200MW x 200MW x 450 MW x 900 MW x OTC Budget 2 hrs 24 hrs 12 hrs 12 hrs Source: Chris James, CT DEP (post-contingency) (price-driven) (price-driven) (capacity shortfall)
  • 29. Some 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
  • 30. Regulations 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
  • 31. Permitting Requirements - MA No permit required < 3 MMBtu/hr fuel input - 300 kw > 3 MMBtu/hr fuel input - best available control technology (BACT) Emergency engine limits See 310 CMR 7.02, 7.03
  • 32. Permitting Requirements - CT General permit language for emergency engines - valid until 12/03 units > 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
  • 33. States 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
  • 34. Bottom 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
  • 35. How 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
  • 36. Simultaneous 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.

Editor's Notes

  • #8: The climate is currently changing, and larger changes are expected. Temperatures and sea level are rising, and precipitation patterns are changing. The US National Assessment of the Consequences of Climate Change for the United States determined that climate change will result in significant impacts on health, agriculture, forests, water resources, coastal areas, species and natural habitats. Impacts in each of these sectors have implications for EPA water programs.
  • #16: This map is based on monitors operated since the first quarter of 2000 and meet 1-year (2000) completeness goals.
  • #19: NH = 2 nd in High Tech Employment NH is the only state among the Top 10 fastest growing that is not in the South or West. (NHPR, 12-20-01) Intel example: Bash Climate =&gt; Bash Intel