How to economically account for CO2 a central question during EFSB Invenergy hearingsInvenergy‘s expert witness Ryan Hardy fought with Conservation Law Foundation (CLF) Senior Attorney Jerry Elmer for 75 minutes on Tuesday morning during the Energy Facility Siting Board (EFSB) hearings on the licensing of the company’s $1 billion fracked gas and diesel oil burning power plant aimed at the pristine forests of Burrillville. In this phase of the hearings the EFSB
Published on September 19, 2018
By Steve Ahlquist
Invenergy‘s expert witness Ryan Hardy fought with Conservation Law Foundation (CLF) Senior Attorney Jerry Elmer for 75 minutes on Tuesday morning during the Energy Facility Siting Board (EFSB) hearings on the licensing of the company’s $1 billion fracked gas and diesel oil burning power plant aimed at the pristine forests of Burrillville. In this phase of the hearings the EFSB is considering the critical issue of carbon emissions and climate change. Hardy, an energy market expert with PA Consulting, submitted testimony to the EFSB claiming that the proposed power plant will reduce carbon emissions because it will replace older, more polluting power plants.
Hardy’s calculations are consumption based, not production (or generation) based, and this is a key difference between the CO2 calculations of Hardy and the calculations of Timmons Roberts, the Brown University professor serving as CLF’s expert witness. Roberts submitted testimony (and here) that the proposed power plant will make it impossible for Rhode Island to achieve its carbon reduction goals under the Resilient Rhode Island Act. Roberts will be testifying on Thursday in what is expected to be a contentious and thorough cross-examination from Invenergy’s lawyers.
What is the difference between consumption-based and production-based accounting for carbon? Roberts explains in his testimony:
In the electricity sector, there is a crucial difference. The six New England states have a single, unitary electricity grid. Rhode Island demand accounts for only about 6 percent of New England’s aggregate electricity load. Therefore, if you use consumption-based accounting, and you build a fossil fuel power plant here in Rhode Island, by means of an accounting trick, you account for 94 percent of the carbon emissions against other states’ goals; that is, these emissions are considered as being from “out of state” and those emissions then disappear from our ledgers. In contrast, when you use production-based accounting, you have to account for the carbon emissions produced or created here in Rhode Island. I believe that production-based accounting is the correct method to use.
Here’s the video of Ryan Hardy’s first hour or so of testimony before the EFSB:
When we return to the cross examination of Ryan Hardy, we learn that Massachusetts uses production based calculations in all its legislation and emissions calculations. Hardy went on to say that he believes that the Resilient Rhode Island legislation was crafted with the goal of reducing carbon emissions by 80 percent by 2050 globally, not statewide.
Elmer ended his cross, and Burrillville’s lawyer Michael McElroy took over. McElroy picked up on a point made by Elmer earlier: Ryan Hardy’s analysis only looks four years ahead, but the plant is expected to operate for 50 years. Why is there no analysis for the last 46 years of the power plant’s life?
McElroy points out that the area where the power plant is planned to be built is now all forest. If a power plant is built, CO2 will increase by 7 billion pounds.
Location does not matter when it comes to CO2 emissions, countered Hardy.
McElroy points out that Burrillville will suffer an additional seven billion tons of CO2 annually for what Ryan Hardy projects to be a one percent reduction of CO2 New England wide.
Here’s video of the rest of Hardy’s testimony:
The Rhode Island Office of Energy Resources, a government agency under the authority of Governor Gina Raimondo, has been advocating for the power plant from the beginning. They called their expert witness, Dr Ellen Cool, who agrees with Hardy about the calculations. Her testimony can be accessed here and here.
In Timmons Roberts’ testimony, he is asked:
Are you aware of the fact that, in interpreting the Resilient Rhode Island Act the Governor’s Executive Climate Change Coordinating Council (EC4) considered [the question of consumer vs production based accounting] and decided to adopt the consumption-based method of accounting?
Yes, I certainly am. That decision was made against the strongly expressed advice of some of us on the EC4’s own expert panel, and in repeated public comment in meetings of the group charged with overseeing public input on the study, and against the strong and united opinion of the entire Rhode Island environmental community. Moreover, that decision was published in a report in December 2016, well over a year after the Invenergy application was filed here in the EFSB. The EC4 is composed of state agency heads–Governor Raimondo’s employees and appointees. The EC4, consisting as it does of gubernatorial employees and appointees, was acutely aware of the political implications for Invenergy when it made this choice.
This testimony certainly puts the Governor’s recent assertions of neutrality when it comes to the power plant into question.
As for the long term prospects of the power plant, Dr Cool writes,
“There may be a point in time when revenues from the electricity markets administered by ISO-NE are insufficient to cover CREC’s fixed and variable operating costs, and CREC may decide to mothball or retire the plant. However, the risk of financial losses is borne entirely by Invenergy and its investors, and not by electric customers in Rhode Island or elsewhere in New England.”
In other words, though she, like Hardy, has not done the projections, the actual lifespan of the plant may well be measured in years, not decades, as the price point of renewables continues to come down and the price of natural gas rises.
In the next hour testimony from we learned that as the system continues to become decarbonized and cleaner, the impact of Invenergy’s plant will be less and less.
Here’s the video:
The EFSB will is next expected to hear more testimony on the critical issue of carbon emissions and climate change on Thursday, September 20, 9:30am and Wednesday, September 26, 10am at the PUC building, 89 Jefferson Blvd, Warwick, Conference Room A (first floor).
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