Perhaps the DOE Should Start in its Own Backyard

Rick Perry's Notice of Proposed Rulemaking... oh, the opportunities for blog fodder.  One more post before I stop (for now).

So, Rick Perry thinks that we need to stop the untimely retirement of baseload generation resources, namely coal and nuclear in order to preserve "resiliency."

He could start in his own backyard.

The DOE's "participation" in the Plains & Eastern Clean Line project is supposed to facilitate the development of renewable energy (and therefore the closing of coal-fired generators it would displace), and the DOE's Record of Decision supporting participation in the Plains & Eastern project used this justification for its decision to support the project.

The already-strong demand for imports of low-cost wind energy into the mid-South and Southeast would likely increase if and when states in the region are subject to regulations limiting greenhouse gas emissions from power plants. EPA’s Clean Power Plan, published in October 2015 and scheduled to mandate compliance beginning in 2022, aims to “continue progress already underway in the U.S. to reduce CO2 emissions from the utility power sector” and is part of a suite of air quality improvements sought by other national environmental regulations. These improvements could be accomplished through retrofitting of older generation plants, plant retirements, and an increasing reliance on local or imported low-carbon generation including renewables. The Department’s Energy Information Administration (EIA) estimates that the Clean Power Plan would result in strong growth in renewable generation, particularly in regions currently lacking robust renewable portfolio standards such as the Southeast. Implementation of the Clean Power Plan would also shift the regional fuel mix away from baseload capacity with on-site fuel supplies (such as coal, nuclear, hydroelectricity, and oil) towards capacity that tends to utilize real-time fuel delivery (wind, solar, and natural gas).  Overall, wind generation is projected to play a major role and become increasingly economically competitive. Although the EIA’s analysis did not look at the degree to which such a fuel mix would be imported to the Southeast or conduct a detailed model of the transmission system, it did find that “[c]ompliance with the proposed rule could necessitate significant investment in electric transmission system infrastructure to integrate renewables from remote areas.”

The Clean Power Plan is dead, smothered under its own hubris.  But yet DOE is still puttering merrily down the road supporting the Clean Power Plan through legacy "decisions" made by the previous administration to participate in an impossible transmission project with no customers intended to facilitate renewable competition for baseload generators in the Southeast.

In fact, the DOE was so hung up on facilitating the development of renewable energy, that it illegally added that extra-statutory factor to its RFP for Sec. 1222 projects, and used it a basis for its decision to "participate" in the project.

To be sure, wind power delivered by the Project will compete with other sources of renewable energy in markets in the mid-South and Southeast. But such competition is healthy, and ultimately benefits consumers and the renewable energy sector as a whole. Indeed, new transmission links such as the Project create value through their ability to foster healthy competition among generators. As the Commission has observed: “New interconnections and transmission service generally meet the public interest by increasing power supply options and improving competition.” The Commission has also explained that “as a general matter, the availability of transmission service enhances competition in power markets by increasing power supply options of buyers and sales options of sellers, [resulting in] lower costs to consumers.”

Right.... healthy competition, but renewables wouldn't be the only competitors.  Baseload generation would also be competing against imported renewables, and perhaps that sort of competition could cause the closure of baseload resources in the Southeast.

In addition, DOE's Environmental Impact Statement gushed on and on about the tons of carbon a Clean Line would save from entering the atmosphere.  I don't have the time and patience to dig that up, so you'll have to accept my paraphrasing here.  A "clean" line couldn't remove carbon from the atmosphere by itself, therefore it could only accomplish this through displacement of existing generators that produce carbon.  Therefore, Clean Line is intended as a vehicle to close existing baseload generators that produce carbon.

So, get with the program, Rick!  Instead of trying to put your thumb on the scale at FERC, why not start a little closer to home by extricating the DOE from its "participation" in the Plains & Eastern Clean Line?  It would probably be a whole lot easier to change policy in your own department than it would be to demand an independent regulatory agency act as your minion on some impossible time line.  Clean up DOE's own backyard first!