Power Plant Enviro Analysis: Case or System Basis?

Environmental justice groups want power plants’ carbon impact treated on a case-by-case basis. Independent generators and utilities want it treated on a system-wide basis. The November 19 workshop at the California Energy Commission aimed to set ground rules for satisfying the state environmental quality law for power plants. Stakeholders also debated whether greenhouse gas reductions in the electricity sector should be determined by the state’s climate protection statute, AB 32, or the California Environmental Quality Act. The basic debate boiled down to whether to view the global warming impacts of new power plants through a narrow or wide lens. AB 32 requires carbon emissions in the state to drop to 1990 levels by 2020, and seeks cuts from the major sources of carbon emissions--existing and proposed power plants and factories. CEQA, on the other hand, requires projects with significant environmental impacts to be mitigated, but only focuses on new projects. There are two competing strategies on the table for evaluating whether a new power project’s carbon emissions create “significant” environmental impacts under CEQA. One involves assessing them on a project-by-project basis. The second looks at the bigger scheme of things, and whether a new plant increases or decreases the electricity system’s overall global warming impact. “If we don’t look at the impact of a plant on the system as a whole, we are providing information that is wrong,” said Chris Ellison, an attorney representing the Independent Energy Producers. He insisted that new projects often replace dirty inefficient plants and thus lighten the electricity system’s carbon footprint. Will Rostoff, an attorney with EarthJustice, disagreed. He noted there are no assurances that the old plant won’t be fired up again. He and other environmental justice advocates urged that the Energy Commission to evaluate proposed plants’ impacts on an individual basis as CEQA requires public disclosure of carbon and other environmental impacts, and mitigation of project harm. According to Dick Ratliff, Energy Commission attorney, under the narrow lens approach each plant is viewed “like a smokestack.” The carbon pollution would be handled the way air quality districts regulate criteria air pollutants, requiring mitigation, and eliminating the need for emissions inventories. In contrast, the wide lens is more complex as it evaluates a power project “as one component in a big machine.” The complexity stems partly because of the shift in hourly, daily, and seasonal power usage and reliability needs. Investor-owed utility and a muni representative supported a systematic analysis when weighing the greenhouse gas impacts of new generating facilities. They point out that much of the carbon reductions under AB 32 will come from an increase in renewable projects, cleaner fossil-fueled plants, and a carbon cap-and-trade market. CEC member Karen Douglas, however, took issue with claims that new plants meant a less carbon intense electrical system, noting that several new plants mean more carbon emissions. Proponents of an individual project CEQA analysis object to a system-wide or “programmatic” approach because it would allow power projects to avoid greenhouse gas mitigation measures for individual plants. CEC member Jeff Byron asked the stakeholders to stop wrangling over their interpretation of CEQA and AB 32 and instead focus on what interim steps the commission can take to meet the Environmental Quality Act’s mandate to mitigate carbon emissions from projects that have cumulative greenhouse gas impacts.

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Power Plant Enviro Analysis: Case or System Basis?

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