Document mbBqkq4GjJ51DRvav85O0z5a4

More Proof That We Need a Coal Fleet Paul Bailey ACCCE Rece-tly, DOE's N at'o -al E-ergy Tec' -ology Laboratory (NETL) issued a report analyzing the resilience of different electricity resources -- coal, oil, natural gas, nuclear and renewables -- in six RTOs/ISOs during the Bomb Cyclone (December 27, 2017 through January 8, 2018).1 To evaluate their resilience, NETL used t' e N at'o-al I-frastructure Adv'sory C ou-eT's definition of resilience which says in part, "... The effectiveness o f a resilient infrastructure or enterprise depends on its ability to anticipate, absorb, adapt to, and/or rapidly recover from a potentially disruptive event." In this case, NETL evaluated resilience based on the contribution of each electricity source to meeting incremental electricity demand during the Bomb Cyclone. Incremental refers to the additional demand for electricity during the Bomb Cyclone as compared to a typical winter day. Here are just a few things in the report that we thought are worth mentioning. The coal fleet was the most resilient source of electricity. s "... across RTOs, coal is the most resilient form o f generation . . . " (p. 18 o f NETL report) / "In PJM, the largest o f the ISOs, coal provided the most resilient form o f generation, due to available reserve capacity and on-site fu el availability, fa r exceeding all other sources ... without available capacity from partially utilized coal units, PJM would have experienced ... blac"outs." (p. 1) / "In PJM, o f the three major sources o f electricity generation, only coal-fired generation exhibited significant resilience in response to the extreme weather even t." (p. 4) s "The most prominent example o f generation resilience occurred in PJM ... some coal-fired units were suddenly brought on line and others ramped up to accomm odate the rapid increase in PJM electricity demand ... coal units in PJM were uniquely positioned to provide the resilience needed at this critical point in tim e." (p. 12) 1 R eliability, R esilien ce and the O ncom ing W ave o f R etirin g B aseload Units V olum e 1: The C ritical R ole o f Therm al Units During Extrem e W eather Events, March 13, 2018, DOE/NETL-2018/1881. Page I 1 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00083774-00001 s Chart 1 (all six RTOs) and Chart 2 (PJM only) below show the percentage contribution o f electricity sources to meeting incremental electricity demand during the Bomb Cyclone. These charts are based on data in the NETL report. Chart 2; Contribution to Meeting Incremental i k'ctricilv 1Jemand in the TIM lU p o n NETL valued re silie n c e at $ 3 . 5 billion in PJM alone. / In PJM "... it was prim arily coal that responded resiliently, with some contribution from oil-firing u n its." (p. 16) Page I 2 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00083774-00002 / In PJM, "The increase in the cost o f energy services [during the Bomb C yclone]...w as $288M per day ... This, in effect, represents a value o f resilience ... [of] $3.5 billion. Simulating the event ... with fu tu re coal retirements is expected to produce higher energy costs and subsequently a higher value o f resilien ce." (p.16) Natural gas prices were very high. / "... in eastern PJM, ISO-NE, and NYISO, gas and electric transmission were severely constrained, leading to all-tim e high gas prices in New York and elevated natural gas and electricity prices across each reg ion ." (p. 6) s "... spot [gas] prices in New Y or" reached $175/M M Btu . . . . " (p. 8) / "... natural gas prices in PJM s p i"ed from a normal level near $3/M MBtu to $96/MMBtu at the Texas Eastern M3 interface . . . o n January 5 ." (p. 14) s Increases in spot gas prices fo r ISO-NE, PJM and NYISO were higher during the Bomb Cyclone than during the Polar Vortex. See Exhibit 1-20, p. 23. Renewables were detrimental to resilience. s "... cloud cover and wind speeds outside o f operational parameters caused a reduction in average daily contribution from intermittent renewables ... essentially imparting a resilience penalty to the system. This resulted in a need fo r dispatchable fossil generation to make up this generation in addition to its resiliency role in meeting the greater demand during the [Bomb C yclone]." (p. 4) s "Available wind energy was 12% lower during the Bomb Cyclone than fo r a typical winter day . . . . " (p. 2) s "Wind and solar had declines o f 19% in MISO, 29% in SPP and 32% in ERCO T." (p. 5) Retirem ents may be underestim ated. s "Retirement o f aging coal and nuclear generation infrastructure may be underestimated which could give rise to reliability concerns and an inability to meet pro"ected electricity demand . . . " (p. 2) s "... coal units will experience repeated cycling . . . as cycling increases, economic damage escalates, leading to premature retirem ent." (pp. 25, 28) To our way of thinking, the NETL report demonstrates two things. First, the coal fleet performed very well, that is, it was very resilient. In fact, the coal fleet performed better than other resources when electricity was needed the most. This seems like an incontrovertible argument for preserving the coal Page I 3 Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00083774-00003 fleet. Second, a diverse mix of resources is really the best "source" of electricity. As we have said before, there is no single source of electricity that is the best all, or even most, of the time. Each resource has its own relative advantages. However, the continued retirement of coal-fueled generation leads inevitably to less resource diversity. April 4, 2018 Sierra Club v. EPA 18cv3472 NDCA Tier 1 Page I 4 ED 002061 00083774-00004