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NH Considering pulling out of RGGI - Thursday hearing

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3mp_kwh

Active Member
Feb 13, 2013
1,170
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Boston
EPA Clean Power Progress in Granite State Under Threat / Public News Service

NJ already pulled out. This is relevant because the reinvestment of RGGI proceeds has helped fund lower emissions activity, such as the $2,500 ZEV credits in MA's MOR-EV program. In NH's case, they are not among other New England states, VT, RI, MA, (+NY), that make up the larger multi-state memorandum of understanding, to have 3.3mm PHEV/BEV on the road by 2025. If NH does pull from RGGI, however, the likelihood of joining such a program, or the funding of chargers, etc., all just becomes that much more remote.
 
NH would be foolish to leave RGGI until we see the EPA's new regulations on carbon. As part of RGGI, NH is already a long way towards compliance with the draft rules. Without it, the state will have to find ways to reduce carbon emissions within the state, which will almost certainly require the closure of PSNH's two coal-fired plants.
 
I agree, Robert, but NH seems like it has been given more to do under the EPA's proposal. Their 2030 target is 46% lower CO2, as measured over 2012 emissions. Sometimes that means a state with little fossil electricity left, who is already planning to shut down the rest.

Only because I need to get my arms around these rules, I took a detour and see EIA showed NH:
2012:
19.3 TWH total
1.3 TWH coal (seeing 2.9TWH '09, 3.1 '10, 2.2 '11...1.5 '14)
7.1 TWH nat gas (half as CO2 intense)

So, not even 10% coal makes rotation a simpler task, in the eyes of the EPA. To your point, I think it was Senator King's comments which suggested not enough "early adopter" credit has been given. His, and others, comments have been coming out since December. IMO, the rule goes too far to define "Clean Power", and deviates too far away from CO2. They don’t count all those 19.3TWH, not even close in NH case:

EPA is proposing to deduct almost all of NH's 8.2TWH of nuclear generation, in the same example (2012). This is to be done for all states. There’s only a couple tables in the entire rule. One shows NH as emitting 905lbs / MWH, as a 2012 baseline. The only way that state’s CO2 production from electric generation even gets this high is by taking the nuclear out. Shut down Seabrook, on top of Yankee’s recent closure (assuming imports), and this is tantamount to giving “Get out of jail free” cards, on CO2. So long as natural gas replaces nuclear, and you started with some coal, your EPA rate-based calculation improves (denominator goes up faster than numerator).

This is echoing in the comments I’ve read, and among folks I’ve met. There’s sort of a “Clean Power” vs. “CO2” fight going on, and it isn’t just with the nuclear industry.

http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposed-rule
 
Unfortunately, it's worse than don't care. Under the draft EPA regs, EVs would actually hurt compliance by increasing the amount of electric generation. Since marginal resources tend to be more carbon-intensive, increasing load increases CO2/MWh and moves the state further out of compliance.

Hopefully the EPA modifies this clear problem in the final regs.