Resource Documents: Delaware (4 items)
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Comments on Notice of Intent to develop a Draft Environmental Impact Statement (EIS) on US Wind Marwin and Momentum offshore wind Construction & Operations Plan, BOEM 2022-0025
Author: Stevenson, David
US Wind’s proposed offshore wind projects off the coast of Maryland will have direct impacts on Delaware as power is to be brought on shore, and turbines will be visible in Delaware. We represent over 1,400 individuals who have expressed concerns about offshore wind development to the Caesar Rodney Institute, and through the website Save Our Beach View. BOEM has stated they are accepting the Construction & Operations Plan (COP) as complete. We beg to differ and highlight below issues that need to be addressed before the COP is considered complete and before BOEM begins the EIS process.
David T. Stevenson
Director, Center for Energy & Environment
Caesar Rodney Institute
June 22, 2022
1. US Wind mistakenly claims emissions savings from the project, and emission savings are the core reason to build the project.
2. BOEM has no suitable study to determine the cost impact of viewshed loss.
3. Maryland shifts costs to, and interferes with interstate tourism in Delaware in violation of Interstate Commerce provisions of the US Constitution.
4. US Wind left several mitigation plans undefined and incomplete.
5. Cumulative impacts are missing from the COP.
6. Discussions of impacts on marine life are incomplete.
7. Commercial fishing will be abandoned in the lease area.
BOEM has a clear duty to protect historic and future users of the lease area from interference from industrial-sized wind turbines. Major negative impacts will be inflicted especially on commercial and for-hire fisheries, tourist viewshed enjoyment, vessel traffic, Coast Guard search and rescue operations, scientific research, and the endangered Northern Right Whale and other marine mammals. Fisheries face not only a direct loss of gear, but also increased risk of collision damage to their vessels, loss of life from hampered search and rescue operations, and loss of the scientific data needed to protect fisheries. Potential loses in tourism will exacerbate social injustice as losses will disproportionately impact lower-wage service workers in restaurants, hotels, and fishing tourism. The COP is missing key information and requires serious modification before BOEM can begin an Environmental Impact Statement.
Download original document: “Comments on Notice of Intent to develop a Draft Environmental Impact Statement (EIS) on US Wind Marwin and Momentum offshore wind Construction & Operations Plan, BOEM 2022-0025”
New evidence renewables don’t reduce carbon dioxide emissions
Author: Stevenson, David
This comparison of actual regional grid carbon dioxide (CO₂) emissions between 2019 and 2021 shows increased use of wind and solar did not reduce emissions. Wind and solar electric generation are actually poor technologies no one would use without permanent government mandates and massive subsidies and taxes that are adding $1 billion a year in power cost. They are also unreliable, non-recyclable, have negative environmental impacts , have shorter productive life spans than alternative power sources, and take up a lot of ground. If it doesn’t reduce carbon dioxide emissions why are we using wind and solar?
The PJM regional electric grid serves over 65 million people in thirteen states. It is the largest such regional grid providing 22% of the countries electric power. Table 1 below shows how generation from various technologies changed from 2019 to 2021, Key changes are:
- Natural gas replaced coal almost one to one as it has been doing so for about the last decade.
- Special oil based backup generators ran significantly more often.
- Total carbon based generation stayed about the same at over 60% of total generation.
- Zero emission nuclear generation fell over 2%, and hydro fell about 5%.
- Combined wind and solar generation grew about 30% replacing lower nuclear and hydro generation plus covering a 0.2% increase in total regional generation, but still only equaled about 4% of total production despite over a decade of mandates and subsidies.
- Overall the emissions fell 0.8%, a small improvement.
|Table 1: PJM electric generation by technology 2019 to 2021|
|Fuel||2019||2021||Change MWh||Change %|
|CO₂ systems mix||851.1926||843.3056||7.8870||−0.9%|
|Source: PJM Systems Mix |
Table 2 details the actual change in CO₂ emissions, but also considers how emissions may have fallen had the rate of emissions by megawatt-hour (MWh) remained the same as 2019. The key points are:
- Coal emissions should have fallen the same 7% generation did, but only fell about half as much as power plant efficiency fell.
- Emissions from oil based backup generation grew 60%, but efficiency improved about 25%.
- Natural gas generation grew 4.6%, but emissions only grew 3.6% as efficiency improved.
- Overall emissions would have fallen 2.3% instead of the actual 0.8% mainly caused by falling coal generation efficiency.
|Table 2: PJM Carbon dioxide emissions by carbon-based fuels|
|Fuel||2019 tons||2021 tons||Difference||% Change||2021 with 2019
|Source: PJM Systems Mix |
Fuel switching from coal to natural gas would most likely have occurred even if no wind and solar power were available. Natural gas has about 60% lower emissions than coal for each MWh produced. Some of that fuel switching was caused by lower natural gas fuel prices, and part was simply replacing closed coal- fired power plants. As generation at coal plants falls the plants become less efficient actually increasing emissions per MWh as shown in Chart 1 below. Coal plants were not designed for frequent stops and starts and doing so can more than double emissions per MWh of production. Calculating from PJM Systems Mix data shows coal emissions grew 3.4%/MWh. Without that increase the actual total emission reduction may have fallen 2.3% instead of 0.8%.
Solar and wind generation increased about 30%, or by 8.1 million MWhs. Nuclear power fell 6.3 million MWhs with 85% of that decrease related to the closing of the last unit at Three Mile Island. If you have been following the news many nuclear power plants are in financial trouble  and some plants are closing. Nuclear power generation has to be continuous as there is limited ability to ramp a plant up and down so those plants largely follow prices set by other generation sources. Federal tax credits for wind power of over $20/MWh  are awarded based on the amount of power generated and were close to the PJM average wholesale energy price for 2021 of $30.84/MWh . So wind projects will bid low or even negative prices sometimes to reap those tax credits and nuclear plants follow even when losing money. Hydropower is very flexible and can be ramped down if the prices go too low.
There is more to the story. Electric demand and supply must be in absolute balance every second or there are brownouts and blackouts. To keep everything in balance PJM can call on fast reacting oil and natural gas-fired generators known as peaking generators. They meet the demand but are less efficient than regular equipment and increase emissions. The tables shows a large increase in oil-fired generation, and emissions. That increase is likely a direct result of wind and solar power ramping up and down as the wind and sunlight stopped or slowed. Without that extra peaking plant operation total PJM emissions may have fallen another 0.2%.
This lack of CO₂ reduction by wind and solar comes at a high cost. Tax payers and electric customers provide expensive subsidies totaling almost $2 billion in the 2020-21 period, or $1 billion a year;
- Besides selling power into the competitive PJM market wind generation receives $18 to 23/MWh  in federal Production Tax Credits paid by taxpayers depending on the year built for an average of $20.50/MWh. With 54 million MWh produced in 2020 and 2021  the total cost was $1,107 million.
- PJM reports  show from 6/1/2019 to June 1/2021, 1,077 MW of new solar capacity was added. Reports from the Solar Energy Industry Association  indicate the average installed cost of utility scale solar with tracking over that period was $0.96/Watt for a total investment of $1,034 million. Solar projects received a 26% federal Investment Tax Credit from taxpayers, or $269 million.
- Four states (NJ, DE, MD, VA) participated in the Regional Greenhouse Gas Initiative that requires carbon based generators to buy allowances to emit CO₂. The cost gets passed on in electric bills. For example Virginia, the only one of the four states with integrated generation and distribution, received $228 million8 in RGGI taxes in 2021. Dominion Energy passed on $6.67/MWh to ratepayers, or about $80/year. In deregulated states the RGGI cost ($434 million in 2020-21) are passed on indirectly in higher average PJM energy prices.
In summary, the minor reduction in emissions occurred because lower emission natural gas replaced coal. The emissions reduction might have been as much as 2.5% instead of 0.9%. Increased reliance on intermittent wind and solar power increased the use of inefficient peaking power plants, and as generation volume at coal plants fell they became less efficient. Increases in wind and solar generation offset zero emission nuclear and hydro generation (84% of increase), with the balance going to higher overall PJM generation. The conclusion is wind and solar power are not yielding lower carbon dioxide emissions, but are adding $1 billion a year in costs. Without lower emissions why are we mandating and subsidizing wind and solar power?
1) Union of Concerned Scientists, “Environmental impacts of wind power”, https://www.ucsusa.org/resources/environmental-impacts-wind-power
2) PJM Systems Mix, https://gats.pjm-eis.com/gats2/PublicReports/PJMSystemMix
3) Institute for Energy Research, “Wind PTC threatens grid reliability”, https://www.instituteforenergyresearch.org/renewable/wind/wind-ptc-threatens-grid-reliability/
4) US EIA, Higher renewable capacity additions in AEO2016 reflect policy changes and cost reductions, https://www.eia.gov/todayinenergy/detail.php?id=26492 and Wind production tax credit extended to 2021, https://www.eia.gov/todayinenergy/detail.php?id=46576
5) PJM 2021 Markets Report, page 5, https://pjm.com/-/media/committees-groups/committees/mc/2021/20210503/20210503-item-07b-1-2021-annual-meeting-markets-report.ashx
6) PJM Capacity by Fuel Type, https://www.pjm.com/-/media/markets-ops/ops-analysis/capacity-by-fuel-type-2021.ashx and https://www.pjm.com/-/media/markets-ops/ops-analysis/capacity-by-fuel-type-2019.ashx
7) Solar Energy Industry Association, Solar Market Insight Report 2021 Q4, https://www.seia.org/research-resources/solar-market-insight-report-2021-q4
8) RGGI, Inc., Auction Results, https://www.rggi.org/auctions/auction-results
9) Caesar Rodney Institute, “Virginia your green new price tag is showing”
David T. Stevenson, Director
Caesar Rodney Institute Center for Energy and Environment
Download original document: “New evidence renewables don’t reduce carbon dioxide emissions”
Connecticut, Delaware, Economics, Emissions, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont •
Review of the Regional Greenhouse Gas Initiative
Author: Stevenson, David
The nearly decade-old Regional Greenhouse Gas Initiative (RGGI) was always meant to be a model for a national program to reduce power plant carbon dioxide (CO₂) emissions. The Environmental Protection Agency (EPA) explicitly cited it in this fashion in its now-stayed Clean Power Plan. Although the RGGI is often called a “cap and trade” program, its effect is the same as a direct tax or fee on emissions because RGGI allowance costs are passed on from electric generators to distribution companies to consumers. More recently, an influential group of former cabinet officials, known as the “Climate Leadership Council,” has recommended a direct tax on CO₂; emissions (Shultz and Summers 2017).
Positive RGGI program reviews have been from RGGI, Inc. (the program administrator) and the Acadia Center, which advocates for reduced emissions (see Stutt, Shattuck, and Kumar 2015). In this article, I investigate whether reported reductions in CO₂ emissions from electric power plants, along with associated gains in health benefits and other claims, were actually achieved by the RGGI program. Based on my findings, any form of carbon tax is not the policy to accomplish emission reductions. The key results are:
- There were no added emissions reductions or associated health benefits from the RGGI program.
- Spending of RGGI revenue on energy efficiency, wind, solar power, and low-income fuel assistance had minimal impact.
- RGGI allowance costs added to already high regional electric bills. The combined pricing impact resulted in a 13 percent drop in goods production and a 35 percent drop in the production of energy intensive goods. Comparison states increased goods production by 15 percent and only lost 4 percent of energy intensive manufacturing. Power imports from other states increased from 8 percent to 17 percent.
David Stevenson is Director of the Center for Energy Competitiveness at the Caesar Rodney Institute. He prepared this working paper for Cato’s Center for the Study of Science.
Download original document: “A Review of the Regional Greenhouse Gas Initiative”
Alberta, Arizona, Australia, California, Connecticut, Delaware, Denmark, Germany, Grid, Idaho, Illinois, Indiana, Iowa, Ireland, Italy, Latvia, Lithuania, Maine, Manitoba, Massachusetts, Michigan, Minnesota, Netherlands, New Hampshire, New Mexico, North Dakota, Ontario, Oregon, Poland, Portugal, Rhode Island, Spain, U.K., Washington •
Real-time wind production — various regions
Author: National Wind Watch
World: Current electricity production and consumption of “low-carbon” and “renewable” electricity – click an area for details
Europe: Quarter-hour load, generation, exchange – click on sample graph for other countries
Nordpool: Current production by source type in the Nordic power system (Norway, Sweden, Finland, Estonia, Latvia, Lithuania, Denmark)
Nordpool: Current power flow in the Nordic power system
West Denmark: Electricity prices, consumption, and production today, every 5 minutes
France: Quarter-hour consumption and production
France: Current, weekly, monthly, yearly demand and production
Germany: Quarter-hour net electricity generation
Germany: Quarter-hour wind production in EnBW control area (Baden-Württemberg)
Great Britain: Last 24 hours of generation by fuel type, every 5 minutes
Great Britain: Current, weekly, monthly, yearly demand and production
Ireland: Daily quarter-hour wind generation and system demand
Ireland: Quarter-hour system demand and fuel mix
Spain: 10-minute demand and generation share
Australia: Australian Energy Market Operator (AEMO, southern and eastern Australia): 5-minute and up to past year regional generation and fuel mix
Australia: AEMO grid (National Electricity Market): 5- and 30-minute aregional generation and fuel mix
Alberta: Monthly wind power forecast vs. actual comparison reports
Ontario: Latest hour of generation
Ontario: Daily hourly generation (scroll to bottom of table for wind plant)
Ontario: Hourly generation and other power data
Northwestern USA: Previous week, real-time 5-minute wind generation, Bonneville Power Administration
California: Daily hourly production, CAISO [click here to download complete report (PDF) from previous day.]
Barnstable, Massachusetts: hourly, daily, weekly, monthly, yearly production and consumption of a 100-kW turbine since June 1, 2011 (100% daily generation would be 2,400 kWh)
Scituate, Massachusetts: hourly, daily, weekly, monthly, yearly production and consumption of a 1.5-MW turbine since March 30, 2012 (100% daily generation would be 36,000 kWh)
Mark Richey Woodworking, Newburyport, Massachusetts: hourly, daily, monthly production of a 600-kW turbine since June 2009 (100% daily generation would be 14,400 kWh)
University of Delaware, Newark: current power output (kW) of 2,000-kW turbine