A new discipline—environmental history—recently came to my attention while helping my Chinese colleagues develop plans to manage air quality. They wanted to know what Los Angeles did in the 1950s and 1960s to clean up its air and what London did in the 1950s. This history is important, not only to understand how those cities accomplished major air quality improvements, but also to understand and avoid the pitfalls they encountered and to improve upon what they did.
History lessons are equally important when considering EPA’s Clean Power Plan. Many are asking, “Will the lights stay on and will the beer stay cold when this plan goes into effect?” It’s important to know that we’ve seen this movie before. To my own surprise, I find myself silently quoting Ronald Reagan in his 1984 debate with Walter Mondale, thinking, “there you go again,” after reading yet another account predicting that the American electricity grid will go into catastrophic failure as a result of the Clean Power Plan.
If you really want to understand a reliability emergency and the effort that went into keeping the lights on, let’s look at Connecticut during the winter of 1995-96. I was a relatively new state regulator, having joined the Department of Environmental Protection’s air program just a few months before. The Nuclear Regulatory Commission (NRC) placed all three Millstone nuclear plants—which supplied more than one-third of Connecticut’s peak capacity of about 6,000 MW—on their “watch list,” and ordered them closed until numerous safety violations were corrected.
Closing one-third of a state’s peak capacity in and of itself is a reliability challenge. This one was compounded by several factors: Connecticut exported energy to neighboring Massachusetts and Rhode Island; Connecticut was designated as “serious” non-attainment for ground-level ozone, and was losing a significant source of NOx-free (an ozone precursor) electricity generating capacity; and, driven by air conditioning demand, Connecticut’s power system peaked in the summer.
The NRC “watch list” action occurred just a few months before air temperatures and humidity would soar, driving demand for electricity and creating conditions conducive to ozone formation. As a new air regulator, I faced my first—and only—reliability crisis. My colleagues and I had to find a way to keep the lights on, while protecting public health. If we failed, our friends and neighbors faced a summer sprinkled with rolling brown-outs or black-outs and the state might be required to adopt more regulations on businesses and industry if power plant emissions caused ozone levels to increase further.
We worked day and night, and over weekends, when necessary, to make sure that the lights stayed on and emissions did not increase to threaten public health. I got to know my colleagues at the Department of Public Utility Control (now part of the Department of Energy and Environment) very well. We received some wacky proposals to keep the lights on, including tying up barges loaded with diesel generators in Stamford and using the Navy’s nuclear submarines in Groton (I don’t think anyone told the Navy first about that one).
Being intimately connected electrically to Massachusetts and Rhode Island, as well as sharing the same airshed, we also worked closely with environmental and energy regulators in those states. Both were also in non-attainment for ozone at that time, and were equally concerned about any additional emissions in Connecticut impeding their ability to protect public health.
Our first strategy involved collaborating with Connecticut’s utilities and New England Power Pool (NEPOOL)—the predecessor of ISO-NE, the grid operator—to identify the cleanest units available and to determine what units might be able to increase their generation. In partnership with the Connecticut Air Bureau, we also developed a short-term emissions trading program that operated during the summer of 1996. To ensure that overall air quality did not suffer, any units that operated on unhealthy air quality days had to surrender NOx allowances in multiples of the amount of tons emitted on that day. Although highly unpopular, the utilities took a very close look at their operations, and used their best-controlled units first. They used the less controlled, higher-emitting units only when absolutely necessary to keep the lights on.
Our neighbors drank cold beer, enjoyed comfortable homes, and breathed air similar in quality to that of the previous summer. Today, it is a non-story, but one that bears remembering, as I’ve seen nothing—then or since then—that comes close to a true threat to reliability. Why was this a non-story? Because environmental and energy regulators did their jobs.
If this outcome was possible with no time to plan ahead and with the need to effectuate plans in a matter of months, what does this say about reliability and the Clean Power Plan?
From a reliability perspective, I’d expect the Clean Power Plan to be “ho hum,” no-big-deal, because environmental and energy regulators will do the good jobs that they’ve been doing for the past several decades. Utilities and grid operators routinely plan for a variety of scenarios, including the possibility of a large unit shutting down temporarily or permanently. The Clean Power Plan provides nearly 15 years to achieve full compliance, several lifetimes of planning for most utilities. Several gigawatts of fossil fuel plants have already shutdown due to competition from natural gas and renewable energy, or simply old-age. We’ve handled these just like we’ve always handled them—through the normal planning and regulatory processes.
In Reliability Standards, Safety Valves, and the State Clean Power Plan Compliance Obligation, my colleagues advise that ensuring electric reliability while meeting the Clean Power Plan obligation falls within the purview and responsibility of states. Given the number of carbon reduction tools available and the compliance flexibility the proposed rule offers, it’s highly likely that states will be able to comply in a manner that protects reliability.
Connecticut’s experience demonstrates that regulators can address a real emergency, and do so quickly, if one arises. States know how to deal with reliability issues, and they have the tools they need to comply with the Clean Power Plan and maintain affordable, reliable electricity.