Grid Operations and Why They Matter for Air Quality — Part 2

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In the second part of a training for the Mid-Atlantic Regional Air Management Association (MARAMA), Nancy Seidman explored the air quality and health benefits of energy efficiency and electrification.

Grid Operations and Why They Matter for Air Quality — Part 1

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In a training for the Mid-Atlantic Regional Air Management Association (MARAMA), Nancy Seidman discussed regional transmission and opportunities for collaboration among air quality regulators, state energy offices and utility commissions.

Environmental Regulations and the “No Regrets” Approach: A Refresher for Utility Generators

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Many of us have a hard time keeping track of where our federal government stands on environmental issues, especially when viewed through a political lens or from the perspective of the popular press. For example, in 2016 we signed on to the Paris Climate Accord. We withdrew in 2020, then rejoined in 2021. The Obama administration put in place numerous environmental regulatory programs. Subsequently, the Trump administration undermined them in court and dismantled them administratively. Then, rather than supporting the Obama administration’s Clean Power Plan, which was replaced by the Trump administration’s Affordable Clean Energy rule, the Biden administration took a different tack through a series of executive orders.

Despite being confusing at times, policy changes should not be an impediment to utility companies. The reason: Electric utilities across the country have always been masters of long-term planning. They know that major infrastructure projects take a long time — up to a decade or more — to conceive, plan and execute. More than half of all states require utilities to develop long-term integrated resource plans, a full range of feasible options on the supply side (utility-scale generation), demand side (customer-sited solutions) and distribution side (customer and community resources), and to assess them against a common set of planning objectives and criteria to meet expected customer service requirements into the future at least cost.

The truth is that utilities routinely make and execute resource plans, whether mandated or not. As illustrated in a blog one of us wrote in 2015, a careful assessment of risk factors will reveal that, in addition to what is immediately before you, utilities face “a host of other rules, initiatives, and market trends that are forcing other changes.”

So, instead of getting caught up in the latest pronouncements, utilities should make sure that they consider a wide range of regulatory scenarios, then develop plans to help them acquire a portfolio of resources capable of serving customers well, given existing trends and the law. In other words, “no regrets” approaches today can dictate what reasonably appear to be a company’s most equitable and economical choices.

What follows are some examples to illustrate that new environmental requirements could arise from federal laws already on the books. Utilities, working with their state regulators and stakeholders, should recognize and make long-term plans for these likely requirements.

Ambient Air Quality Standards (standards reviewed every five years)

The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to review the National Ambient Air Quality Standards every five years. This requirement includes primary and secondary standards for six of the most common air pollutants, known as criteria pollutants: carbon monoxide, lead, ground-level ozone, particulate matter, nitrogen dioxide, and sulfur dioxide. The purpose of the review is to ensure that these standards reflect the best, current scientific information to ensure the protection of public health and the environment.

These reviews depend on the development and evaluation of scientific information by the EPA, and, in turn, advice from the agency’s independent Clean Air Scientific Advisory Committee. Today’s utility planners should note the ongoing review of the air quality standards for fine particulate matter, for example. A 2021 Advisory Committee report indicates that the current standards may not be adequate to protect public health and welfare, as required. Particulate matter is emitted whenever fossil fuels are burned, so a tighter standard could result in more restrictions on processes and equipment (including power plants) that burn fossil fuels.

Section 110(a)(1) of the Clean Air Act requires states to submit State Implementation Plans to the EPA within three years after the initial development or revision of a national primary ambient air quality standard. State plans provide for the implementation, maintenance and enforcement of these standards.  These plans provide an excellent opportunity for utility regulators, utilities and community groups to help states design appropriate plans, consistent with other utility planning efforts.

Interstate Air Pollution (allowable emissions in 12 states are due to decrease through 2024)

In 2011, EPA finalized the Cross-State Air Pollution Rule (CSAPR) to address the emissions of criteria air pollutants that are transported across state lines and affect air quality in downwind states.

Because the interstate transport of emissions affects air quality and public health locally, regionally, and in states hundreds of miles downwind, this rule requires certain states in the eastern half of the United States to regulate and reduce power plant emissions to improve air quality. If a downwind state can demonstrate that upwind emitting sources in neighboring states are affecting its ability to comply with national standards, the “good neighbor” provisions of Section 126 of the Clean Air Act require the upwind source to either cease operation or comply with emissions limitations established by the EPA.

If the EPA determines that states are taking too long to implement changes to their state plans, the agency has the authority to issue a Federal Implementation Plan. In 2021, it issued new or amended plans for these 12 states, revising their emission budgets until air quality projections demonstrate resolution of the link between emissions in these states, allowing downwind states to meet air quality standards.

New Source Performance Standards for GHG Emissions (standards could be revisited any time)

In 2015, using authority from Section 111(b) of the Clean Air Act, the EPA set New Source Performance Standards for greenhouse gas (GHG) emissions from new, modified, and reconstructed fossil fuel-fired power plants. As required, the agency established these emissions standards based on its evaluation of the “best system of emission reduction” for affected sources. For example, the best system for baseload natural gas-fired turbines was determined to be the use of efficient natural gas combined cycle technology. For peaking turbines, however, the EPA determined that using “clean fuels” was the best system of emissions reduction. In neither case did the agency require new gas-fired turbines to match the performance of the lowest-emitting commercially available turbines.

In December 2018, EPA proposed revisions to the new source performance standards for coal-fired electric power plants relaxing the requirements. The primary reason given by the agency, “high costs and limited geographic availability of [carbon capture and storage] CCS.” Using the same authority, the EPA could likewise propose to tighten the standards for baseload and peaking gas plants. If it were to consider current resource information, the agency could revisit its best system of emissions reduction determination for a gas “peaker” and determine, for example, that new plants should not emit more than the very lowest emitting units on the market today.

Hazardous Pollutants (standard reviewed every eight years)

In 2012, the EPA developed the Mercury and Air Toxics Standard (MATS) pursuant to Section 112 of the Clean Air Act. That section gives the agency the authority to regulate hazardous air pollutants from stationary sources like electric generating units. Section 112 also requires periodic review and potential revision “taking into account developments in practices, processes, and control technologies.”

In fact, fossil-fueled electric power plants emit toxic air pollutants and could become subject to further restrictions given the EPA’s recent announcement about the need to enforce the mercury requirements, reversing another decision made during the Trump administration. The agency is taking comments on whether the mercury emissions limits should be made more stringent.

Utilities have the capability and the responsibility to factor all these contingencies and scenarios into their long-term plans and investment decisions. In the foreword to its 2011 publication Preparing for EPA Regulations:  Working to Ensure Reliable and Affordable Environmental Compliance, RAP quoted Moody’s Investor Service:

 …credit risk factors associated with energy and climate legislation have existed for decades and managing these risks are considered a core competency for all utility operators, whether they are regulated or un-regulated, public, or privately-owned.

This applies as much today as it did 10 years ago when Moody’s made the pronouncement. Staying abreast of changes to environmental and public health laws and their potential effects on the utility sector continues to be an important responsibility of utility owners, operators, and regulators.

NOx, NOx – Who’s There?

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In a presentation for air directors with the Ozone Transport Commission, Nancy Seidman and John Shenot proposed an innovative model rule concept to reduce nitrogen oxides emissions from water heaters, a significant source of emissions that has received little attention from state regulators.

NOx, NOx – Who’s There?

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​For the Ozone Transport Commission’s Stationary and Area Source Committee, Nancy Seidman and John Shenot proposed an innovative model rule concept to reduce nitrogen oxides emissions from water heaters, a significant source of emissions that has received little attention from state regulators.

Energy Efficiency for Better Air Quality: Reducing Air Pollution and Restoring Scenic Beauty

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​In a webinar for an Arkansas energy efficiency stakeholder group, RAP’s Nancy Seidman and Erika Droke of the Arkansas Office of Air Quality highlighted how energy efficiency has played a quantifiable role in improving air quality.

How Electrifying Trucks Can Help Roadside Neighborhoods Breathe Easier

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We know that electrifying trucks, as we wrote last month, can reduce significant amounts of air pollution; it can also have significant health benefits, particularly for frontline communities. Analysis by Alexander Meitiv and Ann Xu for Texas A&M’s Transportation Institute finds that, by electrifying just 40% of existing, predominantly diesel-fueled medium-and heavy-duty vehicles in the eight-county Houston area, Texans could avoid more than 21 tons of nitrogen oxides (NOx) – over a quarter of the 80 tons a day emitted per day by Greater Houston’s on-road traffic. This could be achieved by electrifying a little over 60,000 medium-and heavy-duty vehicles, about 1% of all the vehicles in greater Houston.

This is big news for all areas in non-attainment for ozone under the Clean Air Act, a serious public health and economic challenge. But it is especially big news for people living near highway corridors, because electrifying the same vehicles also reduces fine particle emissions by nearly 20%.

Fine Particulates Are Deadly

Tailpipe emissions from medium- and heavy-duty diesel trucks contain significant amounts of fine particle pollution, also referred to as “PM2.5.” PM2.5 are particles that are 2.5 microns or smaller that are produced along with partially combusted fuel and from other pollutants like nitrogen and sulfur oxides. (To get a sense of just how small 2.5 microns is, the diameter of a human hair is around 50 microns.)

The World Health Organization’s International Agency for Research on Cancer characterizes PM2.5 as a carcinogen, and for decades, we have known that PM2.5 causes premature mortality. In the proceedings of the National Academy of Sciences research indicates that roughly 100,000 Americans per year die from fine particle pollution.

In spring 2020, public health researchers at Harvard issued a study further illustrating the danger of particulate pollution. They found that the pre-existing conditions that increase the risk of death in those with COVID-19 are the same diseases that are affected by long-term exposure to air pollution, and that a small increase in exposure to PM2.5 leads to a large increase in the COVID-19 death rate. Emissions from medium- and heavy-duty vehicles, a major source of PM2.5, should be of grave concern and raise a red flag.

Who Is Affected?

Low- and moderate-income (LMI) communities and communities of color, especially those located near transportation corridors, are disproportionately affected by transportation-related emissions of PM2.5. Meitiv and Xu’s analysis finds that the proximity and exposure to truck-related emissions in certain neighborhoods “leads to environmental justice questions related to air pollution and public health.”

LMI communities are often located in very close proximity to roadways because property values in those areas are likely to be lower . The CDC has found that racial and ethnic minority communities, foreign-born people, and people who speak a language other than English at home represent the highest percentage of people living within 500 feet of a major highway.

As illustrated in the following figures, people living in close proximity to roadways in the Houston-Galveston region are subject to long–term exposure to these pollutants. Figure 1 shows a census block map organized by percentage of low- and moderate-income (LMI) residents. As the legend suggests, the darker the shade, the higher the percentage of LMI residents in each block.

Figure 1: Census Block Group Map of Percentage of LMI Residents

Figure 1 shows that in Houston’s surrounding communities – the northwest, northeast and southeast quadrants – neighborhoods are home to 50–100% LMI residents. Even in the city’s southwestern suburbs (lighter shade), where the relative percentage of LMI residents is low, there are still neighborhoods where the proportion ranges between 20% to as much as 50%.

The Strategy: Electrify Medium- and Heavy-Duty Vehicles

The most effective way to improve air quality for communities near roadways, according to the EPA, is to “reduce the emissions of each vehicle on the road and the number of vehicle miles driven.” Vehicle electrification can reduce emissions. And Meitiv and Xu’s research illustrates how the electrification of medium- and heavy-duty vehicles can be especially effective.

Figure 2: PM2.5 Concentration Reduction From 40% Heavy-Duty Truck Electrification

In their analysis, the authors found that (1) heavy-duty long-haul electrification reduces emissions along major corridors, whereas (2) medium-duty short-haul electrification reduces emissions across secondary roadways, especially on the west side of Houston. Figure 2 illustrates reductions of PM2.5 concentrations (the lighter colors) across Houston and the surrounding areas produced by the electrification of 40% of heavy-duty trucks in the region. In addition, emissions reductions from electrifying heavy-duty trucks can be seen along major corridors in the region, including routes to Galveston to the southeast, Lake Jackson to the south, and Bay City to the southwest.

Figure 3 illustrates reductions of PM2.5 concentrations (the lighter colors) produced by the electrification of 40% of medium-duty trucks in the region. Most notable are PM2.5 emissions reductions in the areas to the west and the northwest of Houston, on secondary roads and, similar to the effects produced by electrifying heavy-duty trucks, on major corridors as well.

Figure 3: PM2.5 Concentration Reduction From 40% Medium-Duty Truck Electrification


Electrifying trucks can reduce air pollution significantly and produce public health benefits, particularly for frontline communities. Texas A&M Transportation Institute’s analysis identifies major benefits in NOx reductions by electrifying a fraction of diesel-fueled vehicles on Houston’s highways. They also found an important co-benefit of the same truck electrification strategy: Electrification reduces deadly PM2.5 emissions by 20%. Not only is this good news for overburdened Houston neighborhoods near roadways, but it also has positive implications for similar communities throughout the United States.

RGGI’s Program Review Offers a Chance to Revisit Local Air Quality Needs

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While there is substantial evidence that the Regional Greenhouse Gas Initiative (RGGI) has been very successful at reducing carbon and other emissions across the multi-state region, there is still important work to be done to document and ensure air quality improvements at the local level — especially in frontline communities that either host fossil-fuel power plants or are downwind from those plants. Since the RGGI program started 12 years ago, can we better document how air quality has changed in communities that may be affected by the continued operation of fossil energy generation? And in communities where more needs to be done, could RGGI help support local air quality improvements through expanded monitoring?

The RGGI members — 10 states across New England and the Mid-Atlantic — have a history of using a periodic, comprehensive program review to assess RGGI’s operations and ensure its economic, environmental, and equitable performance. As awareness grows of the disproportionate public health impacts in frontline communities from COVID-19 and air pollution, and as Mid-Atlantic and New England states increase their focus on ensuring greater equity in environmental programs, the 2021 program review is an ideal opportunity to consider these questions.

RGGI’s Consumer Benefit Allocation

The RGGI framework is ideally suited to address air quality concerns in frontline communities. The original agreement to develop RGGI, a 2005 memorandum of understanding (MOU) signed by member states, includes a provision for a “comprehensive review” of all aspects of the program. In 2005, RGGI states also agreed to allocate at least a quarter of their allowance revenues for “consumer benefit” or “strategic energy” purposes, which they defined broadly: “to promote energy efficiency, to directly mitigate electricity ratepayer impacts, to promote renewable or non-carbon emitting energy technologies, and to stimulate or reward investment in the development of innovative carbon emissions abatement technologies.”

Initially spurred by the consumer benefit allocation idea, RGGI states have, in fact, invested a far greater amount of their revenues in complementary policies. They have directed nearly $3 billion in proceeds from the quarterly allowance auctions back into state economies, focusing on policies that complement the program and contribute to its success.

The Need for Air Monitoring in Overburdened Communities

The 2021 program review is a good time to better understand the air quality impacts on electricity ratepayers in frontline communities. And one useful first step would be to enable better air quality monitoring at the local level.

We recommend starting with monitoring fine particle pollution that is released from unburnt fuel and from other pollutants like nitrogen and sulfur oxides which have their own health impacts. While there are other pollutants that could be monitored by more complicated and expensive technology, starting with particulates could provide a good idea of the levels of pollution coming from local power plants and from other sources like transportation or other manufacturing plants.

Fine particles are also referred to as “PM2.5,” because EPA’s public health standard addresses particles that are 2.5 microns or smaller. To get a sense of just how small that is, the diameter of a human hair is around 50 microns. The health impacts of particulates are extremely serious. More than 25 years ago, PM2.5 was demonstrated to cause premature mortality. Around 100,000 Americans per year die from fine particle pollution.

In addition, a reason for disproportionate effects of the coronavirus on certain subgroups of the public appears to be related to their long–term exposure to various types of air pollution including fine particles. In spring 2020, public health researchers at Harvard issued a study in which they found this connection between exposure to increased concentrations of PM2.5 and increases in COVID-19 death rates.

Simply investing in monitors, however, will not be enough. States will need to work with community groups to define affected communities and those locations most in need of additional monitoring. Focusing on those adjacent to power plants in RGGI’s jurisdictionmay be a start.

Today, all state and local health agencies are required to maintain monitoring networks, comprised in part by what are known as “federal reference monitors” that meet U.S. Environmental Protection Agency (EPA) requirements for equipment, quality assurance, control and location. A typical continuous PM2.5 monitor is costly and requires ongoing maintenance, an outlay of over $20,000 per year per monitor.

There are good alternatives, which are lower-cost though admittedly somewhat less accurate. A PurpleAir monitor, for example, costs around $300 and needs to be calibrated against a federal reference monitor.  PM2.5 is one pollutant that a PurpleAir monitor is designed to measure. The EPA has studied their use and calibrated them with good success.

In Denver, Colorado, the Love My Air project is an example of the type of project that would be worthwhile in the RGGI region. It is a partnership between the Colorado Department of Public Health & Environment, Denver Public Schools (over 20 of them), and the Tri-County Health Department. The City of Denver has indicated that, while there are multiple factors that influence exposure to air pollution, “schools are an ideal intervention point for sensor deployment, education and empowerment.”

Monitoring that relies on affordable technology like PurpleAir would help in quantifying the burden of particle pollution in communities. It could be used to expand state or local monitoring networks and help citizens learn more about their air quality. Support for monitoring PM2.5 would also help identify whether that pollution stems from a RGGI facility or others nearby pollution sources.

As the RGGI states undertake a comprehensive program review, of all aspects of the program, beginning this year, we encourage them to consider supporting PM2.5 monitoring. It could help RGGI states demonstrate benefits beyond reduction of carbon dioxide emissions, and better ensure that investments made with the program’s revenues are benefitting electricity ratepayers in all the communities within the region.

EV Policy Options for Montana

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​In a webinar for Montana legislators and energy office staff, Camille Kadoch and David Farnsworth discussed electric vehicle policy options and the role of integrated resource planning in advancing transportation electrification.