Carbon and Climate Are the Main Issues in Invenergy Gas Plant Case | Conservation Law Foundation

Carbon and Climate Are the Main Issues in Invenergy Gas Plant Case

Jerry Elmer

This week, the Rhode Island Public Utilities Commission is hearing the Invenergy case. In a blog last week, I wrote about the overall structure of the case and that there are three main issues:

  • Whether the plant is needed for system reliability, which you can read about here.
  • Whether Invenergy has lied by grossly overstating the supposed ratepayer benefits, which you can read about here.
  • What the disastrous effects on our climate would be if we built a new, long-lived fossil-fuel plant now. On this subject, CLF is presenting expert witness, Dr. Timmons Roberts, whose blog (with a link to his full testimony) you can see here.

For CLF, carbon and climate change are the big issues, and today I want to examine Invenergy’s own figures about carbon.

Invenergy is presenting the expert testimony of Ryan Hardy, whose testimony is on the PUC website. Hardy says that Invenergy’s emission rate would be 760 pounds of CO2 for every megawatt-hour (MWh) of electricity produced. [Hardy testimony, page 19, line 22.]  Note that Hardy’s testimony was filed on April 22, 2016.

Hardy’s testimony is contradicted by Invenergy’s own filing with the Rhode Island Department of Environmental Management (DEM) for an air-emissions permit under the Clean Air Act. That application was filed last year, on October 30, 2015.

On a table presented as part of that application, Invenergy says that, actually, it will emit 781 pounds of CO2 per MWh – and that is only when it is burning fracked gas. [Table, line 14, column 2.] Invenergy also wants to burn dirty oil for 30 days a year, which will release 1,227 pounds of CO2 per MWh.  [Table line 14, column 3.]

Thus, the weighted average of carbon emissions (from both fracked gas and dirty oil) from the Invenergy plant would be 818 pound of CO2 per MWh. That may not seem like such a big difference, but over the course of a year, the actual emissions from the Invenergy plant would be more than 300 tons higher than Hardy’s incorrect figure would allow. (Did Hardy not even see Invenergy’s own submission to DEM? Or did he see it and not care?)

Here is an even more interesting figure: according to ISO-New England, the operator of our regional power grid, the current weighted average for CO2 emissions from all generators in New England (that is, including renewables) is 726 pounds of CO2 per MWh. You can see the ISO-New England report here; the relevant figure appears in the chart on page 20, in the bottom right-hand cell.

In other words:

  • Even Ryan Hardy’s false, low-ball estimate of carbon emissions from the spiffy, all-new, state-of-the-art Invenergy plant is higher than the current New England average for all generators; but
  • The actual, correct figure for Invenergy’s carbon emissions is higher than both Hardy’s false, low-ball estimate and much higher than the current New England average.

Of course, there is a broader issue. That broader issue is not how much carbon Invenergy will emit per MWh (although Invenergy should be called out for presenting false information to the PUC and to the public). The bigger issue is that, in light of the climate change emergency, it is wrong to build any new long-lived fossil-fuel plant now. This is a subject that Dr. Roberts discusses at length in his testimony. [See page 16, line 18, to page 18, line 18; see also page 31, line 20, to page 34, line 16.]  As Dr. Roberts put it:

“Building a new, long-lived, fossil-fuel fired power plant now would be going the wrong way . . . back toward higher [carbon] emissions.”  [Testimony, page 15, lines 11–12.]

And that is really the bottom line. The reason CLF is litigating in both the PUC and the EFSB to stop Invenergy is that in light of the climate change emergency, it is wrong to build any new long-lived fossil-fuel plant now.


Focus Areas

Climate Change


Rhode Island


Stopping Invenergy

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