(Casper Star Tribune, November 29) – Wyoming utilities will need to prematurely shutter four coal-fired power plants to meet the requirements of the Obama administration’s proposal to curb carbon dioxide emissions, the chairman of the Wyoming Public Service Commission argued in recent comments submitted to the U.S. Environmental Protection Agency.
Alan Minier, in a Nov. 21 letter to EPA Administrator Gina McCarthy, wrote that the federal proposal overestimates utilities’ ability to improve the efficiency of their coal-fired power plants, overstates the potential growth of renewable power and errs in its calculations concerning Wyoming’s natural gas generation.
As a result, Wyoming would need to close the Naughton, Dave Johnston, Jim Bridger and Wyodak power plants by 2030 to meet the EPA’s proposed 19 percent carbon reduction for the state.
“I’m trying not to sound alarmist, but it seems to me the scale at which this would affect us, because we are exporters of electricity and coal, I think it will impact our economy in a materially adverse way,” Minier said in an interview. “The biggest problem is the target because it is too aggressive for us.”
The EPA proposal calls for cuts in carbon emissions nationally 30 percent of 2005 levels by 2030. The plan assumes that emissions can be curbed through remedial action in four general areas: improved efficiency of coal plants, increased natural gas and renewable power generation and enhanced energy conservation measures.
Minier’s letter underscored Wyoming’s deep uneasiness with the proposal. The Cowboy State is the top coal producer in the country. Almost 90 percent of its electricity is generated by coal-fired power plants.
Many of the plan’s assumptions are ill-founded or, in Wyoming’s case, not applicable, Minier wrote. The EPA, for instance, targeted efficiency improvements of 6 percent at existing coal-fired power plants.
But in Wyoming, many of those efficiencies are already in place or are uneconomical, Minier said.
The EPA has argued that the efficiency improvements will pay for themselves in terms of fuel costs. However, the proximity of plants to coal mines in Wyoming means that utilities here pay less for coal and have less to gain from efficiency measures, Minier said.
The agency also overstates Wyoming’s renewable energy potential, assuming the state could install 9.4 million megawatt hours of low-carbon or no-carbon electricity generation by 2030.
That assumption is based on consumption from other states, a factor out of Wyoming’s control, Minier said. A more accurate assumption would be around 750,000 megawatt hours for renewables, the amount Wyoming is projected to consume by 2030, he argued.
Wyoming would not receive credit for large renewable projects, like the planned 2,000- to 3,000-megawatt Chokecherry and Sierra Madre wind project in Carbon County, he said. Credit for those projects would go toward the carbon targets of consuming states, Minier said.
Environmentalists said Wyoming should consider partnering with other states to limit emissions. Such cooperation has been encouraged by the EPA and makes sense given Wyoming’s role as an energy exporter, they said.
Richard Garrett, an energy analyst at the Wyoming Outdoor Council, said Minier’s comments paid no mention to why the EPA is pursuing the plan: climate change. But that isn’t a surprise, he said. The Public Service Commission’s role is to implement policy, not make it.
A renewable power standard, which would require a certain percentage of electricity to come from low-carbon sources, would help Wyoming meet the EPA plan. Meanwhile, the increased use of natural gas in energy-consuming states is a good thing, he said.
“Wyoming derives significant revenues from the sale of that gas,” Garrett said. “That looks like a win-win for the state and the environment.”
Shannon Anderson, an organizer at the Powder River Basin Resource Council, noted that Wyoming’s targeted reduction is modest compared with those of neighboring states.
Colorado and South Dakota need to curb carbon emissions by 35 percent, Idaho faces a 33 percent reduction, and Utah a 27 percent cut. Montana, which faces a 21 percent cut, has outlined five scenarios for meeting the EPA’s goal.
“As opposed to fighting EPA, Wyoming could work with them to make it good for the state and the nation,” Anderson said.
Minier’s letter confirmed the worst suspicions of the state’s coal miners, said Travis Deti, Wyoming Mining Association associate director. The plan’s intent is to kill coal, he said.
“You take away our customers as a coal industry, you cause us to shut down as well,” Deti said. “We feel that is by design.”