Pete Baldwin

We are led to believe that PM2.5 particulate matter from coal-fired power plants will lead to 11,000 (or pick a number) premature deaths, as part of various permitting disputes!

“The original rule required power plants to reduce emissions of mercury and other toxic pollutants by more than 90 percent over five years. Mercury is a neurotoxin that can damage the brain and nervous system in young children, leading to lower I.Q. and impaired motor skills. 

The Obama administration estimated that the measure would prevent 4,700 heart attacks and 130,000 asthma attacks as well as 11,000 premature deaths by also eliminating fine particulate matter linked to those ailments

 Fine inhalable particles, with diameters that are generally 2.5 micrometers and smaller. How small is 2.5 micrometers? Think about a single hair from your head. The average human hair is about 70 micrometers in diameter- making it 30 times larger than the largest fine particle.[/caption]

I’ve often wondered, just how does one go about making such premature death rate projection?

If asked, here’s what I would do. I expect the analysts do something similar.

We have measured and reported primary data on the particulate levels for ⁓50 geographic areas in the U.S.

I also assume we also have primary death and death rates that generally indicate the cause of death.It would be unrealistic to expect that the actual cause of death could or would be identified specifically as PM2.5 particle, or even a bunch of PM2.5 particles, so these must be some sort of average rates.

These death rates can be compared across geographies to search for and explore anomalies. A premature death rate can be determined, based on comparative averages.I suppose that If one dies before the “average age”, within some range, it could be defined as “premature”.

The particulate level measured in any specific location, however, is not differentiated by source

. The data can only be the mixed average of all particulate matter sources in that area. Sensors would not be able to differentiate PM2.5 particulate by source and, of course, that means that power plant emissions are lumped together with diesel exhaust,among others.

I expect that that these undifferentiated particulate measures are then compared to “premature” death rates to render a statistical relationship between the two.

That lead me to ask, “what are the sources of PM2.5 particles?”

The National Emissions Inventory (NEI) is a comprehensive and detailed estimate of air emissions of criteria pollutants, criteria precursors, and hazardous air pollutants from air emissions sources. The NEI is released every three years based primarily upon data provided by State, Local, and Tribal air agencies for sources in their jurisdictions and supplemented by data developed by the US EPA. The NEI is built using the Emissions Inventory System (EIS) first to collect the data from State, Local, and Tribal air agencies and then to blend that data with other data sources.

https://www.epa.gov/air-emissions-inventories/2014-national-emissions-inventory-nei-technical-support-document-tsd

Fuel Combustion by Electric Utilities accounts for less than 3% of the PM2.5 emissions.

Call me “old fashioned”, but I am thinking that maybe we should go after the “Wildfires” and the “Miscellaneous”, which account for 75% of the PM2.5 problem, and quit picking on electric utilities!

Articles

PM2.5: How going after utilities is misinformed

 projects that the U.S. electric power sector emissions of sulfur dioxide (SO

, assuming no changes to current laws and regulations.

 emissions in the U.S. electric power sector have been generally declining since their 2007 peak of 2.4 billion metric tons (mt).”

The Outlook itself offers a few numbers to support its case. I have extracted the specific numbers for CO

 Emissions as I did in November 2018 in a piece entitled “We’re wasting time”

http://www.base-e.net/blog-24-quot;were-wasting-timequot

We’re still wasting time, and the “mostly flat” term seems to be an attempt to put a positive “spin” on the fact that CO

And, the starting point for the commentary remains the 2007 peak period and generates a “feel good” reduction.  But, this is not a “feel good” outcome.

I don’t want to overcomplicate things. Flat is bad….down is good!

The Reference Case numbers are virtually the same as they were in November. Some of the side cases have been moderated, but the reference cases, normally representing the best of the estimates, are virtually unchanged.

And, the impact of the much less talked about Clean Power Plan remains minimal at 259 million metric tonnes (0.259Gt). This projected reduction is only 5% of the Reference Case.

 emissions need to drop to ¼ of where they are currently projected to be on the 2°C trajectory, not flat. (

 per capita improvement as part of its narrative. This narrative argues for emissions increases with economic growth. The only good news here is that the narrative is similar to that of both China and India, suggesting that a common ground for negotiating real reductions might be available, when we get serious.

US carbon emissions likely to remain flat through 2050

They called it “111(b) Revisions to Advance Clean Energy Technology”, but in English it is an EPA-proposed elimination of the implied requirement to deploy CCS on coal plants.

The proposed NSPS-2019 applies to greenhouse gas emissions from new, modified, and reconstructed fossil fuel-fired power plants and by revising its determination of the best system of emission reduction (BSER) for these plants.

This proposal includes four distinct actions based on a revised BSER:

To revise the standards for newly constructed steam units as separate standards for large and small units.

For large units, the proposed emission rate would be 1,900 pounds of CO2 per megawatt-hour on a gross output basis (lb CO2/MWh-gross).

For small units, the proposed emission rate would be 2,000 lb CO2/MWh-gross.

To create separate standards of performance for newly constructed coal refuse-fired units.

Regardless of size, the proposed emission rate would be 2,200 lb CO2/MWh-gross.

To revise the standards for large modifications of steam generating units to be consistent with the standards for large and small newly constructed units.

EPA is also taking comment whether and how to address concerns raised by stakeholders regarding the increased use of simple cycle aeroderivative turbines, including as back-up generation for wind and solar resources, whose operation may exceed the non-base load threshold described in the 2015 rule. Any follow-up regulatory actions would be achieved through a separate and subsequent regulatory proposal.

I authored the following table in 2014 for the original NSPS using the DOE Baseline data. It is not hard to see how the proposed 2019 NSPS set its thresholds. In a word “Unabated” or in modern day jargon, “Whatever!”

Given how things work these days, the EPA will proceed. The question is whether this will induce any public utility to actually commit to build a new coal plant?The NGCC plants are 1/3 the first cost, 30% more efficient and with less of an abatement overhang.

I think not! I don’t see any public utility making such a decision.

One day in the not too distant future, this will all change. We will come to the collective realization that we cannot live without fossil fuels, but to do this, CCS will be required on all new and existing fossil fuel power plants.

This new attempt at rulemaking is just more political theatre!

New source performance standard - 2019

The U.S. Energy Information Agency recently published their estimate of the Power Sector CO

 emissions in 2017 at 1,744 MMmt, claiming a 28% reduction from the 2,416 MMmt in 2005.

The results of their analysis are summarized in the following graphic.

The “applause” that has followed seems artificial.

It is important to understand that the starting point for the policy and the claim is 2005, the highest level in recent times. It is always good to start at the “high point” when claiming percent reductions.

The narrative also offers a projected 2% demand growth scenario of 3,043 MMt CO

in 2017, using the same carbon intensity to assign the impact of three factors, as follows.

The analysis states that the reduction is primarily the result of 

 (25%). The analysis attributes the substitution of natural gas for other fossil fuels as“largely….market driven…(by the) ample supplies of lower-priced natural gas and the relative ease of adding natural gas-fired capacity.”

The “relative ease” comment means that a Natural Gas Combined Cycle (NGCC) power plant can be permitted without abatement. In other words, not having to deal with its CO

 emissions. This concession  has been in place, either implied or explicit, since 2007, when I wrote an op-ed titled “Passing Gas”(

http://www.base-e.net/pulsepro/data/files/Passing%20Gas.pdf

Unfortunately, that same energy projection, the U.S. EIA forecast for U.S. CO

 emissions, remains flat or increases through 2050 at 5,279 MMmt in the Reference Case and as high as 5,814 MMmt in the High Economic Growth Case.

What is not mentioned is that with these “successes” in 2017, the U.S. trajectory is still 4x what is required to meet our contribution toward the 2℃ “goal”, and seems more in line with the 6℃ trajectory.

Other sources indicate that China and India are projecting emissions more in line with the 4℃ trajectories, well ahead of the U.S. efforts. And, the commentary again introduces the notion of carbon intensity, when we need absolute reductions.

Most importantly, the two things we need, Nuclear Power and CCS, continue to be made totally uncompetitive by those same EPA “gas friendly” emission standards that allow natural gas to be permitted without abatement.

'We’re Wasting Time!'

No question, the gas turbine business is on its heels!

The price of oil, combined with the move to renewables has been punishing on the industry and the question rightfully asked is “what’s the gas turbine future look like?”

I have been labeled as unconventional most of my career and do not plan to change anything now.

The gas turbine will see substantial growth in the hybridization of Gas Turbine/Battery technologies to provide

The industry will have to deploy 85-90% post-combustion Carbon Capture & Storage (CCS) to compete with renewables. It will no longer be acceptable to deploy unabated Natural Gas Combined Cycle (NGCC) units. The AEO2018 2050 acknowledges that any marginal improvement from coal-to-gas switching is more than offset by the projected economic growth. It also suggests a trajectory that is 4x what is required to reach 2°C/450ppm.

It will not be practical to apply post-combustion CCS to a NGCC unit that is forced into rapid start/stop cycling in order to accommodate the intermittent wind and solar supply variations.

The state level Renewable Portfolio Standards (RPS) that require 30-40% renewable generation, also give renewables first dispatch and will have to change. This first dispatch concession/subsidy, intended to encourage renewable, is in direct conflict with CCS deployment and will have to be eliminated. Renewables will have to compete on level playing field without this generous subsidy. Such a change will have a significant and positive impact on the gas turbine future.

Post-combustion CCS will have to be deployed on the just completed 10-year gas turbine build-out. You remember, “Capture Ready”?

In exchange, the current discussions around NOPR Grid Stabilization and “keeping Nukes and Coal Plants open” will cease Both of these initiatives, intended to pay utilities to support renewables integration, will be eliminated by the market forces of a level playing. And, the renewables will no longer propagate their variability into the grid by default.

You cannot argue that these changes will be too hard to implement. I take the view that we have no choice.

In the world of surprises, did you see where China has undertaken a 16 million acre reforestation plan by 2020? The area is about the size of Rhode Island and is ahead of schedule.

The future of gas turbines. Is there one?

Most of us are familiar with the “Duck” and the need to manage its impact on the grid. As we make progress toward the Renewable Portfolio Standard (RPS), the duck’s “beer belly” will continue to grow.

The Renewable Portfolio Standard requires the utility in residence to meet an agreed percent of renewables in their electric generation mix, but it also mandates that renewables, if available, dispatch first.

That impact on the “utility in residence” is to reduce its plant load factor, depress the market price for the power the plant produces, and propogate the renewable’s intermittency to the utility downstream assets. The “utility in residence” must then compensate for that intermittency utilizing conventional generating assets, most of which will be operating off their best efficiency point.

These conventional generating assets are forced to operate at a less efficient “off-design” condition and incur more frequent start/stop cycles that affect equipment repair and life cycle costs.

The DOE proposed, and as of now abandoned, NOPR recognized and attempted to redefine reserve assets as either On-Line and Off-Line. On-Line capacity is clearly more valuable than Off-Line. This embedded mindset is what has driven conventional utilities and their assets toward a fast start/stop capability.

new regulatory drivers. In response, GE has paired their LM6000 Gas Turbine with a 10-MW/4.3- MWh Lithium-Ion Battery, creating a grid-scale UPS system that is now considered Spinning Reserve. LM6000 Hybrid EGT. An Energy Management system optimizes the combined system.

The following graphic has been in the literature since early 2000’s, but still seems relevant. The GE Gas Turbine/Battery Hybrid seems to fit nicely as a UPS system, and it is also now dispatchable in support of renewables integration, as well as a being able to serve a variety of anciliary services.

The LM6000 can include a fast start capability and when coupled with a battery, can served as a fast

response UPS system and/or an extended bulk power asset. The recent emergence of fast start gas

turbines is a critical success factor enabling this asset combination.

This effort also has “multiple ways to win’, and important attribute for investors, corporate or otherwise. It is not clear how such an asset will be deployed or how the concept will be monetized over time, but this looks like a really good idea and a valuable asset toward system-wide renewables integration.

Grid-scale UPS system

The EIA released their Annual Energy Outlook for 2018 in January. The forecast includes 10 different cases/scenarios, visible in the table generated using their browser tool.

I have rank-ordered these 10 scenarios from a high to low impact in year 2050, and I have also provided some macroeconomic data for reference. The two Reference Cases,with and without the impact of the Clean Power Plan (CPP), are shown

Without going into the detail again,this forecast suggests we are on the “red line” trajectory toward 58Gt, worldwide detailed in my September 2017 blog. The U.S. portion of that outcome is 5.4Gt, which we would hit in any of the top five scenarios.

EIA Annual Energy Outlook- January 2018

The DOE’s recent Notice of Proposed Rulemaking (NOPR), advertised as “Grid Stabilization”, was immediately demonized by the Renewables Community as a subsidy for Coal and Nuclear Power Generation.

The Federal Energy Regulatory Commission (FERC) quickly voted down the initiative.

The DOE really blew the “product positioning” on this, with its “Stabilization” labeling. I see their stabilization effort as the key enabling technology to allow further penetration of wind and solar, but that argument never surfaced.

The NOPR, under whatever name, was a legitimate attempt to create a market and associated compensation for the backup services essential to the continued growth of renewables.

The growth of renewables has been both impressive and important, and we continue to hear that renewables are now competitive with conventional generation. This is only true if the system integration costs for those renewables are not charged to their account. For the most part, these system Integration costs have fallen to the utility in residence, but without identified compensation.

To say that the grid has been taken for granted is an understatement.

It is more like “the tragedy of the commons” where the grid is the proverbial “common” and conventional generation backing it up, is the “depleted resource”, i.e., the decommissioning of conventional generation as uncompetitive.

 is an economic theory of a situation within a shared-resource system where individual users acting independently according to their own self-interest behave contrary to the common good of all users by depleting or spoiling that resource through their collective action.

I published a blog in November of 2015 with this graphic:

The original work was authored and presented Ueckerdt, Falko and Hirth, Lion and Luderer, Gunnar and Edenhofer, Ottmar, System LCOE: What are the Costs of Variable Renewables? (January 14, 2013).

The Clean Power Plan (CPP), or whatever remains of it, includes assumptions of ~30% renewables embedded in the identified state goals. At 30% penetration, the integration cost is equal to the generation costs, but are for the most part, uncompensated.

The DOE NOPR was an attempt to provide that compensation.

With the elimination of the NOPR, it should be no surprise that this issue has surfaced again in the form of “Emergency Aid for Some Coal Plants”, apparently available as an “emergency authorization” from DOE.

For reference, the Lazard “Projected LCOE by 2020”:

Grid stabilization or enabling renewables?

The EIA just released the International Energy Outlook for 2017 and declared that 

 is projected to continue to fall in the 

I looked for a definition of and the assumptions contained within the 

specifically as it relates to the much talked about Clean Power Plan (CPP). There is no mention of, or reference to the CPP in this 2017 International Outlook. Here is what it says.

But, the full implementation of the CPP appears to be built into the forecast and the associated claim of reduced energy intensity.  How do I know?

The new International Outlook has the U.S. at 

The EIA 2017 U.S. Energy Outlook for U.S.,published in January of this year, shows theReference Case CO

 and explicitly included the full implementation of the CPP.

I provided the data for that January Outlook earlier this year on the TMI blog, and on my own website (

forecast, for all intents and purposes, is the same level.

Therefore, the new International forecast suggests that the CPP will be fully implemented in the U.S., but our current political rhetoric does not. I guess the EIA has created some of that “plausible deniability” by referring to “current policies” and “existing government regulations”. The rest of their 

I keep referring to this MIT technology Review article and graphic by Mike Orcott, originally published in their 2012 Technical Review. It is still the best graphic that I have seen to dimension the problem.

You can see that the U.S.A portion of the 6℃ scenario is 5.4 Gt (

). The CPP impact in the U.S. forecast is

 in 2050. If this value is added to the current EIA forecast, the adjusted U.S. value becomes 

This Carbon Intensity language tries to put a happy face on our efforts. As I have stated before, this CO

Intensity is, more or less, the same metric as CO

per GDP that both China and India advocate. They are still growing their economies.

If you look below at the U.S.A again, the current 2050 

The worldwide totals shown in the EIA 2017 International Outlook are plotted on the Orcott graph and, if met, suggests a 4.5℃ level.

I have no reason to believe that the rest of the world will be any more successful than the U.S., since they too are in a growth mode and that this also suggests that the 4.5℃ is optimistic.

Why a 4.5°C raise by 2050 is an optimistic forecast

The 2017 Annual Energy Outlook, released in early January, provides a CO

 emissions forecast, which includes a base Reference Case along with side cases that examine the forecast sensitivity to six basic assumptions.

The Reference Case assumes that the U.S. implements the Clean Power Plan (CPP).

High & Low Oil & Gas Resource & Technology

In addition, the EIA has also provided a forecast for the Reference Case that assumes the U.S. does NOT implement the Clean Power Plan.

The report generator provides both a U.S. Electric Power and a U.S. Energy-Related Forecast. The report generator is available through a link on its website (

http://www.eia.gov/outlooks/aeo/data/browser/

).  The report generator does not allow the user to combine the effects of these side cases.

There are eight cases in all. I have found it useful to arrange these case results from the U.S. Energy Related Total, high to low, to get a sense of their relative impact.

Note, that there is hardly any difference in Electric Power CO

 emissions except in the Reference Case without CPP. All the other cases are in the 1550 Mmt range and there is hardly any impact beyond 2030. This is largely the result of the underlying generation mix assumptions of 70% NGCC without CCS, in combination with 30% renewables, and that the conversion from coal to NGCC is virtually complete by 2030.

The impact of the CPP is shown below, and is in keeping with the approximately 400Mmt (0.4 Gt) in the AEO2016 edition forecast for 2040.

Given the new direction articulated by the incoming Trump administration, a new “worst case” needs to be defined. The prevailing rhetoric would suggest a scenario as follows:

High Oil & Gas Resource & Technology (x1.003 & 1.026)

The values shown are the Electric Power and Energy Related values, respectively, compared to the reference case with CPP.

The combined effects of these in 2050 are x1.327 & x1.282 respectively, again, compared to the Reference Case (with CPP). If these factors are applied in combination, the resulting 2050 U.S. Electric Power Emissions are 2052.4 Mmt, and the Energy-Related Emissions are 6516.3 Mmt (6.5 Gt), effectively the same emissions we have today.

 emissions, based on the AEO2016 are shown in the following table, along with a calculated U.S. percent contribution.  I have extrapolated the 2050 U.S. Energy-Related Emissions without CPP to the estimated 11.4% of the total. Should that remain the case, this set of combined assumptions results in a Worldwide Emission total of 57.0 Gt.

The 57.0 Gt puts the world on a 6°C trajectory. I’ll leave you to locate this on the Carbon Capture Conundrum plot. Hint…it is 3x the 2°C target and 4x the 1.5°C target.

The U.S. portion of the 6°C, 58 Gt Worldwide emissions in 2050 is 5.4 Gt, vs. the projected 6.5 Gt with combined effects as noted above.

If the same logic were to be applied to the Reference Case (with CPP), the 5084.2 U.S. Energy-Related CO

 emissions would become 48.8 Gt Worldwide, at approximately 5°C.

The AEO2017 also offers the metric of Mmt per Capita, presumably to support the claim that emissions are declining. We have seen this logic attempted before, either as CO

 tonnes/GDP or some other production index. CO

 per Capita is just another surrogate for these output-based measures that allow emissions to grow along with economic output.

The good news is that this output-based logic is similar to those proposed by China and India and we could reach agreement on the measure. The bad news is that we are nowhere close to the level required to reach the 2°C/450ppm goal.