iso new england environmental advisory group (eag) teleconference

DRAFT

ISO New England Environmental Advisory Group (EAG) Teleconference

February 12, 20109:30 – 11:30 AM

1

Environmental Advisory Group MeetingFebruary 12, 2010

© 2009 ISO New England Inc.

Agenda

Time Topic Presenter

9:30 1. Introductions and administrative J. Platts

9:40 2. EAG comments on 12/4/09 meeting summary J. Platts

9:45

3. ISO’s Peak Day NOx Analysis – Weighted Average NOx rates – Fuel-Gen sources for 500 MW decrement – Summary of analysis and results – Open Issues for regulatory agencies

W. Coste

10:30 4. ISO NE economic studies M. Henderson

10:45 5. Update on environmental issuesJ. Platts/EAG discussion

11:15 6. Other Major IssuesJ. Platts/EAG discussion

11:30 7. Adjourn

2

Introductions and Administrative

Jim Platts

3



2010 EAG Teleconferences/Meetings

• Proposed Dates– Apr il16– June 11– July 9– October 8– December 17

• Please register for each meeting through ISO TEN• Meetings will be on the ISO-NE calendar with the

registration link to ISO TEN: https://isone.cyberu.com/client/isone/default.aspx

4



RSP10 PAC Meetings

• The following are planned PAC meetings:– February 24 – RSP Planning Process Meeting – March 18 – Transmission Update, RSP Project Listing– April 27 – Resource Issues– May 25 – Environmental Issues

• Environmental regulations

• RPS and Queue resources

• Emissions report

• Regional Energy Efficiency Initiative (REEI)

• Solar developments

• Watch for changes to the PAC agendas

5

DRAFT

ISO-NE Peak-Day NOx Emissions Analysis (Continued from prior EAG meetings)

J. Platts W. Coste

6



Disclaimer

• ISO considers all the work done on the peak-day NOx analysis and the results presented to the EAG still preliminary.

• While these preliminary results seem intuitively correct they are subject to further internal review and documentation of the processes used.

7



NOx Rates Used in the Analysis

• The analysis used proprietary ISO NOx rates for generating units in the analysis of the 500 MW generation decrement at peak

• EAG members requested to review these rates

• ISO has developed weighted average rates for generation and fuel combinations of units in lb/mmBtu and lb/MWh. These are shown on the following two slides

8



ISO NE Weighted Average NOx Rates by Generation and Fuel Types – lb/mmBtu

9

0.000.200.400.600.801.001.201.401.601.80

CC N

G

CC L

FG

CC D

FO

FC N

G

GT

LFG

GT

DFO

GT

JF

GT

NG

IC N

G

IC L

FG

IC O

BG

IC D

FO

ST W

D N

ew

ST B

IT

ST W

D E

xist

ST R

FO

ST M

SW

lbs/

mm

Btu

Wt NOx Rate

Gen Fuel lb/mmbtuCC NG 0.019

CC LFG 0.071

CC DFO 0.140

FC NG 0.009

GT LFG 0.246

GT DFO 0.657

GT JF 1.091

GT NG 0.027

IC NG 0.010

IC LFG 0.282

IC OBG 0.300

IC DFO 1.679

ST WD New 0.075

ST BIT 0.136

ST WD Exist 0.191

ST RFO 0.204

ST MSW 0.430



ISO NE Weighted Average NOx Rates by Generation and Fuel Types – lb/MWh

10

lb/MWhGen Fuel Wt NOx Rate

CC NG 0.167CC LFG 0.816CC DFO 1.587FC NG 0.071GT NG 0.245GT LFG 2.951GT DFO 10.265GT JF 14.949IC NG 0.086IC LFG 2.826IC OBG 3.265IC DFO 17.875ST WD New 1.013ST BIT 1.330ST RFO 2.159ST WD Exist 2.583ST MSW 5.951

0.02.04.06.08.0

10.012.014.016.018.020.0

CC N

G

CC L

FG

CC D

FO

FC N

G

GT

NG

GT

LFG

GT

DFO

GT

JF

IC N

G

IC L

FG

IC O

BG

IC D

FO

ST W

D N

ew

ST B

IT

ST R

FO

ST W

D E

xist

ST M

SW

lb/M

Wh



Review of Purpose and Chronology• Purpose

– Examine NOx emissions on ISO-NE’s historic peak load days to provide a better basis for estimating future NOx emission reductions from energy efficiency during peak load periods

• Chronology– June 12th EAG meeting: ISO-NE proposed to analyze the five highest

peak load days for the years 2005, 2006, 2007 and 2008– August 14th EAG meeting: Presented some preliminary results based on

ISO proprietary generator NOx rates

– October 16th EAG meeting: Presented preliminary results for all 20 days based on EPA data and ISO data, for generators not in EPA database

– December 4th EAG meeting: Presented hourly incremental NOx rates and hourly rates for 500 MW load decrements using ISO data

11



Today Presenting Final Preliminary Results

• Using only ISO NOx emission rate data– At December EAG meeting provided:

• Peak hourly NOx rates for a theoretical 500 MW generation decrement for all 20 peak days

• Top 500 MW excluding conventional and pumped hydro bids

• EAG requested fuel types comprising 500 MW

• At this meeting ISO is providing new results:– Energy production by fuel and technology types comprising 500

MW each hour

– Corresponding NOx emissions by technology and fuel type

12



Hourly NOx Emission Rates for a 500 MW Generation Decrement from Peak Excluding Hydro Bids

13

0.00

2.00

4.00

6.00

8.00

10.00

12.007/

19/2

005

7/26

/200

5

7/27

/200

5

8/5/

2005

8/11

/200

5

7/17

/200

6

7/18

/200

6

8/1/

2006

8/2/

2006

8/3/

2006

6/26

/200

7

6/27

/200

7

8/2/

2007

8/3/

2007

8/8/

2007

6/9/

2008

6/10

/200

8

7/8/

2008

7/9/

2008

7/18

/200

8

Dec

rem

enta

l NO

x Em

issi

on R

ate

(lb/M

Wh)



July 27, 2005 – Fuels and NOx Emissions for 500 MW Generation Decrement

14

0

100

200

300

400

500

600

700

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

MW

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST0.0

0.5

1.0

1.5

2.0

2.5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Tons

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST

Blue is ST-RFO, Light blue is MSW-ST, Mauve is NG-ST, Aqua is FO2-GT, Maroon is JF-GT, Rust is FO2-IC, Green is Kero-GT



August 2, 2006 – Fuels and NOx Emissions for 500 MW Decrement

15

0

100

200

300

400

500

600

700

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

MW

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST0.0

0.5

1.0

1.5

2.0

2.5

3.0

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Tons

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST




August 2, 2007 – Fuel and NOx Emissions Sources for 500 MW Decrement

16

0

100

200

300

400

500

600

700

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

MW

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST0.0

0.5

1.0

1.5

2.0

2.5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Tons

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST




July 8, 2008 – Fuel Sources and NOx Emissions for 500 MW Decrement

17

0

100

200

300

400

500

600

700

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

MW

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Tons

Hour Ending

WDS ST

WAT PS

WAT HW

WAT HDR

WAT HDP

TDF ST

OBG GT

NUC ST

NG ST

NG GT

NG CC

MSW ST

LFG IC

KER GT

JF GT

FO6 ST

FO2 IC

FO2 GT

BLQ ST

BIT ST




Weighted Average NOx Rates by Generation and Fuel Most Used for Peak

500 MW – lb/MWh

18

0.02.04.06.08.0

10.012.014.016.018.020.0

CC N

G

CC L

FG

CC D

FO

FC N

G

GT

NG

GT

LFG

GT

DFO

GT

JF

IC N

G

IC L

FG

IC O

BG

IC D

FO

ST W

D N

ew

ST B

IT

ST R

FO

ST W

D E

xist

ST M

SW

lb/M

Wh

Fuels most used

lb/MWh

Gen Fuel Wt NOx Rate

CC NG 0.167

CC LFG 0.816

CC DFO 1.587

FC NG 0.071

GT NG 0.245

GT LFG 2.951

GT DFO 10.265

GT JF 14.949

IC NG 0.086

IC LFG 2.826

IC OBG 3.265

IC DFO 17.875

ST WD New 1.013

ST BIT 1.330

ST RFO 2.159

ST WD Exist 2.583

ST MSW 5.951



SUMMARY OF KEY RESULTS FROM ANALYSIS

19



New England 20 Peak Days’ Hourly NOx Emissions

20

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

NO

x (T

ons

per h

our)

Hour

NOx Emissions from EPA & ISO Data for(5) Peak Load Days per Year: 2005-2008

50719 50726 50727 50805 50811 60717 60718

60801 60802 60803 70726 70727 70802 70803

70807 80609 80610 80708 80709 80718

All time peak day

Peak Days:Yr/Mo/Day



New England 20 Peak Days’ Cumulative Daily NOx Emissions

21

0.0

50.0

100.0

150.0

200.0

250.0

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Cum

ulati

ve N

ox (T

ons-N

ox)

Hour

50719 50726 50727 50805 50811 60717 60718

60801 60802 60803 70726 70727 70802 70803

70807 80609 80610 80708 80709 80718

All Time Peak Day

Peak Days:Yr/Mo/Day



New England Hourly NOx Emissions from Power System Generators vs. System Generation Output

August 2, 2006 – Highest Peak July 18, 2008 – Lowest Peak

22

3

5

7

9

11

13

15

13,000 15,000 17,000 19,000 21,000 23,000 25,000 27,000 29,000

Hou

rly N

Ox

(ton

s / h

our)

Hourly Load

Midnight to 6 AM Morning Afternoon 6 PM to Midnight

3

5

7

9

11

13

15

13000 15000 17000 19000 21000 23000 25000 27000 29000

Hou

rly

NO

x(t

ons

/ ho

ur)

Hourly Load

Midnight to 6 AM Morning Afternoon 6 PM to Midnight



8/02/2006 – NE Hourly NOx Emissions from Power System Generators

23

Hourly System NOx vs. Generation Output

Hourly Incremental NOx Rate

3

5

7

9

11

13

15

13,000 15,000 17,000 19,000 21,000 23,000 25,000 27,000 29,000

NO

x (t

ons

/ ho

ur)

Hourly Load

Midnight to 6 AM Morning Afternoon 6 PM to Midnight-10

-5

0

5

10

15

20

25

30

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

(lb/M

Wh)

Hour Ending



Hourly NOx Emissions vs. System Generation at Peak NOx Hour for Peak-Load Day

24

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

22,500 23,000 23,500 24,000 24,500 25,000 25,500 26,000 26,500

NO

x (T

ons)

Generation (MW)

Peak Hourly NOx Rate = 4 lbs/MW/hr (slope of line)



Daily NOx Emissions Rate vs. Daily Peak System Generation for Peak-Load Day

25

0.0

50.0

100.0

150.0

200.0

250.0

22,500 23,000 23,500 24,000 24,500 25,000 25,500 26,000 26,500

NO

x (T

ons)

Generation MW

Daily NOx Rate = 50 lbs/MW/day (slope of line)



Hourly NOx Emission Rates for a 500 MW Generation Decrement from Peak Excluding Hydro Bids

26

0.00

2.00

4.00

6.00

8.00

10.00

12.007/

19/2

005

7/26

/200

5

7/27

/200

5

8/5/

2005

8/11

/200

5

7/17

/200

6

7/18

/200

6

8/1/

2006

8/2/

2006

8/3/

2006

6/26

/200

7

6/27

/200

7

8/2/

2007

8/3/

2007

8/8/

2007

6/9/

2008

6/10

/200

8

7/8/

2008

7/9/

2008

7/18

/200

8

Dec

rem

enta

l NO

x Em

issi

on R

ate

(lb/M

Wh)



Weighted Average NOx Rates by Generation and Fuel Types Most Used on Peak – lb/MWh

27

0.02.04.06.08.0

10.012.014.016.018.020.0

CC N

G

CC L

FG

CC D

FO

FC N

G

GT

NG

GT

LFG

GT

DFO

GT

JF

IC N

G

IC L

FG

IC O

BG

IC D

FO

ST W

D N

ew

ST B

IT

ST R

FO

ST W

D E

xist

ST M

SW

lb/M

Wh

Fuels most used

lb/MWh

Gen Fuel Wt NOx Rate

CC NG 0.167

CC LFG 0.816

CC DFO 1.587

FC NG 0.071

GT NG 0.245

GT LFG 2.951

GT DFO 10.265

GT JF 14.949

IC NG 0.086

IC LFG 2.826

IC OBG 3.265

IC DFO 17.875

ST WD New 1.013

ST BIT 1.330

ST RFO 2.159

ST WD Exist 2.583

ST MSW 5.951



Summary• Peak hour NOx emissions ranged from 6 to 13 tons over

the 20 highest peak-load days for 2005-2008• For the all-time peak load day (8/2/06), at the peak hour,

operating emergency generators added approximately 3 tons, or 12 total tons for the entire day

• Cumulative daily NOx emissions for each of the 20 peak days ranged from 122 to 228 tons, including emergency generators that operated on the all-time peak day

• Daily peak hour NOx rates and average daily hour are 4 lb/MW/hr and 50 lb/MW/day, respectively

• Generation and fuels most used on peak are– Steam with residual oil– Gas turbine with No. 2 oil and jet fuel– Combined cycle with natural gas

28



Open Issues for Regulatory Agencies

• Are these results useful? If so how should they be used by regulators?

• Which NOx rate will be used: the average peak-hour rate or 24 hour average?

• Should the New England state agencies apply these rates to determine reductions in generator NOx emissions

from energy efficiency?• Will EPA accept NOx reductions for SIP planning and

HEDD based on this peak day NOx analysis?

29



30

Questions

DRAFT

Stakeholder Process for Submitting Economic Study Requests

Michael I. HendersonDirector, Regional Planning and Coordination

PAC MeetingJanuary 21, 2010

DRAFT

Background



33

Objectives of “Attachment K” Analysis

• Satisfy Tariff requirements– Perform a Needs Assessment of economic considerations in

response to stakeholder requests

• Provide forum for stakeholder review of the impact of alternative future system scenarios– Include economic evaluations – Supplement with environmental emissions analysis– Consider potential economic benefits of relieving transmission

constraints• Also shows benefits of developing resources in alternative locations

– Similar to “what-if” framework of Scenario Analysis– Not an introduction to a specific Market Efficiency Transmission

Upgrade (METU), e.g., “Attachment N” project– Provides information to stakeholders



Needs Assessments for Economic Considerations

• Part 4.1.b of Attachment K states that “the ISO’s stakeholders may request the ISO to initiate a Needs Assessment to evaluate potential regulated transmission solutions or other participant-developed market solutions investments that could result in (i) a net reduction in total production cost to supply system load based on the factors specified in Attachment N of this OATT, (ii) less congestion, or (iii) the integration of new resources and load on an aggregate regional basis (Economic Studies)”

34



Submittal and Consideration of Needs Assessment Requests

• Requests for Economic Studies by stakeholders must be submitted by April 1 each year– These will be posted to the ISO website

• The ISO may add its own proposals• The ISO shall develop a rough scope of work and cost

estimate for all requested studies• The ISO shall develop a preliminary prioritization based

on perceived benefits• By May 1 of each year, a PAC meeting shall be held at

which Economic Study proponents provide an explanation of their request

35



Submittal and Consideration of Needs Assessment Requests, cont.• By June 1 of each year, the PAC shall meet, discuss and prioritize up

to 3 Economic Studies to be performed

– The costs will be recovered under the Tariff

– ISO will present a straw priority list

– Additional meetings may be held to discuss the prioritization or substance of the studies

• If agreement is not reached on prioritization or study substance, then the dispute resolution provisions may be invoked by any PAC member by August 30

• The ISO will issue a notice to the PAC detailing the prioritization of the Economic Studies

• There are no deadlines for completion of studies within the Tariff

36



37

Evaluation of Proposed Solutions• Possible next step

– Not part of “Economic Studies”

• Once a “need” has been identified through a Needs Assessment, the ISO evaluates proposed solutions (Part 4.2 of Attachment K)

• Solutions to a “need” may be market-driven or Regulated Transmission Solutions– Market solutions will be reflected in updated Needs Assessments

and the RSP as described– Proposed Regulated Transmission Solutions are developed or

evaluated through Solutions Studies, and approved and classified as Reliability Transmission Upgrades or Market Efficiency Transmission Upgrades under Attachment N as appropriate

DRAFT

Process for SubmittingEconomic Study Requests



39

Content of Economic Study Requests

• Indicate suggested general location and type of resource expansion along with relaxed transmission constraints – Example: Add 5,000 MW of wind injected into Orrington and

• Identify needed increase in transmission constraints to relieve all congestion

• Alternatively, suggest increase of specific transmission limits– Example: Increase Orrington – Boston interface by 4,800 MW

• Details of a specifically proposed transmission project aren’t required, but can be provided

• Energy Efficiency– Can be captured by simulating several years

• Example: stakeholders may assume load stays at the 2009 level

– Specific load reductions may be postulated



40

Process for Submitting Economic Study Requests

• All communications to ISO should be made to [email protected]

• Submit requests by April 1, 2010

• To better coordinate presentations, ISO will advise all requestors of all received requests and the time allotted for each presentation by April 8

– Presentation materials due to ISO by April 15

– Requestor presentations to be held at the April 27 PAC meeting

– Draft ISO-NE Scope of Work for Economic Studies will be discussed at the May 25 PAC meeting



41

Economic Studies – Samples

• Completed Economic Studies– 2007 Study – 10-year study of base system resource expansion

and sensitivity analyses to fuel prices and demand resources

– 2008 Study – 10-year study of postulated various expansions of resource additions and relief of transmission constraints

– 2009 Governors’ Request – Year 2030 analysis of large-scale integration of renewable resources in the 20-year timeframe

• Ongoing Economic Studies– 2009 Request – Year 2013 interregional analysis being

conducted by the Joint ISO/RTO Planning Committee (JIPC) showing the effects of increasing the transfer capability between New York and New England



42

Economic Study Metrics

• Production Costs

• Load Serving Entity Energy Expenses

• Congestion

• Interface Flow Duration Curves

• Fuel Use

• Environmental Air Emissions



43

Questions

DRAFT

Environmental Issues Affecting Three ISO/RTOs(Based on presentation by Peter Carney of NYISO to IPSAC meeting)

Jim Platts



Purpose

• Review key federal and regional environmental developments affecting some or all of the regions served by the PJM, NYISO and ISO-NE

45



Summary

• U.S. EPA developments in air and water regulations are likely to keep reducing power plants’ air and water environmental impacts over the next ten years

• The potential effect of these developments could be increased operating costs for fossil and nuclear plants

• This could change the capacity mix, interregional dispatch and transmission flows that could drive the need for transmission upgrades

46



Issues to be Covered

• Air regulations: Attainment of criteria pollutant standards– Ozone

– Sulfur dioxide (SO2)

– Particulate matter (PM)– Regional haze – Clean Air Interstate Rule (CAIR) replacement

• Mercury • Technology standards: MACT*, RACT* and BACT*• CO2 – EPA finding and rules, cap and trade

• Open-cycle cooling water (CWA Section 316b)• Coal combustion by-products

47

*Maximum Achievable Control Technology, Reasonable Achievable Control Technology and Best Available Control Technology


© 2009 ISO New England Inc. 48

Source: EPA Region 1 Presentation by Dave Conroy to CT DEP, 9/9/09



Source: EPA Region 1 Presentation by Dave Conroy to CT DEP, 11/13/09



Ozone Non-Attainment in the Northeast

50

Data is in parts per billion (ppb)



Ozone Developments

• States are planning for attainment of current ozone standard – 75 ppb

• On January 7, 2010 EPA proposed a new ozone standard in the range of 60 to 70 ppb

– Was challenged in court

– Final determination August 2010

– State Implementation Plans (SIP) due December 2013

51



Ozone Developments, cont.

52

State HEDD Commitment

Tons Percent

Connecticut 11.7 8.7%

New York 50.8 37.7%

New Jersey 19.8 14.7%

Pennsylvania 21.8 16.2%

Delaware 7.3 5.4%

Maryland 23.5 17.4%

Total 134.9 100.0%

• Ozone Transport Commission (OTC)– High Electric Demand Days (HEDD)– Six OTC states have HEDD commitment to reduce NOx on

HEDD days



New England 2008 Electric Demand vs. Ozone Violations: June through Sept 15

53

0

1

2

0

5,000

10,000

15,000

20,000

25,000

30,0006

/10

/20

08

7/8

/20

08

7/1

8/2

00

8

7/2

1/2

00

8

7/7

/20

08

7/1

9/2

00

8

9/5

/20

08

7/3

0/2

00

8

6/3

0/2

00

8

7/1

/20

08

8/1

8/2

00

8

7/1

0/2

00

8

7/2

8/2

00

8

7/3

/20

08

6/8

/20

08

6/2

7/2

00

8

8/2

5/2

00

8

7/1

1/2

00

8

8/5

/20

08

9/6

/20

08

8/1

4/2

00

8

6/2

4/2

00

8

6/2

3/2

00

8

7/2

6/2

00

8

9/2

/20

08

8/7

/20

08

8/6

/20

08

8/8

/20

08

8/2

/20

08

6/1

3/2

00

8

7/1

2/2

00

8

9/9

/20

08

6/7

/20

08

9/1

4/2

00

8

6/1

4/2

00

8

8/1

2/2

00

8

8/1

1/2

00

8

6/2

0/2

00

8

8/2

6/2

00

8

7/2

7/2

00

8

8/1

7/2

00

8

6/1

6/2

00

8

8/2

4/2

00

8

8/2

0/2

00

8

8/3

0/2

00

8

8/1

6/2

00

8

9/1

0/2

00

8

9/1

1/2

00

8

6/2

1/2

00

8

6/6

/20

08

9/1

3/2

00

8

8/3

1/2

00

8

7/4

/20

08

6/1

/20

08

Exc

eed

ance

Day

? 1

= Y

es

Pea

k E

lect

rica

l Dem

and

(M

Wh

)

Peak Electrical Demand Exceedance Day



NYISO NOx Emissions vs. NY Ozone Concentrations

54

NYCA NOx Emissions vs Ozone Concentration

y = 8E-05x + 0.0784

R2 = 0.1594

0.040

0.060

0.080

0.100

0.120

0.140

0.160

0.180

0.200

0.220

0 50 100 150 200 250 300 350 400 450 500

NOx Emissions (Tons)

Oz

on

e C

on

ce

ntr

ati

on

(p

pm

)



SO2 Emission Standards

• SO2 NAAQS 1971– Current standards

• Annual: 30 ppb

• 24 hour: 140 ppb

• Litigation requires EPA to issue a new standard by June 2010

• On December 8, 2009 EPA proposed to eliminate the 24-hour standard and establish a new one-hour standard in the range of 50 to100 ppb

• Most states in the three ISO/RTO Region will have some areas that may exceed the new standards

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Regional Haze Rule (RHR)

• SO2, NOx and PM contribute to haze which impairs visibility

• EPA RHR, passed in 1999, is designed to improve the visibility in 156 national parks and wilderness areas

• Final amendments issued in 2005– Affects facilities built between 1962 and 1977 with potential to

emit greater than 250 tons of visibility related emissions– Must use Best Available Retrofit Technology (BART)– A Mid Atlantic/Northeast Visibility Union (MANE-VU) of state and

federal regulators, is coordinating RHR planning and strategy to reduce 90% of the SO2 from 167 of the highest stacks at 100

generators– July 2013 Compliance

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*

* SIP = State Implementation Plan



Clean Air Interstate Rule Replacement

• 2005 Clean Air Interstate Rule

– Affects 28 states plus Washington DC

– Two-phase caps on SO2, NOx and PM designed to meet 1997 ozone standard

– In 2008 court remanded rule

– Later in 2008 EPA reinstated the rule while it develops a replacement rule for CAIR

58



Mercury

• February 2008 Clean Air Mercury Rule vacated by a federal court

• Litigation requires EPA to issue MACT regulations by November 2011

– Existing MACT: No less stringent than average emissions limit achieved by best performing 12% of sources

– New MACT: No less stringent than the emissions limit achieved by best controlled existing source.

• A number of northeastern states have mercury regulations setting emission limits for power plants

59



CO2 – EPA Finding and Rules

• Dec 7, 2009 EPA issued a CO2 endangerment finding

• EPA requires reporting of greenhouse gas (GHG) emissions starting 1/1/2010 for facilities emitting greater than 25,000 metric tons of CO2 equivalent (CO2e)– This translates to fossil plants greater than 10 MW if base loaded– First report due 3/1/11

• September 30, 2009 EPA proposed the so-called “Tailoring Rule” rule requiring permitting of GHG emissions– Plants emitting greater than 25,000 metric tons CO2e*

– Permitting will be through the Clean Air Act Title V air permit on its renewal every 5 years

– Requires BACT or energy efficiency measures yet to be defined

60

* e means equivalent to CO2 for the other five GHG in terms of global warming potential



CO2 Cap and Trade – RGGI

• Ten northeastern states cap and trade program completing its first year

– CO2 cap is 188 million (short) tons through 2014

– Held six allowance auctions: 2 in 2008 and 4 in 2009

– Sold 163 million 2009 allowances, 8 million 2012 allowances

– Total revenues: $494 million; allowance prices are ~$2

– 2008 emissions are 82% of cap

– Program to be reevaluated in 2012

– 2018 cap is 10% lower than current cap

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CO2 Cap and Trade – Federal

• Two main cap and trade bills in Congress

– Proposed 2020 caps are 17 to 20% below 2005 emissions

– Could be in place as early as 2012

• “Leaks” from Copenhagen

– Suggested reductions

• Developed countries: 25-45% in 2020 from 1990

• Developing countries: 15-30% in 2020 from 1990

62



Open-Cycle Cooling Water

• December 2008 Supreme Court decision determined that EPA could use benefit/cost analysis in applying Best Available Technology (BAT) for reducing cooling water entrapment and entrainment of aquatic organisms during water permit renewals

• EPA is deciding how it will apply BAT to water permits

• Possibility exists that cooling towers may be required when permits are renewed

63



Coal Combustion Byproducts

• US coal plants produce 121 million tons/yr of by-products

– 43% is used beneficially

– USDOE Goal: Reuse 50% by 2010

– DOE Study: If regulated under Resource Conservation and Recovery Act, it would cost U.S. coal plants $11 billion annually

• TVA Kingston plant ash pond spill has led to EPA review

– March 2008 EPA conducted coal ash impoundment surveys

– EPA was to release new regulations by year-end (2009)

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Implications for Region’s Power Plants• EPA air regulatory trends show tightening of air standards for

SO2, ozone, PM and mercury

• Coal plants may require scrubbers for SO2 and mercury reductions, NOx controls for ozone attainment and additional mercury controls

• HEDD states– Some oil plants may require NOx controls

– Peaking turbines may need to reduce output or add controls

• Long term, where feasible carbon capture and storage may be needed for coal plants

• Depending on EPA’s application of BAT for water permit renewals, cooling towers may be required as retrofits on larger existing fossil and nuclear plants with open cycle cooling

65



Summary• Regulations

– Add costs for emission allowances

– May require use of low-emitting fuels

– Could add capital costs for controls

– Fossil generating units may elect to limit energy production and reduce capacity rating during peak production periods

• Implementation of planned and pending air and water regulations may result in changing the mix and dispatch of interregional generation resources

• These regulations could lead to generating unit retirements

• The 3 ISO/RTOs need to continue monitoring environmental regulations and assess their impacts to ensure the interregional system remains reliable and capable of economic and emergency power exchanges

66



Next Steps

• NCSP09– Summarize environmental regulations affecting power plants– Summarize the status of renewable resource development and

wind integration issues

• NCSP10– Estimates of emissions: SO2, NOx and CO2 will be included in

production cost analysis being conducted

• Ongoing– Continue monitoring environmental regulations for impact on

system reliability and economic performance

67

DRAFT

Other Major Issues

EAG Discussion

68



NERC Early Retirement Study

• NERC is conducting a study to evaluate the potential for early retirement of fossil generators due to collective impacts of emerging environmental regulations:– Clean Air Interstate Rule– Clean Air Mercury Rule– Coal Combustion Residual Impoundments– Clean Water Act 316b

• Assumes no risk of climate legislation• Criteria for evaluation of potential retirement

– Compare incremental generic cost of environmental compliance to cost of replacement power for each fossil unit

– If the combined environmental compliance cost is greater than the cost of replacement power, the unit will be considered a candidate for retirement.

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70

Questions

iso new england environmental advisory group (eag) teleconference

Documents

iso new england

iso data

iso tenmeetings

proprietary iso nox

isone calendar

average nox rates

iso nox emission rate

peakday nox analysis