Emails, Russ Keene, spokesman, Balanced Energy for Texas Coalition, July 2 and July 13, 2015
4:17 p.m.
BET is a statewide coalition of energy consumers, producers, and providers committed to supporting policies that preserve and promote Texas’s leading role in energy and economic development. The membership includes coal producers, transporters and industrial users, seeking a balanced energy portfolio for Texas.
Hope this is helpful - happy to try to be of further assistance where possible.
Cordially, Russ Keene
2:07 p.m.
July 13, 2015
BET was founded in 2010.
The 24 coal plant projected closing/retirements (of the state’s 41) due to CPP rule is derived directly from the EPA’s own Integrated Planning Model analysis. Each state has a EPA “budget” of allowable CO2 emissions; EPA’S IPM model predicted what the Texas budget rate of pounds of CO2 emissions per mega watt hour (853 by 2020 and 791 by 2030) would do to the Texas power plant fleet and it predicts the plants in the slide retiring by 2020-2025 even though none are scheduled to retire for any other operational or regulatory reason.
Re some claims the rule won’t “force” any specific retirements and that the states have “flexibility” in complying with their budgets, we find it a disingenuous argument given that the very assumptions built into the budget derivation assume fuel switching off of coal and the mandatory budget of 852/791 lb/MWh necessarily makes the majority, if not all, coal plants incapable of competing in a market forced to meet such an extraordinarily low budget.
Some additional information about the slides background is provided below. Also attaching a new slide for you comparing other states’ emission reduction targets per CPP.
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Russ Keene
EPA’s Integrated Planning Model (IPM). As reflected in the first slide of the first attachment *(entitled “June 22 Texas CPP and Haze Impact on Fleet Slides”), EPA’s IPM model, based on the budget proposed for Texas, projects the retirement of 24 of the 41 coal-fired units in Texas (reflecting 12,760 MWs of the 25,302 MW nameplate capacity of the Texas coal fleet). The remaining three slides in that attachment is a list of key data regarding the entire Texas coal fleet. The information in the retirement chart comes from two primary sources of information. The first source is EPA’s parsed data files available in the rulemaking docket. This includes files outlining how EPA’s Option 1 (all 4 BSER Blocks are utilized) impacts units in 2025, under a scenario where each state is responsible for complying with the rule, rather than compliance at a regional level. Attached to this email is the file in its original form, as well as an edited version which limits the file just to Texas units, hides certain columns, and highlights projected Texas retirements. The second source of information is not found in the rulemaking docket, but it is available on EPA’s Clean Power Plan IPM website (http://www.epa.gov/airmarkets/powersectormodeling/cleanpowerplan.html). Sorting this data requires additional work, as the RPE file does not identify units by name and combines some units by site. However, through an analysis of the description of the plants (location/region, capacity, fuel type, etc.), names were assigned. Then, each run was compared to determine if any plants were no longer included in the IPM run – a sign that the plants were no longer modeled as operating. The years of review were 2016, 2018, 2020, 2025, and 2030. A 2016 base case was also reviewed and is available on EPA’s IPM website (linked above). Looking solely at ERCOT as an example, while there are no plant names assigned, it is evident how fewer units are included under each run as years progress. Note that the chart demonstrates the point that significant retirements are expected by 2020, which is an extremely short timeframe that could expose the Texas market to dramatic reliability concerns. As described below, even those plants not projected by EPA to retire by 2020 are is put in serious jeopardy by the rule, as proposed, due to the budget EPA proposes to force Texas to meet and the assumptions built into EPA’s budget derivation.