Natural Resources Defense Council sells out California, again

The coal industry wants to build dozens of new coal plants in Wyoming, vastly increasing the amount of carbon dioxide getting pumped into the atmosphere, and laying waste to huge new stretches of Wyoming countryside. But it has to look like an environmental project. Oh yeah, and somebody else has to pay for it. The solution is to get Arnold Schwarzenegger, months after committing the state of California to the most ambitious carbon reduction target in the nation, to sign onto a new, expensive transmission line so that the coal-fired electricity can get to California in force, strangling the newly emergent renewable energy industry in its crib. The best part, since the wind blows in Wyoming as well as California, is that you can claim that you are building the transmission to support the new green, instead of the old black. The green part will never happen, of course. But memories are short, the life of big coal plants span generations, and the profit potential is huge.
There's an easy way to deal with this kind of fraud. Simply ask every politician with a hand in this atrocity whether the proposed Frontier transmission line will be carbon neutral or not. It's a simple, yes or no question, easy to understand. If you are trying to build a political constituency in California around the climate crisis, it is the kind of hot-button issue that organizers dream about.

So, what do the big environmental groups and renewable energy trade organizations in California do? they send a humble request for an opportunity to play with the big boys on our behalf:

Natural Resources Defense Council
Environmental Defense
Center for Energy Efficiency and Renewable Technologies
Western Resource Advocates West
Wind Wires

April 17, 2006

The Honorable Arnold Schwarzenegger
The Honorable Kenny Guinn
The Honorable Jon Huntsman
The Honorable Dave Freudenthal

Dear Governors Schwarzenegger, Huntsman, Guinn, and Freudenthal:

Your announcement today of plans by seven western electric utilities to assess the feasibility of a long-distance high-voltage transmission line that would originate in Wyoming and run all the way to California raises far-reaching public policy questions for the western region.  We are intrigued and encouraged by your statement that this would be the "largest clean energy enabling infrastructure project ever proposed in the West".

However, in our view, there are several clear requirements that must be satisfied before the project earns this designation.  It must address the challenges set out below.  Moreover, the selection of a route or routes and the impacts of coal mining must be weighed in evaluating the life-cycle costs of a project such as this.

The West is growing, and with that population and economic growth comes the need to provide electrical energy to our homes and businesses.  We know that congestion is already a problem on some transmission lines and will become a problem on other lines over the next twenty years.  We also know that the West has bountiful renewable energy resources ­ geothermal in Nevada, wind in New Mexico, Wyoming and the Dakotas, solar in Arizona ­ and that new technologies for using coal with significantly reduced emissions of pollutants that damage health and scar the skies, and the capacity to capture global warming pollutants, are ready to be deployed across the West.

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One challenge for you and for this new study is to find a way to ensure that new transmission line capacity is an integral part of a sustainable energy future that relies on renewable energy resources and coal plants that meet California¹s clean air and global warming standards, including the new performance standards for baseload power generation seeking long-term utility investment, and not on outdated technologies that foul the air and waste scarce western water resources. The Balanced Energy Plan published by Western Resource Advocates, convincingly demonstrates that a strategy of relying on investments in energy efficiency and renewable energy resources is less costly, cleaner, and as reliable as a strategy that relies on new conventional coal-fired power plants with all their environmental and economic risks.  To qualify as a clean energy enabling project, a transmission project should place a priority on transmission corridors that deliver renewable energy and that facilitate carbon capture and sequestration.  

A second challenge will be to identify the costs of a long-distance high-voltage transmission line and to fairly evaluate whether such an alternative makes sense when compared to other alternatives for generating electricity and moving it to places where demand is growing.  Our analyses suggest that there are lower-cost alternatives for both generating and transmitting electrical energy to places like southern California, Las Vegas, and Phoenix that would not require the kind of enormously expensive projects as the Frontier line.   The feasibility study should consider all cost-effective energy efficiency measures, nearly always the cheapest, quickest energy resource, and an effective tool to decrease grid congestion. Since planning and developing a project on the scale of the Frontier Line is also a long-term process, the study should also evaluate the incremental, near-term, and economic transmission alternatives recommended by a broad range of stakeholders in the Rocky Mountain Area Transmission Study.

A third and related challenge is to objectively explain whether and under what conditions the electric utilities participating in this study should be allowed to recover any of their costs from ratepayers, and what state and federal agencies will review those requests.  While we have open minds on the subject, we are appropriately skeptical (considering the many billions of dollars at issue) that the Frontier line makes economic sense.  We are equally convinced that state public utilities commissions should have an important role in deciding the allocation of any costs for new transmission.

Finally, the fourth challenge that we pose to you today is to devise an open and transparent process that gives all stakeholders the ability to participate in this study. When several Western governors announced the idea of a Frontier line over a year ago, they committed to a fully open and public process.  Yet the announcement today largely reflects a series of closed door meetings in which the public and their representatives were not involved. If this project is to be credible ­ and if this study to which you and the electric utilities today commit themselves is to be credible ­ then the public must have a seat at the table.

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The project upon which you are embarking represents a massive, enormously expensive solution to meeting the West¹s growing demand for electrical energy.  It may be a good idea.  It may not be a good idea.  Today we call upon you to ensure that the study is open and transparent and is designed to promote a clean energy future and not a dirty energy future.

Ralph Cavanagh
Natural Resources Defense Council

Vickie Patton
Environmental Defense
Rocky Mountain Office

V. John White
Center for Energy Efficiency and Renewable Technologies

Roger Hamilton
West Wind Wires

James Martin
Western Resource Advocates

The problem here is not just the re-emergence of the same old minions of the Western nuclear and aluminum industries that were so instrumental in wrecking the Columbia River, now leading the charge on behalf of new coal plants. And it's not just because the contribution of wind from Wyoming over the next couple of decades will be relatively teensy no matter what we do, simply because it will take decades to build the kind of capacity that will make a substantial difference on the scale of a California-sized grid, and that  a big transmission line won't wait around for someone to build a way to make politically correct electrons.

It's because the NRDC/EDF/CEERT/WWW/WRA letter is, not to put too fine a point on it, lame.

I can write the script from here. The humble request is eagerly accepted by the pro-coal parties who want to build the line. Problem solved! The Frontier transmission line disappears off of the political radar, into an endless series of meetings in windowless hotel ballrooms all over the western United States. At the end of the day, a token amount of transmission capacity actually moves electrons from genuine renewable projects in the Northern Rockies, and the bulk transmission capacity goes to a new generation of "clean" integrated gas combustion turbines burning Wyoming coal and allowing California to greenwash its carbon footprint by importing dirty electricity from someplace else. Victory is declared. Just as NRDC was the handmaiden that enabled California's catastrophic experiment in deregulating electricity in the late 1990's, they become enablers for a massive new increment of coal-fired electricity in Western power markets.

I do not dispute the good intentions of the NRDC/CEERT/WWW/WRA axis. This is an argument about tactics and strategy. What is frustrating about seeing the beginning of yet another process that will result in the long-term public interest getting rolled again, with the active assistance of environmental advocates, is that there is a much cleaner and more effective way to parse this issue, and to actually build a real, live, effective political constituency around it at the same time.

Instead of negotiating about how clean the coal has to be or how discriminatory transmission of intermittent renewables can be, simply establish now, at the outset, that any electricity that moves on the line must have zero net emissions footprint. For coal, that automatically mandates the cleanest possible coal technology and requires full, verifiable carbon mitigation. The range of negotiable issues gets much smaller.

In the absence of a viable national or global market for carbon emissions, the Euro carbon market (current pricing of around $30/ton) is a reasonable interim proxy for pricing the carbon premium that coal-fired generation would pay. A realistic on-site carbon capture solution - the alternative if we weren't such reasonable people - would cost far more.  California is big enough to put together a viable regional carbon trading market, so we can tie into that price once the CCX is up and running. The California carbon clearing price would instantly become the de facto US price point for carbon emissions. From an engineering cost perspective, we've known for nearly 20 years the rough order of magnitude of that price if we are serious about limiting carbon emissions - $30-$60/ton, or between one and two orders of magnitude higher than Oregon's current, token carbon offset price.

Demanding full emissions mitigation in order to play is simple to explain - no net impact compared to renewables - and implements the letter (and intent, if Schwarzenegger is actually serious) of California's worthy carbon reduction initiative. It makes equivocation much more difficult for politicians; they either walk their talk on carbon reduction, or they don't. Anything less assures the worst of both worlds; lots of new coal with lots of new carbon and a gilding of eco-repectability, eagerly supported by a cadre of pet environmental organizations.