On Tuesday, November 17, 2015, the Rhode Island Energy Facility Siting Board (EFSB) opened a Docket (a “Docket” is a case or a litigation) to consider a proposal by a company named Invenergy to build a new, 900 megawatt (MW) gas-fired power plant in Burrillville, Rhode Island.
The proposal was not unexpected – it had been announced previously – so, the very next day, on Wednesday, November 18, CLF filed a formal motion to intervene in the EFSB Docket. You can see the Invenergy proposal (all 471 pages of it!) on the EFSB website (click on Oct. 29 filing); and you can see CLF’s Motion to Intervene, here>.
The Invenergy proposal raises multiple issues, including the cost of electricity to ratepayers and the overall reliability of our electricity grid in light of the recent retirements of several dirty old coal and nuclear plants. I will discuss those cost and reliability issues in future blog posts. But the overriding issue that the Invenergy proposal raises is climate change; CLF is opposing the Invenergy proposal because building a new $700 million, long-lived fossil-fuel plant would make it impossible for Rhode Island to meet its carbon-emission-reduction targets.
In its filing to the EFSB, Invenergy argues that, because 28% of the electricity generating capacity in New England is from dirty coal and oil, building this plant will lower carbon emissions by replacing higher-emitting coal and oil generation with lower-emitting gas generation. [Invenergy Cover Letter, p. 3.] In order to see why Invenergy is mistaken on this point, you need to know that, although 28% of the generating capacity in New England is coal and oil, those coal and oil plants almost never run. In fact, the overall fuel mix used in New England to produce electricity is under 6% for coal and oil combined.
Invenergy says that its proposed new plant will be a so-called “baseload” facility, operating most or all of the 8,760 hours per year. [Application, page 122, ¶ 5.] Thus, in order to make a fair comparison of the carbon emissions of this (proposed) plant with other, existing generation, you need to compare the emissions of this plant with the overall fuel mix used to generate all electricity in New England. A new gas-fueled combined-cycle gas plant, such as Invenergy is proposing, emits 900 pounds of carbon dioxide (CO2) per megawatt-hour of electricity produced; this is significantly higher than the average emission rate of 730 pounds of CO2 per megawatt-hour for the overall fuel mix in New England.
To put this into context, consider a typical central air conditioning unit for an average home, which uses about 1,125 kilowatt-hours of electricity per year. The resulting carbon emissions would be 1,010 pounds if the electricity came from the Invenergy plant, but only 820 pounds if the electricity came from the present, average New England fuel mix. That is a difference of nearly 200 pounds of carbon – from just one appliance in one house!
The short of it is that, while Invenergy pretends that its new plant will emit less carbon than current plants in New England, in fact it would emit more carbon.
Moreover, the plant would be long-lived. Invenergy says its new facility would be useful for at least 20 years, and maybe as long as 30 or 40 years! [Application, page 123.] Meanwhile, under the Resilient Rhode Island Act, Rhode Island is committed to reducing carbon emissions 10% below 1990 levels by 2020, 45% below 1990 levels by 2035, and 80% by 2050. These carbon-reduction emissions are the public policy of the State of Rhode Island, announced by the Rhode Island General Assembly. Building the new Invenergy fossil-fuel plant would make it impossible to reach those statutory goals.
Another troubling part of the Invenergy proposal is its stated intention of building two oil tanks, of a million gallons each, at the plant site. Invenergy proposes to burn oil if and when natural gas is unavailable.
As Invenergy itself is quick to point out, burning oil is much dirtier than natural gas. (In fact, this is one of Invenergy’s arguments in favor of its proposal!) But Invenergy is inconsistent on how much oil it really plans to burn. In its EFSB application, Invenergy predicts that it might have to burn dirty oil only 5 days a year [Application, page 51, ¶ 3.] Yet, in its Clean Air Act Permit application to DEM, Invenergy asks for permission to burn oil between January and December, up to 30 days a year. And, elsewhere in its EFSB papers [pages 31, 34] Invenergy asks for permission to burn dirty oil between January and December for up to 60 days a year!
The carbon-emission profiles of this plant would be very (very!) different, depending on whether the plant burns oil 5 or 30 or 60 days a year!
In future posts, we shall examine issues pertaining to ratepayer costs and the reliability of the overall electricity grid. These issues are important (in part because Invenergy relies on these issues in all of its promotional materials about the plant). However, it is important to keep in mind that the single most important issue posed by the proposal for a new power plant is climate change.
Building an expensive, new, long-lived, fossil-fuel-fired power plant now would make it impossible for Rhode Island to meet its climate goals. That is the key issue in this case.
TAKE ACTION AGAINST THE INVENERGY PLANT! Send an e-mail to Governor Raimondo telling her that you oppose construction of a new fossil-fueled power plant in Rhode Island because climate change is real, and building this plant will make it impossible for Rhode Island to ever meet its carbon-emission-reduction goals. Your e-mail will contain a link to this CLF blog post; please add your own comment to Gov. Raimondo to personalize your message.