Washington Update. Mary Miller Chief Administrative Officer Edison Electric Institute. Western LAMPAC Spring Meeting April 2015

Transcription

1 Washington Update Mary Miller Chief Administrative Officer Edison Electric Institute Western LAMPAC Spring Meeting April 2015

2 OSHA Settlement Settlement agreement reached with OSHA, resolving challenge to the final rules that were issued last April Close collaboration among industry and labor to formulate positions on the provisions in the standard since OSHA originally proposed changes 10+years ago Negotiated phased in compliance dates and attained key clarification on more than 50 issues relating to specific areas of the rule Now working on the development of the compliance directive that will assist OSHA personnel in enforcing the new rules

3 Policy Issues on the Radar Environmental Regulations Energy Legislation Grid Security Quadrennial Energy Review Distributed Generation

4 Environmental Regulations

5 Environmental Regulatory Challenges: 2015 and Beyond Air Climate Water Land & Natural Resources Mercury & Air Toxics Standards (MATS) NSPS- New Sources 316(b) Transmission Siting and Permitting Waste & Chemical Management Coal Ash Interstate Transport (CAIR/CSAPR) NSPS- Existing Sources Effluent Limitation Guidelines Avian Protection PCBs in Electrical Equipment Regional Haze/Visibility BACT Permitting Waters of the United States Endangered Species HazMat Transport Multiple NAAQS International Negotiations Total Maximum Daily Loads (TMDLs) Vegetation Management New Source Review (NSR) Waterbody- Specific Standards

6 Utilities Have Substantially Reduced Air Emissions While Increasing Electricity Production 1990 represents the base year. Graph depicts increases or decreases from the base year. Sources: U.S. Department of Energy, Energy Information Administration (EIA), U.S. Environmental Protection Agency (EPA), and U.S. Bureau of Economic Analysis. February by the Edison Electric Institute. All rights reserved.

7 Clean Power Plan: Timeline EPA to finalize goals/guidelines in summer 2015 States submit compliance plans to EPA for approval Due 2016; EPA has to approve (or not) in one year Extension to 2017 if making progress Extension to 2018 if working with other states Compliance starts in 2020 First reports documenting progress due 2020 Cover 2020 and 2021

8 Clean Power Plan: Key Issues for Power Sector Pace and timing of compliance/reliability Assumptions and approach to BSER Treatment of zero-emissions generation: nuclear & hydropower Treatment of new NGCC unit emissions Treatment of interstate renewables

9 Interim Goals Interim goal is actually a 2020 goal Reductions from increased use of existing NGCCs must occur by 2020 Creates emission reduction cliff For 80 percent of states, more than 50 percent of 2030 goal must be achieved by 2020 For 11 of those states, 75 percent or more of 2030 goal must be achieved by 2020 Only real option is to close coal plants by 2020

10 4 Out of 5 States Would Have to Achieve Most of Their 2030 Goals by 2020 AK 44% CA 67% OR 71% WA 78% NV 69% ID 66% AZ 90% UT 75% MT 50% WY 54% CO 78% KS 53% NM 72% ND 67% SD 67% NE 54% TX 72% OK 70% MN 85% IA 61% MO 62% AR 84% LA 77% WI 72% IL 66% MS 77% MI 72% IN 57% AL 56% KY 57% TN 74% OH 55% GA 80% WV 42% SC 82% PA 49% FL 76% VA 63% NC 71% VT NY 58% ME 37% CT 46% NJ 43% MD 48% NH 64% MA 53% RI 32% DE 65% Percentage of 2030 goals that would have to be achieved by 2020 >75% 50% to 74% <50% HI 35%

11 The Cliff: 2020 is Tomorrow How do you comply with the cliff? Close coal plants (Other options? Not really.) If coal plants close, how do you maintain reliability? Build new EGUs (natural gas) Expand natural gas pipeline infrastructure Make adjustments to transmission system How long does that take? Plan, site, permit, build New EGUs = 3 years (or more) Gas pipelines = 3-5 years (or more) = 2022 > = 2027 > 2020 Transmission lines = average around 7-8 years, but may take as long as years

12 The Solution: Revise or Eliminate Interim Goal There should be no reduction cliff This will reduce reliability concerns States can choose when to close units, can wait for NGCCs and new infrastructure to be built Allows states to make investments in renewables and enduse efficiency EPA most likely to revise approach to interim goal calculation in final rule

13 Credit for Early Action Proposal allows limited compliance credit for actions taken before 2020 Final CPP should make clear that all post-2012 reductions count Proposal penalizes leadership in emission reductions and clean energy programs Pre-2012 reduction measures result in a lower baseline, more stringent goals

14 316(b) Cooling Water Intake Structures Final existing facilities rule published August 15, 2014 Avoids a categorical one-size-fits-all approach Standards largely reasonable, achievable, and appropriately flexible No mandate for closed-cycle cooling (e.g., cooling towers) Impingement compliance can be met through 7 different options Entrainment standards can be set site-specifically Implementation will present operational and compliance challenges Permit application requirements challenging, novel and problematic ESA permitting EPA contemplates compliance within 8 years Litigation proceeding; decision possible late 2016

15 Coal Combustion Residuals (CCR) Final rule published April 17, 2015 CCR ( coal ash ) regulated as non-hazardous waste Issues of concern: Self-implementation & citizen suit enforcement Regulation of inactive CCR impoundments Possible change in regulatory classification of CCR in future CCR legislation would address implementation issues and provide regulatory certainty

16 Waters of the U.S. (WOTUS) EPA-Corps proposed rule published April 21, 2014 Defines scope of waters protected under the Clean Water Act (CWA) Expands federal CWA jurisdiction beyond traditionally regulated waters Proposed WOTUS rule could trigger substantial additional permitting and regulatory requirements for utilities Affects new and existing generation (including renewables), transmission, distribution, and remediation efforts Comments submitted November 14, states and other stakeholders and industries oppose rule EEI supports a focused rule consistent with Supreme Court decisions EPA-Corps aggressively moving to finalize rule by June

17 Energy Legislation

18 Energy Legislation Both House and Senate energy committees plan to move broad energy legislation this session with markups & floor action by this summer Both committees starting to hold hearings on components of energy bills Key areas of interest will be: energy infrastructure development (transmission & natural gas pipelines), workforce development, energy efficiency, cybersecurity

19 Grid Security

20 ESCC Organizational Structure Electricity Subsector Coordinating Council (ESCC) 30 member body to serve as the principal entity coordinating with government counterparts on planning, preparedness, resilience, and recovery issues related to national security issues affecting the electric grid. Electricity Subsector Information Sharing and Analysis Center (ES-ISAC) Day-to-day operations run by NERC Leadership Co-chairs representing the three major industry segments Steering Committee NIAC representative, APPA, CEA, EPSA, ISO/RTO Council, NEI, NERC, and NRECA Asset Owners CEOs proportionally representing asset owners from across industry segments

21 Cyber Legislation Legislation is moving in Congress that would establish a framework, including privacy and liability protections, to promote more voluntary sharing of information between government and private companies about cybersecurity threats and defensive measures The House passed two complementary cyber information sharing bills the week of April 20 The Senate is expected to take up similar legislation by Memorial Day

22 Quadrennial Energy Review

23 Quadrennial Energy Review First installment of the QER, released April 21, is focused on energy transmission, storage, and distribution infrastructure Intended to provide a multi-year roadmap to study and identify challenges, and is tasked with: Reviewing federal energy policy with regard to energy infrastructure Reviewing the adequacy of existing executive and legislative actions Assessing and recommending priorities for research and development to achieve innovative goals Identifying analytical tools and data to support policy development and implementation

24 Distributed Generation

25 What Others Are Saying

26 What Others Are Saying

27 What Others Are Saying

28 Large-Scale Utility Solar PV Is About Half The Cost of Residential Rooftop Solar Source: GTM/SEIA Solar Market Insight Data is the average Q1-Q Data only includes cost of PV technologies

29 The Majority of Residential Rooftop Solar Customers Require a Connection to the Grid Source: Value of the Grid to DG Customers, Institute for Electric Innovation, October 2013

30 Changing Electric Distribution Grid: Centralized to Distributed Today Future Integrated Grid Platform Source: EPRI