Articles in this morning’s Boston Globe and Salem News describe an important shift in the status of Salem Harbor Station and highlight the need for ISO New England (ISO-NE) to go beyond the analyses it has done in the past so that it can finally identify an alternative that will actually solve the reliability issue that has dogged efforts to retire the plant since 2003.  That is the subject of the recent protest filed by CLF asking the Federal Energy Regulatory Commission to require ISO-NE to perform an expedited analysis of the alternatives and establish a timeline for implementation.

ISO-NE’s failure to identify solutions that will relieve the need for Salem Harbor Station has resulted in decisions that will cost ratepayers up to $18.5 million in above market payments in 2012-2013 and up to $16.9 million in 2013-2014. ISO-NE could avoid imposing these costs on ratepayers by implementing an alternative that would allow the plant to retire by 2012.

However, if ISO-NE rejects Dominion’s recent “permanent delist bid” – its latest and most telling signal that it wants to retire the plant – on the basis of reliability, ratepayers face the risk of even higher costs. The reality is that ratepayers pay more per kilowatt for electricity from Salem Harbor Station than they pay for other sources of electricity in the capacity market ranging from natural gas to nuclear and renewable.  This dispels the perception that coal is a cheap source of electricity.   Importantly, these additional costs aren’t spread among ratepayers throughout New England; instead, they are passed on solely to the ratepayers in northeastern Massachusetts, the same people who already bear the costs of additional medical expenses from the heart and lung diseases and other illnesses caused by pollution from the plant.  A study released by Clean Air Task Force concluded that pollution from the Salem Harbor Station causes 20 deaths, 36 heart attacks and 316 asthma attacks every year.

These costs diminish any economic benefits that the City of Salem receives from tax payments and jobs at the plant, and the likelihood that Dominion will retire in 2014 if its de-list bid is accepted makes it more important than ever that an alternative use for the site be developed to replace the facility.

Dominion’s claims that it is not planning to retire the plant contradict its own filings before the Federal Energy Regulatory Commission.  Continuing a tradition of telling the story that best suits its interests depending on the audience, Dominion told the Commission in a 2009 filing that it estimated only three more years of economic viability for the plant.  Dominion spokesman Dan Genest told the Salem News, “We know what it costs us to produce a megawatt of electricity at Salem Harbor Station, and the lower price at auction is not enough to cover our costs to generate electricity.” Despite its claims that it can continue to make profits in other markets, Dominion has said in its own filings that it was likely to lose money in those markets.

The bottom line is that ISO-NE has a responsibility to find an alternative to replace Salem Harbor Station that will cost less.  Now that the threat of even higher costs looms, protecting ratepayers demands a solution by no later than 2014, and the public health and environmental harms caused by the operation of this 60 year old coal and oil-fired relic weighs heavily in favor of shutting down the plant as soon as possible.

Local Activists from Salem Alliance for the Environment (SAFE) and HealthLink are hosting a Forum this Sunday that will expose the true costs of burning coal at plants like Salem Harbor Station.  The heat is on Dominion Energy to shut down Salem Harbor Station to allow the City of Salem and Massachusetts to usher in a clean energy economy that will provide sustainable and equitable jobs without jeopardizing public health or the environment.  Anyone who is interested in moving us towards a Coal Free Massachusetts should attend this event to find out more about the toll coal fired power plants take on communities from mining through burning and finally the disposal of ash.

For more information on how you can get involved check out the SAFE and HealthLink websites  CLF’s take action webpage.

There has been a significant development in the long running saga of the Salem Harbor power plant, one of the major targets of CLF’s Coal Free New England campaign. On October 5, Dominion Energy, the plant’s owner, quietly filed what is known as a Permanent Delist Bid with ISO New England (ISO-NE), the operator of the New England electricity system and markets. The filing commits Dominion to permanently withdraw Salem Harbor Station from the forward capacity market, the key market where power plants, and other resources like energy efficiency, are paid to be present, available and ready to meet the electricity needs of the region.

What does this mean?

By filing to permanently withdraw Salem Harbor Station from the forward capacity market, Dominion is signaling that it does not believe the market will be able to provide sufficient revenue to run the plant profitably and that it cannot maintain the plant going forward.

According to Paul Peterson, senior associate at Synapse Energy Economics, Inc., “The delist process was created specifically to allow power plants to withdraw from the forward capacity market, either temporarily or permanently, depending on their economics. A power plant that enters a permanent delist bid – an irrevocable decision that it will no longer try to earn revenue from that key market – is laying the groundwork to shut down.”

Although there are alternative scenarios that could allow Dominion to re-enter the market at a future date, the barriers to re-entry are extremely high and the process for doing so is complex.

Excessive ratepayer burden

Dominion’s move puts additional pressure on ISO-NE to implement a plan by June 2014 that does not rely on Salem Harbor Station to keep the lights on – ever. On October 14, CLF filed a protest with the Federal Energy Regulatory Commission citing ISO-NE’s failure to develop such a plan following the 2009 and 2010 auctions, keeping Salem Harbor Station available for “contingency” needs at enormous cost to area ratepayers. In our protest, CLF pointed to insufficient planning and loopholes in the ISO-NE process that have allowed Dominion to receive more than $30 million dollars in above market payments just to continue to exist, even while Dominion’s own filings indicated its intentions to leave the market. The company filed “static delist bids” for the past two years, a temporary exit measure that allows a company to receive above market payments if it is deemed necessary for reliability. Dominion’s ability to repeatedly game the system has forced ratepayers to bear the cost of maintaining an obsolete and polluting coal plant well beyond its useful life.

Buckling under pressure?

Salem Harbor Station is under increasing economic and environmental pressure. In June 2010, CLF filed a federal lawsuit against Dominion for repeatedly exceeding smokestack emissions limits at Salem Harbor in violation of the federal Clean Air Act. The suit would hold Dominion responsible for paying millions of dollars in penalties retroactively. Meanwhile, new EPA regulations on the near horizon will mean tougher pollution controls and multi-million dollar investments needed to comply with them. The permanent delist bid is a clear indication that Dominion doesn’t believe it can continue to wring dollars out of ratepayers for its obsolete plant for much longer, and we are making sure they won’t. Stay tuned.

Hotter Temperatures More than Doubled Smog Days in New England

On October 1, the EPA announced that the number of bad air quality days increased from 11 last year to 28 in 2010.  These are also known as “high ozone days” and are triggered when ozone levels exceed the standards EPA has set to protect public health. Excessive ozone, more commonly known as smog, results from a combination of nitrogen oxides, volatile organic compounds and heat and sunlight. Even short-term exposure to smog has been shown to shorten lives and cause other severe health impacts, including shortness of breath, chest pain, asthma attacks, and increased hospitalization for vulnerable populations such as the very young, elderly, and those already suffering from lung or heart disease. In children, smog can also result in dramatic long-term impacts such as reduced lung development and function.

The hotter the day, the worse the smog—and that smog is intensified by the increased use of electricity from coal and other fossil fuel-fired power plants when we crank up our air conditioners.  Emissions from cars and trucks add to the dangerous mix, and as climate change progresses, the temperatures continue to rise.

Until now, the greater Boston area had experienced an average of 14 days of 90 degrees or more per year. In 2007, the Union of Concerned Scientists had estimated that climate change would result in no more than 15-18 days of 90+ degree weather from 2010-2039.

But in 2010, Boston endured 23 days of 90+ degree weather, far outstripping both the annual average and predictions of what that number would be in the future.  Although EPA has proposed stronger emissions limitations for power plants and cars and trucks, the rapid rise in 90+ degree days is a side effect of climate change that has already been set in motion, and it will continue and worsen unless we take action now to reduce greenhouse gas emissions.

Coal-fired power plants rank as one of the primary culprits when it comes to emitting climate change pollutants and nitrogen oxides.  Across the nation, coal-fired power plants are the second largest source of nitrogen oxide emissions, and here in New England alone, eight coal-fired power plants churn out 10,515 tons of nitrogen oxide a year and millions of tons of carbon dioxide.  By contributing to climate change and increasing smog-forming pollutants, coal-fired power plants pose a major threat to New England’s air quality.  Creating a healthier future for New England means creating a Coal Free New England.  CLF is committed to shutting down each one of these polluting plants by 2020.  Work with CLF to create a thriving, healthy New England.

I’m one of those people who believes that climate change is the biggest challenge facing the planet, but I was baffled about how to react when I saw the Polar Bear ad for the Nissan Leaf®.  At first I thought it must be an ad by one of the national environmental groups, and I was shocked that they could afford the spot on the opening night of Thursday Night Football®.  When I realized it was an ad for an electric car, I couldn’t decide whether to be thrilled or concerned.  On one hand, I am thankful to see a multi-national corporation embracing the problem of climate change and investing in solutions.  Nissan’s commitment is virtually heroic when compared to the oil and coal industries’ multi-million dollar campaigns to confuse the world about the reality of climate change.  In addition, emissions from cars and trucks are one of the most rapidly growing sources of greenhouse gas pollution in the United States and worldwide, and electric cars are a promising solution. So why couldn’t I just enjoy the moment and applaud a victory in the climate change battle?

Two reasons.

First, fueling cars on electricity isn’t as effective if that electricity comes from coal-fired power plants. This is a real-world example of jumping “out of the frying pan and into the fire.”  If we reduce gasoline use but ramp up coal burning and all the things that come with it—mountaintop removal mining, strip mining, coal ash, mercury pollution and so on—then we reduce positive impacts of electric cars, and  contribute to plenty of other environmental damage.[1] Solving the problem of climate change demands action on all fronts, not just a transformation of the cars we drive, but of the electricity that fuels them and the rest of our society. If electric cars are really going to be part of the solution, then we must work to get renewable energy flowing through the transmission lines that power them. At the same time, we must also work to reduce our overall energy demand through energy efficiency and other new technologies.

Second, I love polar bears. Sometimes I almost cry during the Coke® ads, but I worry that when people see us pointing to polar bears and penguins as the victims of climate change, they will fail to see it as a problem that impacts people.  I understand that pictures of the wreckage from Hurricane Katrina,  victims of flooding in the Midwest or Pakistan or countless other “natural disasters” intensified by climate change are painful to see and painful to contemplate, but they are just as much the symbol of climate change as polar bears.

I know I can’t expect Nissan to focus its ad campaign on maximizing awareness and action on climate change, and that creating a market for and successfully putting electric cars on the road is already a big step forward; however, I hope ads like Nissan’s, will move people to think about all of the everyday choices we make that affect the climate and not just what kind of cars we drive Here are just a few of the ways that you can fight climate change:

1. Maximize energy efficiency at home. Check out some of the incentives and rebates available.
2. Ask your electric provider if they have a renewable energy option. National Grid offers a GreenUp option, and NStar offers NStar Green and a number of other providers.
3. Bike or use public transit whenever you can.  MassBike provides great information and training on commuting.
4. Become a CLF member to learn about climate change issues in Massachusetts.

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[1] Notably, this is less of an issue in areas like New England where natural gas power plants make up the bulk of the electric grid.

While the overarching environmental challenge of our time continues to be global warming we can’t loose sight of the need to confront the other air pollution that threatens the public health.  For those of us who fighting against dangerous pollution from coal fired power plants like Salem Harbor in Massachusetts this is not news – but the fact that a bi-partisan group of U.S. Senators (there is a phrase you don’t see much !!) have filed legislation to address this pollution is significant.   Exactly how good a bill is this?  We don’t know as they haven’t released the text and the devil (and god) are in the details.   But it is good to see our Senators paying attention to coal plant pollution !

Meanwhile, Tricia Jedele who runs CLF’s office in Rhode Island is helping to move ahead an effort to focus on the old school environmental value of waste reduction.  Reduce, Reuse and Recycle.  And she points out that the U.S. EPA have produced a very convincing report on how this classic brand of environmental action is good for the climate – bringing us back to global warming again . . .

The NY Times presents some required reading about how improvements in air pollution control technology can have the unpleasant consequence of putting pollution into our waterways.  The problem of contaminated coal ash is one that CLF has engaged for years – back in the year 2000 CLF negotiated a successful settlement with the then-owner of the Salem Harbor and Brayton Point power plants (PG&E) that cleaned up groundwater and land that had been contaminated by toxic coal ash over the course of decades – a settlement that predates the purchase of those power plants (out of bankruptcy) by Dominion – company that has its own checkered history regarding coal ash disposal.

Another manifestation of the same problem comes from the longstanding practice of using ash from coal fired powerplants as a “feedstock” for cement – iconic concrete structures containing coal ash include the Hoover dam, vast swaths of interstate highways and the tunnels and stations of the Washington DC metro.

More recently, coal plants have been awarded “carbon offsets” for selling ash to cement companies on the theory that use of ash “displaces” industrial kilns that produce greenhouse gas pollution while making cement.  Many organizations, including CLF, have expressed strong doubts about this practice – noting that it is simply paying coal plant owners once again for something they would have been doing anyway: turning a waste product into a revenue producing commodity.   A far better course of action, rather than create “rip offsets” that undermine climate protection while bestowing a windfall on polluters is to encourage processes and procedures that slash greenhouse gas emissions from cement kilns.

The increasing levels of toxic metals in the ash as air pollution regulations have tightened, is bringing an end to the practice of using fly ash in cement in projects designated as green under the LEED program of the U.S. Green Building Council and the innovative Collaborative for High-Performance Schools (CHPS).  Academic research strongly suggests that this is increasingly dangerous practice.

The bottom line is clear: coal is laden with toxic materials, and converting coal into energy, whether it be through burning it in the oldest or newest of plants (or even gasifying it)  releases these materials creating a serious toxic waste handling and disposal issue with potentially catastrophic effects if done badly.

The Federal Energy Regulatory Commission (FERC), in an order issued on September 18, 2009, has sided with the operator of the New England electricity system (ISO-NE) in a dispute with Dominion, the owner of the Salem Harbor Power Plant.

Here is the basic situation:  Dominion has “de-listed” the Salem Harbor Power Plant in the upcoming “Forward Capacity Auction”.   This means that it is virtually certain that in the 2012-2013 period that the plant will not be obligated to run and will not received capacity payments that power plants receive when they have such an obligation.   While the plant could still run and be paid for the electricity it made the act of de-listing means that the owner of the plant thinks there is a significant chance it will not be running during that year.  If, however, ISO-NE, finds that one (or more) of the  power generating units at the plant are “needed for reliability” then Dominion would receive payments set at the level of the “de-list bids” submitted this year.

Here is the dispute:  ISO-NE argued that Dominion had set the amount of its “de-list bids” to high.  Dominion had calculated those bids assuming that all pollution control equipment put into the plant would have to be depreciated (basically paid off) within three years.  ISO-NE argued that this was inappropriate. Local newspapers took note of this dispute.

CLF, and the Massachusetts Attorney Generals office, agreed with ISO-NE that Dominion’s bids were inappropriate.  CLF, pressing beyond the polite wording of ISO-NE’s filing, argued that the only appropriate circumstance for the “super-accelerated depreciation” being sought by Dominion would be appropriate only if Dominion were proposing to permanently de-list the plant.  The absurdity of Dominion’s position was highlighted by the fact that it was contradicted by public statements of its own spokesman in a local newspaper.

The Mass. AG, supported by CLF, also raised concerns about the lack of public disclosure of key information about the plant and the lack of auditing of the representations that plant owners like Dominion made to ISO-NE.

FERC, in the order resolving the dispute, accepted the basic logic that ISO-NE and CLF presented, requiring use of the longer depreciation period proposed by ISO-NE.   FERC stated that it could not consider converting a de-list bid from being one-year to permanent at this point in the process – which is essentially a moot point as CLF floated that as an idea that would only apply if the shorter depreciation period was accepted, which it was not. Also, FERC did not squarely address the issues of public disclosure and auditing, relying on earlier decisions that will be continued to be criticized.

But in the end this was squarely a defeat for Dominion: their bluff of calculating costs as if the plant was shutting down, but not actually committing to do so, was called.

These battles will continue.  The likely next dispute will center around “reliability” as all of these numbers games are meaningless if ISO-NE recognizes that the improved transmission system, new generation and rising amounts of energy efficiency and “demand response” (slashing energy use at peak hours during the summer) means that the plant can retire without causing any shortages in the regional electricity system.  They are very close to doing so (having found that other nearby plants can safely retire) and are likely to reach the right result here – although it might take some encouragement.

The Boston Globe today presents an excellent editorial on the misguided proposal for the power plant in Somerset Massachusetts:

ONE OF THE state’s “Filthy Five’’ coal-burning power plants is trying to turn itself into a Cinderella of clean-burning electricity generation. Since the makeover includes a first-in-the-nation commercial use of a certain technology to reduce dirty emissions, the state should give it a closer environmental review. (MORE)

This particular proposal is one that CLF is engaging in many ways, including in a pending court case (somerset-sc-clfs-memo-suppt-of-jdgmt-8-10-09).  And earlier on in the legal process this plant was (among other issues) discussed in an Op-Ed by Dr. James Hansen.  It has been the subject of ongoing upset, protests and opposition.

If you want to support our work on cases like this – go for it – or just comment below if you have a local coal fired power plant giving you gas.