pjm-region-1024x657By Peter Galuszka

Amidst all the gnashing of teeth in Virginia about complying with proposed federal carbon dioxide rules, there seems to be one very large part of the debate that’s missing.

Several recent analytical reports explore using regional, carbon marketplaces to help comply with proposed federal Clean Power Plan rules that would cut carbon emissions by 2030. They conclude that the carbon goals can be attained more cheaply and efficiently by using a regional approach.

The lead study is by the PJM Interconnection, a grid that involves all or parts of 13 states including most of Virginia. Its March 2 report states that “state by state compliance options – compared to regional compliance options – likely would result in higher compliance costs for most PJM states because there are fewer low-cost options available within state boundaries than across the entire region.”

The same conclusion was made by another report by the Washington-based consulting firm Analysis Group on March 16. It states: “PJM’s analysis of compliance options demonstrates that regional, market-based approaches can meet Clean Power Plan goals across PJM states at lowest cost, with retirements likely spread out over a number of years.”

PJM set off in its analysis by setting a price per ton of carbon dioxide emissions with an eye towards the entities being exchanged among PJM-member utilities in a new market. The PJM report shows that electricity generation varies greatly among members. Some are farther along with renewables while others are greatly reliant upon coal.

By exchanging carbon units, some coal plants might actually be kept in service longer while overall goals are still achieved. EnergyWire, an industry news service, quotes Michael Kormos, PJM’s executive vice president for operations, as saying that the market-based carbon exchange, somewhat counterintuitively, might keep coal plants running longer.

“With the renewables and nuclear coming in as basically carbon free, we’re actually able run those coal resources more because they are getting credit from renewables and the nuclear as zero carbon.”

In December, PJM had 183,694 megawatts of generation. Some 67,749 megawatts are from coal-fired units.

Kormos says that a number of coal-fired units are going to be retired in the 2015 to 2030 timeframe regardless of what happens with the Clean Power Plan, whose final rules will be prepared by the U.S. Environmental Protection Agency later this year. The retirements of older coal plants are expected to involve a minimum of 6,000 megawatts of power.

It is curious that very little of this report is being heard in the vigorous debate in Virginia about complying with the Clean Power Plan. What you hear is a bunch of humping and grumping from Dominion Virginia Power and its acolytes in the General Assembly, the State Corporation Commission and the media.

This is not a new concept. Carbon trading is active in Europe and has worked here to lessen acid rain.

It is amazing that one hears nothing about it these days. It is shouted down by alarmists who claim that Virginia ratepayers will be stuck with $6 billion in extra bills and that there’s an Obama-led  “War on Coal.” The New York Times has a front-pager this morning about how Kentucky’s Mitch McConnell is taking the rare step of actually leading the “War on Coal” propaganda campaign.

Also strange, if not bizarre, is that this approach is precisely market-based which so many commentators on the blog claim to worship. Where are they on the PJM idea? Has anyone asked Dominion, which is running the show in this debate?


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26 responses to “Carbon Cuts: Why PJM Has a Better Idea”

  1. The PJM approach may have merit, and it’s something that Virginia legislators should have examined before passing legislation. Anything that could delay the phase-out of perfectly good coal-fired power plants should be considered.

    I have two questions: First, if Dominion purchases more electricity through PJM, does it have the transmission capacity to wheel the electric power into the state? Dominion withdrew the proposal to build a transmission line through Virginia’s northern piedmont a few years back. Would it have to revivify that project?

    Second, if CO2 emissions are being shut down across the PJM system, not just Virginia, will other power companies have enough spare generating capacity to take up the slack for Virginia?

    These are empirical questions that should be easily answered.

    1. Second question first: the answer is no. As Kormos said, there’s around 60K of megawatts of coal-fired power in PJM and around 1/10, or 6K mw, at significant risk. That’s a pretty widespread impact, and replacements will have to be built.

      As to your other question, my understanding is, the transmission capability between Dominion and the rest of PJM is generally pretty strong. There are pockets of Virginia, however, where constraints are forecast that will become increasingly troublesome unless fixed, and NoVa is where a couple of big ones are. For perspective on how relatively insignificant Dominion’s transmission problems are, see: http://www.pjm.com/~/media/committees-groups/subcommittees/rscs/20150219/20150219-item-02-2014-rtep-baseline-assessment.ashx Warning: there’s a major risk of TMI here; searching the document for substation names such as “Loudoun,” “Glebe” and “Skiffes Creek” will help zero in on Dominion’s problems.

      1. re: ” Second question first: the answer is no. As Kormos said, there’s around 60K of megawatts of coal-fired power in PJM and around 1/10, or 6K mw, at significant risk. That’s a pretty widespread impact, and replacements will have to be built.”

        where does PJM say that in their analysis?

        “As to your other question, my understanding is, the transmission capability between Dominion and the rest of PJM is generally pretty strong. There are pockets of Virginia, however, where constraints are forecast that will become increasingly troublesome unless fixed, and NoVa is where a couple of big ones are. ”

        once you get beyond the PJM links – isn’t Dominion responsible ?

        “For perspective on how relatively insignificant Dominion’s transmission problems are, see: http://www.pjm.com/~/media/committees-groups/subcommittees/rscs/20150219/20150219-item-02-2014-rtep-baseline-assessment.ashx Warning: there’s a major risk of TMI here; searching the document for substation names such as “Loudoun,” “Glebe” and “Skiffes Creek” will help zero in on Dominion’s problems.”

        yes.. but THIS is the analysis that should be compared and contrasted to Dominion’s words.

        there is a lot of info in the PJM report and a lot of “build” recommendations but they are not for more plants but more interconnections.

        In other words – they think there is another power generation – the problem is getting it to where it is needed – which reinforces my belief that the utilities are running some plants 24/7 as “hot ready” – not 24/7 power generation.

        that also sounds like what Dominion is trying to do with the James River line – and I suspect other places where interconnections would route power to where it is needed from existing running plants without having to fire up more plants.

        we’re basically burning coal – not to generate electricity but to have the ability to immediately respond to increases in demand.

        Can you imagine running the engine in your car in idle just so it would be ready for you to hop into when you needed it?

        that’s what I derive from some of the PJM analysis.. they don’t say it overtly – they just talk about more interconnections – but more interconnections won’t do you any good at all if the power generation is not available.

        they’re trying to build interconnections to access existing running plants…

        1. “where does PJM say that in its analysis?” I quote Peter, above: “In December, PJM had 183,694 megawatts of generation. Some 67,749 megawatts are from coal-fired units. [Mike] Kormos says that a number of coal-fired units are going to be retired in the 2015 to 2030 timeframe regardless of what happens with the Clean Power Plan, whose final rules will be prepared by the U.S. Environmental Protection Agency later this year. The retirements of older coal plants are expected to involve a minimum of 6,000 megawatts of power.”

          “once you get beyond the PJM links – isn’t Dominion responsible ?” Yes and no. PJM operates the grid, which is everything down to “distribution” which is commonly considered below 69kV, though in some areas there may be a different cut-off. PJM plans the grid — meaning, the VSCC and FERC insist that Dominion go to PJM to plan its transmission network. But Dominion builds it and owns it and maintains it and collects rates based on what it owns.

          “that’s what I derive from some of the PJM analysis.. they don’t say it overtly – they just talk about more interconnections – but more interconnections won’t do you any good at all if the power generation is not available.” PJM does not own generation; it provides a market for generation, and unified economic dispatch for generation that contracts to sell to PJM’s market, but there are hundreds of generation owners, many of them not utilities that sell at retail. If the generators don’t come, PJM cannot make them. What it can do is blow the whistle on an impending shortfall, alert the State Commissions and retail utilities to it, and get them hustling to find or build or solicit more new generation. PJM does not do that. But when it is built, PJM will make sure it can be delivered.

          1. “re: ” “where does PJM say that in its analysis?” I quote Peter, above: “In December, PJM had 183,694 megawatts of generation. Some 67,749 megawatts are from coal-fired units. [Mike] Kormos says that a number of coal-fired units are going to be retired in the 2015 to 2030 timeframe regardless of what happens with the Clean Power Plan, whose final rules will be prepared by the U.S. Environmental Protection Agency later this year. The retirements of older coal plants are expected to involve a minimum of 6,000 megawatts of power.””

            yep – I saw that. What I did not see was PJM wringing it’s hands and blasting the EPA for shortfalls. why not?

            “once you get beyond the PJM links – isn’t Dominion responsible ?” Yes and no. PJM operates the grid, which is everything down to “distribution” which is commonly considered below 69kV, though in some areas there may be a different cut-off.

            let me understand. PJM operates some of the grid in Va?

            ” PJM plans the grid — meaning, the VSCC and FERC insist that Dominion go to PJM to plan its transmission network. But Dominion builds it and owns it and maintains it and collects rates based on what it owns.”

            is the James River crossing endorsed by PJM as the right solution?

            “that’s what I derive from some of the PJM analysis.. they don’t say it overtly – they just talk about more interconnections – but more interconnections won’t do you any good at all if the power generation is not available.” PJM does not own generation; it provides a market for generation, and unified economic dispatch for generation that contracts to sell to PJM’s market, but there are hundreds of generation owners, many of them not utilities that sell at retail. If the generators don’t come, PJM cannot make them. What it can do is blow the whistle on an impending shortfall, alert the State Commissions and retail utilities to it, and get them hustling to find or build or solicit more new generation. PJM does not do that.”

            so PJM has not sounded the warning – why not?

        2. “is the James River crossing endorsed by PJM as the right solution?” Yes it was endorsed several years ago as the preferred transmission solution by PJM, accepted by FERC, and submitted by Dominion (as the builder) to the VSCC for siting approval, which has been hung up ever since over the siting/aesthetic issues and the politics of taking on the wealthy landowners of Kings Mill. See, that PJM 2014 RTEP document we referenced earlier, “previously approved project b1905.x.”

          1. PJM on perhaps the need for an interconnection but not where, I suspect, right.

            so my ignorance is on display again – PJM looks at the grid in Virginia, owned and operated by Dominion (and others) and recommends interconnections?

  2. re: “may have merit”.. hahahah bahahahaha

    what Peter asked in his excellent piece was WHY the PJM analysis is being ignored by Dominion, the SCC, the GA and you!

    why do you rely solely on Dominion’s minons to define the issue without acknowledging and discussion of the PJM view?

    so, you could now go back and write another article similar to what Dominion wrote except from a PJM perspective so you have some balance and Dominion won’t be able to re-write it.

    ouch!

    1. Larry, you can be so obnoxious! I haven’t *ignored* the PJM report. I have read the PJM report. I will report on the PJM report in my next blog post. I’m sorry I can’t pack a month’s research, analysis and writing on an unfamiliar and incredibly complex subject into two or three days, but I guess that’s just my failing as a human being. But don’t say I have ignored anything.

      1. I was being a smart butt – .. pulling your chain… mea culpa…

        you did a good job – that basically helped to get folks thinking about the bigger picture with PJM… your effort was substantial and it benefited every one of us who read it because it did get us to think about it.

        thanks!

      2. Well – this is one conversation that I felt was pretty narrow and one-sided that got properly re-contexted to a more legitimate and broader perspective.

        One of my problems here is Dominion’s involvement in politics, it’s influence in the Virginia GA as well as the SCC and their attitude about dealing with the public which comes across as ” do the exact thing we are wanting or bad stuff will happen” and ” no, we do not need to really justify our choices for where to put power lines or pipelines – we did our own study and we know what we want”.

        I will admit one thing and that is – dealing with the public now days and their preference for seeing things in sound-bite black and white views, both government and private industry has evolved to a philosophy of
        not really engaging the public.. but managing a PR process.

        but I still find a certain arrogance with Dominion much like I see in VDOT sometimes.. and so I do not take either one of their words as gospel without checking other sources.

        And that’s why I thought and still think – anything from Dominion – no matter how comprehensive it is – is, on it’s own, a managed PR effort rather than a truly trustable objective point of view and needs a context that includes others like PJM.

        If PJM agrees substantially with what Dominion is saying – I see that as having strength. If PJM is not saying the same things in terms of priorities – especially with regard to grid reliability – then I need to understand the differences and why.

        So one of the entire benefits of your blog – is – to challenge singular view perspectives whether they are you or others you are, essentially representing – when they are actively involved in the content.

        Even though you get beat up – and I claim my share .. some of it not entirely warranted – just razzing.. but others well deserved – you should see this as a tremendous success of your blog…

        you are NOT some loon standing on a soapbox blathering at folks who pass by.. you post substantiative ideas and content that are worthy of discussion – and I must say – one of few in number compared to some of
        the other stuff out there.. which unfortunately you have gotten into the habit of slurping at times.. but I digress.

        thank you – for BR and all you do. and if I need to say this more frequently, I will.

  3. Peter Galuszka Avatar
    Peter Galuszka

    Last I saw, they were looking to buy 1600 megawatts of power commerically through PJM for 2019-20. That’s about the size of a big plant.

    I don’t know if the NOVA line was all that essential. I think the one over the James is because they are shutting down pat of Yorktown.

    1. TMT – It’s never been and will never be what ONE or even TWO or THREE scientists assert… it’s a body of knowledge that is concurred with by many more.

      Hell’s Bell’s – Edison .. went around electrocuting elephants to “prove” that AC voltage was more dangerous than his DC invention.

      scientists have had in their ranks crackpots and quacks, thieves and even murderers since the beginning of science… but don’t confuse that with science and an agreed to body of knowledge…

  4. […] Cutting Carbon in Virginia – Amidst all the gnashing of teeth in Virginia about complying with proposed federal carbon dioxide rules, there seems to be one very large part of the debate that’s missing. (Bacon’s Rebellion) […]

  5. Peter Galuszka Avatar
    Peter Galuszka

    To be fair to Jim, the PJM report didn’t come out until the GA was pretty much over, so it may not have been something they might have been able to consider.

    At the same time, a regional carbon tax and market approach is so obvious that Dominion must know all about it and so, too, water carriers like TOmmy Norment and the Va. Beach senator.

    Larry has a point that all too often in Virginia, Dominion decides long in advance what to do then let’s us know how it will be.

    I could never figure why Republicans are so adamant about not using a carbon market approach to the CPP. It has been used by GOP leaders in other cases. Maybe Obama suggested it and that made it toxic.

  6. We have to see how the EPA Clean Power Plan shakes out in the final form, but if it’s anything like the proposal, VA will have to consider all options including regional approach. The PJM plan above alludes to VA being able to keep coal plants open by building more nukes. Both of which are my least favorite options.

  7. It seems clear to me that a regional plan would have merit. What manner of bizarre coincidence would have been necessary for the optimal electrical generation and distribution area to be the random borders of the Commonwealth of Virginia?

    Wind, tide, sunshine and other potential natural energy sources are not evenly distributed by state. Why shouldn’t electricity be made when it can be made cheaply (after factoring in the external costs of pollution)? There is some loss in transmission so that would have to be a factor.

    As far as an energy brokerage like PJM – why not? Peter is right – it is the essence of free market pricing – whoever is willing to pay the most gets the juice.

  8. “This is not a new concept. Carbon trading is active in Europe and has worked here to lessen acid rain. It is amazing that one hears nothing about it these days. It is shouted down by the $6 billion Virginia ratepayers will supposedly have to pay for carbon compliance and the “War on Coal” propaganda.” You are exactly right; even if you believe that carbon emissions should cease overnight, there is a huge necessary transition period, a huge phase-out cost; and a carbon tax is the fairest way to spread that cost around rationally and smoothly.

    Inasmuch as PJM is the system operator for a 12 state area embracing a staggering 180,000+ megawatts of power, and it’s in the business of running an electricity energy market, markets in electric capacity (reliability) futures and specialty products such as renewable resource power, and dispatching that power on a real-time locational-marginal-price basis, it has all the tools to handle the buying and selling of carbon emissions credits as well, across a very wide base. I’m not an apologist for PJM but I happen to believe they do what they do very well. If you want a market in carbon rights, they will administer it effectively and efficiently.

    But first: get the design of the market right:
    o Treat all fossil fuels the same in terms of their contribution to the greenhouse effect. It’s not just coal but also oil, and yes even natural gas, that emits CO2 when burned.
    o Be realistic about implementation timeframes consistent with a reasonable ramp-up of alternatives. Often those big coal units we want to retire are baseload, the most expensive and long-lead-time to replace.
    o Require this uniformly across, at least, the entire continental US. Broad-based markets cannot arise where each jurisdiction has its own rules. We’re talking Congress, in other words, and that is asking a lot these days.
    o Make a simultaneous pitch for demand-side-management of electricity consumption so consumers have their own way to participate in the market. This happens to be something PJM already is well equipped to handle.

    Now if we could accomplish all that, we still might have a few naysayers to convince. But WHETHER to try to reduce carbon emissions is another issue entirely.

    1. I think PJM is way more than a market myself.

      A “market” can say – for instance, “we’re out of product”.

      or they can say: ” we don’t have enough product to meet your demand”

      or they could say : ” power is very scarce.. right now.. it’s going to cost you 75 cents a kilowatt hour and even then we can’t fill your entire order.

      I think PJM mission is more than just a market.

      When PJM says – “we can’t help you – go do some rolling blackouts”..

      people will realize that it’s more than just a market.

      1. Yes — they have multiple goals, but the primary one is reliability (“keep the lights on”), which entails running capacity markets both next-day and long-term. They also do the transmission planning for the region. Once they have enough resources lined up to keep the lights on, they turn to how to do it at lowest overall cost through an implied instantaneous energy market based on locational marginal pricing. That’s what “economic dispatch” means.

        1. right – but what does their “build” plan mean when a lot of it is for new interconnections and not new generation sources?

  9. PJM makes Dominion look like an amateur when it comes to insuring grid reliability.

    Dominion runs around getting the SCC to hammer the EPA and tell the public that if they don’t get their way – places like Hampton will be “threatened”.

    Then we have PJM – whose mission is even more important and not one word of anti-EPA crud from their lips .. and they consider it THEIR responsibility to provide OPTIONS for maintaining and improving reliability.

    Now the other thing to notice about PJM is what kind of a critter they are.

    are they govt? are they private? do they have stockholders and shareholders? Are they for-profit?

    nope.

    they are a government-created critter – an RTO – regional transmission organization. RTOs were created by the Federal Energy Regulatory Commission (FERC) Order No. 2000, Issued on December 29, 1999.

    well , shut my mouth.. it’s a govt-sanctioned critter that has a helluva important mission that it appears to do pretty well . and not the slothful bureaucracy that Jim and Don B love to was loquaciously about from time to time.

    whatever happened to the free market ?

    and why is Dominion – a sort-of – free market critter not the equal of PJM when it comes to quietly getting the job done?

    oh.. and let’s not forget transparency and accountability.

    who do you pick? Dominion or PJM?

  10. “they are a government-created critter – an RTO – regional transmission organization. RTOs were created by the Federal Energy Regulatory Commission (FERC) Order No. 2000, Issued on December 29, 1999.”

    LarryG, you’ve hit on an interesting topic. PJM was originally a power pool, an association of eight utilities in the Pennsylvania and New Jersey and Maryland area (thus the name P.J.M.). It had a long tradition of operational independence from those eight members, but that wasn’t enough to satisfy the non-members (read: co-ops and munis) who also operated transmission in the area and were not members of the pool. So, in the 1990s PJM and its future members helped write the book for Order 2000, and simultaneously became one of FERC’s first examples of how an “Independent System Operator” should work. I know because I was deeply involved in negotiating and writing the agreements that created the PJM ISO and resulted in its expansion, among other things, to include Dominion, AEP and APCo, the three principal Virginia electric utilities.

    I think part of PJM’s success is that it was not so much imposed as evolved over the past 25 years to where it is today. PJM is now a limited corporation, even has a few assets of its own (e.g., computers and control center facilities), but does what it does through contracts with everyone involved to operate the grid, pursuant to which it gives orders to those on the grid when and how to operate, operates markets for energy, capacity, reactive power, d.s.m. and so forth, coordinates the scheduling of maintenance outages, determines the priority of applications to interconnect new generation to the grid and at what cost, and plans expansion of the grid to meet NERC reliability standards. PJM does not own the facilities it operates; it depends entirely on its members to build, own and maintain the grid’s generation and transmission under its operational control; and subject to FERC approval its members collectively can, in theory, tell PJM what to do. All these FERC deemed necessary attributes of a system operator that would be sufficiently independent to trust to operate markets without bias toward any participants, yet sufficiently competent to trust it with the reliability of the electric grid over a multi-state area. FERC dictates that the grid be run by ISOs in order to create a level playing field for market participants, but allows transmission owners and generators to choose which ISO to join.

    So, I disagree with the tenor of your comment that PJM is just a “government-created critter” — certainly it has deeper roots than your phrase suggests although the result, of course, is a government-sanctioned, government-regulated entity in compliance with Order 2000. I guess you could say the same of any utility, including Dominion too, except, Dominion is a shareholder-owned corporation with a great deal of investment in hard assets, not a membership corporation owning not much more than office equipment.

    1. thanks for the history – seriously.. I had read up in Wiki/other on it but you have a personal perspective and appreciated.

      on the govt part – once something extends beyond one state’s borders, it becomes an ICC type issue, I would think not dissimilar to insurance .

      but that alone does not require more govt control – they could have had an interstate charter… or who knows – I don’t, there are so many different ways.

      We’ve had brownouts and blackouts under PJM – also…. when they did all they could do but there was no more power available and the grid went down.

      because of that history of times when there was an actual shortage of power – I would have expected PJM to be front and center on any proposal to close plants…

      so that’s what I’m essentially asking. You posted a couple of PJM docs and I quickly went through them to see where they proposed a slew of interconnections but I found no worlds about closing plants or replacement plants – and I guess that surprised me given the words coming from Dominion that closing plants will stress their ability to maintain reliability.

      If Dominion is having that problem because of the proposed EPA rules, why are not the other states in the PJM pool and if true, why is PJM not expressing it’s concern also?

  11. slowlane Avatar

    Peter, your MAP has one inaccuracy. You omitted my home utility, “Southern Maryland Electric Company” – SMECO – which serves all of Charles, Calvert, and St. Mary’s counties, and a small part of rural Prince Georges, Maryland……………. Potomac Electric Power Company – PEPCO – serves ONLY Washington DC, Montgomery county, and 90% of Prince Georges county, Maryland.

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