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by Share Brandt

The Ball is in EPA’s Court


As promised last month, I will provide a summary of comments filed by the Wisconsin Department of Natural Resources (WDNR) and Public Service Commission (PSCW) on the Environmental Protection Agency’s proposed carbon emission guidelines for existing power plants. I can only cover a few key points of the 119 pages of comments and supporting documents in the space allowed. To review the entire document, search the Internet for “Wisconsin’s Comments on the Clean Power Plan.” Here are a few of the core issues.

  • A fundamental weakness in EPA’s proposal is that it fails to recognize the CO2 reductions that Wisconsin (and other early acting states) has already achieved. This problem persists throughout the proposal, but in particular in EPA’s use of the single baseline year of 2012.
  • Inequity across states in that states that already reduced emissions significantly (prior to 2012), such as Wisconsin, are being asked to reduce emissions more than states that have done less. In addition, states that emit the most CO2 are asked to do the least. As a result, states end up with very different, and largely counterintuitive, emissions reduction goals.
  • EPA defined Best System of Emission Reduction (BSER) in this proposal using four building blocks. However, EPA generally fails to recognize that the four building blocks, if applied simultaneously, work against each other. For instance, Wisconsin’s modeling consistently shows that increasing in-state gas generation to comply with building block 2 drives coal-fired plants to become load-following and less efficient, thereby making building block 1 entirely unattainable.
  • PSCW estimates that the costs to comply with EPA’s proposal over the compliance period range from $3.3 to 13.4 billion. While these estimates are preliminary the agencies are very concerned the costs of EPA’s proposal will threaten Wisconsin’s most reliable energy source and damage our ability to provide affordable energy to our citizens and manufacturing-based economy.
  • Wisconsin’s state Renewable Portfolio Standard (RPS) allows renewable energy purchased from out-of-state to be used to meet the RPS requirements. Wisconsin utilities have built, own, or operate almost 400 MW of wind energy in other states and have long-term agreements to purchase even more out-of-state renewable power. EPA must establish clear, legally-based guidelines to allow states that own or purchase renewable generation in another state to claim compliance credit for that generation.
  • EPA has not adequately performed sufficient analyses to demonstrate that its proposal will ensure reliability of the grid in Wisconsin. We are particularly concerned that, in the absence of a robust coal-fired fleet, natural gas plants currently used for peaking may not be able to support the electric load. [Federal Energy Regulatory Commission’s (FERC) Philip Moeller summarized this concern in his comments to the EPA by saying, “The laws of physics will trump any paper regulations or laws.” FERC has responsibility to promote the reliability of our nation’s electric power system and to assure just and reasonable rates.]

There are many more key concerns outlined in the state’s comments, many that we have written about in previous articles. More than four million comments were filed; generally regulations draw a few thousand. Now it’s in the EPA’s hands to use the comments to guide a revision to the rule that is reliable, achievable and affordable for America’s electricity consumers.



© Wisconsin Electric Cooperative Associationz