Reward N.Y. for its fuel strides

Commentary / January 2, 2015 / Albany Times Union

As the Environmental Protection Agency reviews its Clean Power Plan for decreasing carbon dioxide emissions from existing power plants, it must recognize the great strides New York has already made.

While the goal is laudable, the plan as currently proposed is unreasonable and would place New York at a competitive disadvantage to other states.

In its review, EPA must acknowledge the importance of electrical system reliability and fuel diversity to sustaining a strong New York economy, as well as the unparalleled emission reductions New York's power sector has already made.

The plan calls for New York to further reduce CO2 emissions from existing power plants, but it does not give New York power plant owners full credit for cutting CO2 emissions by 48.9 percent below 1990 levels and 41.6 percent compared to 2005 levels. That's the most of any sector in New York's economy, and already more than EPA's plan requires for many other states. According to the Energy Information Administration, New York has the lowest per-capita energy-related CO2 emissions of any state.

New York's success is in part due to its participation in the Regional Greenhouse Gas Initiative — a program by which New York meets targeted reduction goals through a regional cap on emissions — and its non-emitting assets, such as nuclear energy, which account for 30 percent of New York's power supply.

For New York to comply with EPA's Plan, the Independent Power Producers of New Yorkrecommends three things: the state's existing nuclear resources continue to be counted toward its emission reduction requirements; additional states participate in the RGGI program or other similar market-based programs to meet emission reductions; and reductions achieved since the RGGI program began in 2008 be counted toward the reductions.

Moreover, should the plan remain unchanged, New Yorkers depending on readily available electricity to power both their homes and businesses may suffer reliability problems.

Currently, 46 percent of New York's statewide generating capacity is from dual-fueled facilities (plants that can switch between natural gas and oil). During the extreme winter weather in the Northeast last year, pipeline constraints and competition for fuel produced higher prices for natural gas, making the operation of oil facilities the more economic alternative.

In states lacking this breadth of fuel diversity, this extreme weather produced serious reliability problems for consumers, whereas New York's power producers were able to meet demand using a combination of power sources, such as from duel-fueled and nuclear facilities — the latter of which was operating at 97 percent efficiency nationwide during this period, according to the Nuclear Energy Institute. If EPA's Plan does not recognize the important role these facilities play in both minimizing emissions and providing reliable power, New York ratepayers will suffer increased costs and dubious service at the worst of times.

Such weather conditions demonstrate the value of maintaining dual-fuel capability and fuel diversity for electric system reliability.

In fact, New York's resources are so diverse that approximately 23 percent of its electricity generation is supplied by renewable energy resources and 53 percent of annual electricity used comes from non-emitting resources like in-state hydro and nuclear.

As a RGGI founding state, New York has long been at the forefront of power sector innovation and emission reductions solutions.

If the EPA intends its Clean Power Plan to be a step in the right direction, it should consider the practical and successful experiences of New York — and not penalize the state for what it has already achieved.

Gavin Donohue is president and CEO of IPPNY.

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