Feeds:
Posts
Comments

In reality, education reform is about economics. If done properly, it will attract/retain businesses, provide jobs, generate tax revenues, increase property values, reduce crime rates, and reduce the single largest item in the state’s budget. This was the direction taken in 1995 by Gov. Carper, State Superintendent Mike Ferguson, and a business consortium (DuPont, Bell Atlantic, Delmarva Power, Hercules, Zeneca, and Christiana Care) when they advocated for change in Delaware’s public education system.

To be clear, we must first distinguish between teaching and education. Teaching is a profession consisting mainly of teachers with special knowledge and training who exercise personal judgment in carrying out their responsibilities with students in the individual school buildings. The broader concept of education, however, is a business.

The 1995 concept of Delaware education reform was implemented in a pilot program at a school that proved to be very successful. In a study conducted by Dr. Gary Miron of the Evaluation Center at Western Michigan University at the request of the Delaware Department of Education and the State Board of Education, he observed that students at the new school were, “…outperforming their counterparts at similarly matched traditional public schools…”  The school achieved national recognition and generated a substantial operating surplus.

The essence of this bold plan was to shift operational decision-making authority from a school board and district into the individual school building. Control was now local and exercised by a principal working with teachers, answerable to parents with oversight and support provided by a board. Andreas Schleicher, a member of Rodel’s International Advisory Group, presented data at a Rodel Foundation Education Event to show that, when a school is given that type of autonomy, student performance is improved.

The significant reduction of district and board responsibilities should lead to a reduction of the number of school districts from 19 to 5 (1 in Sussex, 1 in Kent, 2 in New Castle, and 1 VoTech District.) New York City and Los Angeles each have only one school district.

Governor Carney’s first executive order creates a working group to consider a public-private partnership between Delaware’s Economic Development Office and the business community. Perhaps an education component should be added to the mix to reflect the previous business/education initiative. Recently the governor created a board to study government efficiency. Since education makes up about one-third of the state’s budget, if you have read this far in the article, you know this author’s position on education efficiency.

A reduced deficit, an improved economy, and higher student performance, now that’s a bold solution everyone can support.

Ronald R. Russo is a Senior Fellow at the Caesar Rodney Institute, and the Founding President of the Charter School of Wilmington.

7 1LINKEDINCOMMENT

The Obama Administration set records on expansive and expensive new environmental regulations.  In one example, compare the 56 federal implementation plans forced on states during the Obama years to the 5 total imposed by the combined Clinton and Bush presidencies.  Unfortunately, the Obama years also yielded the slowest regulation driven environmental gains in decades, 2% in seven years compared to 2% a year from 1980 to 2009.

The primary force for a better environment turned out to be innovations in natural gas production, a development the administration and environmental groups fought, that was carried out by private industry on private lands. Natural gas prices dropped 80% as producers figured out how to use horizontal drilling and hydraulic fracturing to release tightly held gas from shale formations.  Falling natural gas prices dragged down the price of coal and oil that shows up in lower electricity, gasoline, and heating costs, and is saving families over $1500 a year in lower energy prices!  Fuel switching from coal to cleaner burning natural gas at power plants added almost another 5% improvement in air quality.

Obama era regulations targeted three primary substances; ground level ozone and fine particles the Environmental Protection Agency claimed posed a health hazard, and carbon dioxide the EPA linked to rising global temperatures.  Ozone levels improved by 1% a year up to 2009, but only improved 1% in seven years under Obama.  Fine particles improved 3% a year up to 2009, but only improved 3% over seven years under Obama.  The Obama regulatory effort reduced carbon dioxide emissions by an amount that will lower global temperatures by 0.01°C by 2100, essentially zero impact!  Carbon dioxide reductions from power plants can be attributed 70% to fuel switching for lower prices, and 30% to new regulations.

EPA cost benefit analysis showed new regulations would cost tens of billions of dollars a year to implement.  Free market sources, such as, the US Chamber of Commerce, estimated the cost to more likely be hundreds of billions of dollars.  Either way, a lot of money for marginal air pollution improvements.

The problems don’t end with air pollution regulations.  Voluntary multistate programs to improve water quality in areas such as the Chesapeake Bay brought Water Quality Index improvements of 25-percent from 1986 to 2010. That improvement ended after the voluntary agreement became a regulation in 2010 requiring states to institute mandatory steps, such as, storm water management regulations.  No water quality improvement, but those regulations have managed to increase new home prices by $10,000 each in the Chesapeake watershed.

Aggressive requirements in motor vehicle miles per gallon standards were also mandated.  The latest information shows average MPG for the nations motor vehicle fleet actually dropped from 17.6 MPG in 2009 to 17.5 MPG in 2014.  The mandated MPG standards were unreachable and will likely be scaled back to a more practical level by the Trump Administration.

The Obama Administration, often through procedural short cuts and with support from questionable science, relied on ineffective regulations to “improve” the environment.  Predictably, results were poor.  We look forward to the Trump Administration rolling back bad regulations, and following the rule of law.  We expect a focus on actual improvements to the environment. This could include increasing infrastructure spending on securing drinkable water (remember Flint?), improving sewer systems, and reclaiming brownfields and Superfund sites.  Under the new administration, infrastructure spending could double without increasing the budget by using sources such as multi-billion dollar fines from the Volkswagen settlement for fudging tail pipe emissions, and other large settlements instead of handing them over to the Sierra Club and Greenpeace, favored interest groups of the Obama EPA administration.

For more details on air quality improvements see our study “Sorting Root Causes of Air Quality Improvements 2009 to 2015” at https://criblog.wordpress.com/2017/02/12/sorting-root-causes-of-air-quality-improvements-2009-to-2015/ .

David T. Stevenson, Director, Member Trump Administration EPA Transition Team

E-Mail: David Stevenson@CaesarRodney.org

Executive Summary

There are two pollutants listed for action in the Clean Air Act that still have potential negative health impacts according to the EPA; fine particles (PM2.5) and Ozone. Dramatically tightened rules from the Obama Administration on power plants, motor vehicles, and the Ozone National Ambient Air Quality Standard had essentially no impact on emission levels of those two pollutants.

A number of major regulations have been implemented since 2009. The motor vehicle industry saw a dramatic increase in the requirements for higher Corporate Average Fuel Economy, and tighter emission guidelines. Electric power plants have seen the most impact from regulation including the Mercury & Air Toxics Rule (MATS), the Cross State Air Pollution Rule (CSAPR), the Carbon Pollution Standard for New Power Plants which established New Source Performance Standards (NSPS), and the Clean Power Plan (CPP), all targeted at reducing the use of coal. Two reductions in the NAAQS for maximum Ozone levels tightened the standard by 12.5% and impacts all applications burning fossil fuels.

Fine particle levels were reduced by 3%, but 93% of the U. S. population already lives in areas in compliance with national standards. There was less than 1% reduction in Ozone levels between 2009 and 2015, and it is likely 2016 Ozone levels will show zero improvement from 2009 as it was a hot summer which leads to higher Ozone levels. It is unlikely the regulations will have any additional significant impact going forward. Regulations reduced Carbon dioxide emissions roughly 0.5 billion metric tons annually, but the impact of that on global temperatures in 2100 will be less than 0.01°C.

  • The entire country is in compliance for Carbon Monoxide, and Nitrogen Dioxide, and will be in compliance by the end of 2017 for
  • Sulphur Dioxide averaged 66% below the standard, and only ½% of the country is above the
  • Fine particles ten micrometers or smaller averaged 65% below the standard, and only 3% of the country is above the
  • Fine particles 2.5 micrometers or smaller averaged 29% below the standard, and only 7% of the country is above the
  • Ground level Ozone averages 1% below the standard, but 37% of the country is above the

The EPA publishes an aggregate of reductions in ambient air quality levels by averaging annual results for six pollutants and ground level Ozone. There have been major improvements with a net 62% reduction since 1980. However, progress since 2009 has been small with most of the improvement related to non-regulatory induced reductions in the price of natural gas. Pricing impacts can be seen starting in 2009 in lower operating hours for coal- fired power plants, with regulatory changes apparent beginning in 2012 with lower coal-fired generating capacity, so calculations are straight forward. Power plant air quality improvements are due 70% to lower natural gas prices, and 30% to new regulations.

Both influences are unlikely to lead to any further improvement in air quality. Regulatory changes for motor vehicles have had almost no impact as fuel use increased 3% and average fuel economy went down ½%. The EPA reported tons of emissions from motor vehicles dropped between 2009 and 2014; carbon monoxide by 16%, volatile organic compounds by 20%, and nitrogen dioxide by 26%. None of those pollutants currently pose a health risk as ambient levels are way below the point they impact health.

Motor vehicle emissions improvements should show up primarily in lower Ozone levels. Ozone ambient levels came down less than 1% in seven years. Clearly, the tougher motor vehicle standards had very little impact on ambient levels of Ozone. We suspect the lack of progress in improving Ozone levels is related to the fact we are most likely approaching natural background levels. Any regulation to reduce ozone will be very expensive with very little positive result.

The air quality impact of new regulations promulgated by the Obama Administration have pretty much run their course. The MATS regulation failed to follow the Administrative Procedures Act by not completing a proper cost/benefit analysis and was overturned by the courts. The Impact of MATS was already completed by the time the courts ruled, and those impacts duplicated most of the potential impact of the Cross State regulation. It is likely the Clean Power Plan will be overturned by the courts, and will certainly be withdrawn by the Trump Administration. The gasoline mileage targets set by the Obama Administration are unrealistically high, and are unlikely to have been met. The Trump Administration will likely review the targets and cut them back to more realistic levels. Plus, it takes fifteen years to turn-over the vehicle fleet so progress on reducing pollution will be slow.

Natural gas prices are unlikely to fall further.  In fact, it is more likely they will increase.

European natural gas prices are running 2.5 times higher than U. S. prices. There is a huge drive to export from the U. S. to Europe which requires expensive capital investment to liquefy the gas to allow shipment in an efficient manner. A number of Liquefied Natural Gas plants are under construction, and natural gas prices should rise as exports begin.  Higher natural gas prices should lead to a slight electric generation shift back to coal raising coal generation capacity factors. Some planned closings of coal-fired power plants will likely continue, but it is likely the plant closing trend would end under either administration.

Methodology

Break out the components of the aggregate air quality improvement reported by the EPA. Compare the timeline of potential key change agents to actual results and historic trends to determine the most likely change agents impacting air quality. Review data to quantify the relative impact of various change agents.

 

Criteria Pollutants

The Clean Air Act establishes a list of pollutants to be regulated by the Environmental Protection Agency. The EPA is to review National Ambient Air Quality Standards (NAAQS) for each pollutant every five years. Air Quality Monitoring Stations scattered around the country measure various pollutants. Dramatic progress has been made since 1980, and the first five pollutants listed below are now not monitored at most stations. The emission source relative contribution is listed in parenthesis.

CO – Carbon Monoxide, 69 sites (NAAQS 9 ppm 8 hour average, not to be exceeded more than once a year). The standard was last revised in 1971, there are no non-attainment areas with the national ambient average 84% below the standard, with the primary source of emissions being motor vehicles (54%), and miscellaneous sources (35%).

Lead – 8 sites (NAAQS 0.15 micrograms/m3 maximum of three month rolling average). The standard was last revised in 2008, there will be no non-attainment areas by the end of 2017 with the national ambient average 85% below the standard, with the primary remaining source being lead smelters.

SO2 – Sulphur Dioxide, 45 sites (NAAQS 75 ppb 99th percentile of one hour daily maximum, averaged over three years). The standard was last revised in 2010, there are 2 million people living in non-attainment areas in small pockets around the country with the national ambient average 66% below the standard, with the primary source being fuel combustion including coal- fired power plants (82%).

NO2 – Nitrogen Dioxide, 26 sites (NAAQS 100 ppb 98th percentile of one hour daily maximum, averaged over three years). The standard was last revised in 1971, there are no non- attainment areas with the national ambient average 55% below the standard, with the primary sources being motor vehicles (58%) and fuel combustion including power plants (29%).

Nitrogen Dioxide (NO2) is the primary source for Nitrous Oxide (NO) when ultraviolet light strips off an oxygen atom, and of other nitrogen oxides (NOx).  Nitrous Oxide is the required catalyst to create Ozone. It is produced directly from the burning of fossil fuels but is very reactive and has a short lifespan in the atmosphere.

PM10 – Particulate Matter ten micrometers or smaller, 171 sites (NAAQS 150 micrograms/m3 averaged over 24 hours, not to be exceeded more than once per year on average over three years). The standard was last revised in 1987, there are 9 million people living in non- attainment areas primarily in California and in pockets in other western states with the national ambient average 65% below the standard, with the primary source being miscellaneous including forest fires, dust, and volcanoes (87%), fuel combustion including power plants (5%), and industry (5%).

PM2.5 – Particulate Matter 2.5 micrometers or smaller, 480 sites (NAAQS 12 micrograms/m3 annual mean, averaged over three years). The standard was last revised in 2012, there are 23 million people living in non-attainment areas primarily in California with small pockets in Ohio and Pennsylvania with the national ambient average 29% below the standard, with the primary source being miscellaneous including forest fires, dust, and volcanoes (71%), coal-fired power plants (14%), motor vehicles (6%), and industry (7%).

Ozone – 212 sites (NAAQS 70 ppb annual fourth highest daily 8 hour maximum, averaged over three years). The standard was last revised in 2015, there are 119 million people living in non- attainment areas primarily in high population density urban areas with the national ambient average 1% below the standard. Ground level Ozone is not emitted directly, but is created in a chemical reaction between oxygen and volatile organic compounds, methane, and carbon monoxide in the presence of sunlight and a nitrous oxide catalyst. High temperatures accelerate reactions leading to summer time peaks in ambient Ozone levels. It is more difficult to weight Ozone precursor sources, but the EPA shows natural sources may make up 50%.

Nitrogen oxides come from motor vehicles (58%), and other fuel combustion including power plants (29%). Volatile organic compounds (VOC) come from industry (39%), natural biogenic (33%), and motor vehicles (23%). Other natural sources, such as, wildfires and methane also play a role. We do note maps of modeled ambient NOx levels show the greatest peaks near major highways and NOx is critical for Ozone production (see below map).

Source: ICF International using EPA Modeling Programs

 

Air Quality Changes

The EPA publishes an aggregate of reductions in ambient air quality levels by averaging annual results for six pollutants and ground level Ozone. Table 1 summarizes the raw data, and Table 2 summarizes the percent reductions with the data from the EPA Air Quality Trends website at https://www.epa.gov/air-trends. Table 3 lists emission inventory, and Table 4 highlights the percentage point improvement of each pollutant.

Table 1: Average Ambient Air pollution levels for fifty monitoring stations

Year CO Lead SO2 NO2 PM10 PM2.5 Ozone
1980 9.092754 1.84125 159.75778 108.49615 0.101198113
1981 8.999275 1.34125 151.87889 104.60385 0.095495283
1982 8.486473 1.073125 137.17778 104.94231 0.093757075
1983 8.60628 1.0925 147.22889 96.726923 0.101867925
1984 7.987681 1.0475 134.69333 92.902564 0.09403066
1985 7.480435 1.28875 138.61333 94.888462 0.093212264
1986 7.810145 0.7125 137.17444 96.985897 0.091691038
1987 7.046377 0.830625 134.07778 96.326923 0.095560535
1988 6.908696 1.42625 140.08519 100.50385 0.104970126
1989 6.953623 0.675 134.77185 98.411538 0.089396226
1990 6.478261 0.42625 120.15407 92.153846 84.9298246 0.089580189
1991 6.198551 0.35625 113.66222 92.973077 86.0233918 0.090209906
1992 5.714493 0.31375 110.71185 80.434615 74.5847953 0.084120283
1993 5.378261 0.2625 101.64296 78.126923 73.6461988 0.086837264
1994 5.553623 0.30125 103.8963 81.126923 72.702729 0.086521226
1995 4.997101 0.3275 94.824444 80.961538 73.168616 0.090599057
1996 4.614493 0.1975 87.677778 73.055769 65.4853801 0.085811321
1997 4.249275 0.1975 92.648889 69.919231 66.5964912 0.08509434
1998 4.105797 0.17875 89.708889 67.088462 62.5692008 0.090320755
1999 4.072464 0.20875 91.225926 71.403846 69.3489279 0.088084906
2000 3.585507 0.2175 82.716296 64.565385 65.6491228 13.500417 0.082063679
2001 3.355072 0.30875 85.546667 64.696154 64.3450292 13.2500051 0.083731132
2002 2.923188 0.14875 74.22963 61.880769 63.5643275 12.8225871 0.087933962
2003 2.749275 0.1325 78.805926 61.803846 67.3450292 12.3261245 0.082316038
2004 2.575362 0.27375 75.626667 56.267949 57.1345029 12.0194898 0.075070755
2005 2.322464 0.135 74.914074 55.94359 60.4269006 12.8213388 0.080023585
2006 2.252174 0.11875 68.854815 54.869231 61.0994152 11.6018527 0.079304245
2007 1.973913 0.109375 64.717778 53.192308 63.4951267 11.9017996 0.07925
2008 1.757971 0.11375 58.954815 52.2 58.91423 10.8493589 0.075245283
2009 1.723188 0.099375 50.815185 48 52.5087719 9.79977943 0.069929245
2010 1.636232 0.07625 46.25037 47.511538 53.0643275 9.89908439 0.073382075
2011 1.705797 0.08125 37.940741 47.863462 55.5438596 9.74826315 0.074410377
2012 1.567391 0.09375 36.683704 44.761538 53.380117 9.1044105 0.075929245
2013 1.473913 0.08 30.474444 45.850641 57.5438596 8.89536258 0.067299528
2014 1.398551 0.03625 31.934074 46.866667 55.0233918 8.7921365 0.068033019
2015 1.411594 0.02125 25.257778 44.603846 51.9415205 8.49430699 0.068995283

Table 2: Percent Reduction of Ambient Levels of Pollutants from a Base Year

Year CO Lead SO2 NO2 PM10 PM2.5 Ozone Average
1980
1981 -1.0% -27.2% -4.9% -3.6% -5.6% -8.5%
1982 -6.7% -41.7% -14.1% -3.3% -7.4% -14.6%
1983 -5.4% -40.7% -7.8% -10.8% 0.7% -12.8%
1984 -12.2% -43.1% -15.7% -14.4% -7.1% -18.5%
1985 -17.7% -30.0% -13.2% -12.5% -7.9% -16.3%
1986 -14.1% -61.3% -14.1% -10.6% -9.4% -21.9%
1987 -22.5% -54.9% -16.1% -11.2% -5.6% -22.1%
1988 -24.0% -22.5% -12.3% -7.4% 3.7% -12.5%
1989 -23.5% -63.3% -15.6% -9.3% -11.7% -24.7%
1990 -28.8% -76.8% -24.8% -15.1% -11.5%
1991 -31.8% -80.7% -28.9% -14.3% 1.3% -10.9% -27.5%
1992 -37.2% -83.0% -30.7% -25.9% -12.2% -16.9% -34.3%
1993 -40.9% -85.7% -36.4% -28.0% -13.3% -14.2% -36.4%
1994 -38.9% -83.6% -35.0% -25.2% -14.4% -14.5% -35.3%
1995 -45.0% -82.2% -40.6% -25.4% -13.8% -10.5% -36.3%
1996 -49.3% -89.3% -45.1% -32.7% -22.9% -15.2% -42.4%
1997 -53.3% -89.3% -42.0% -35.6% -21.6% -15.9% -42.9%
1998 -54.8% -90.3% -43.8% -38.2% -26.3% -10.7% -44.0%
1999 -55.2% -88.7% -42.9% -34.2% -18.3% -13.0% -42.0%
2000 -60.6% -88.2% -48.2% -40.5% -22.7% -18.9%
2001 -63.1% -83.2% -46.5% -40.4% -24.2% -1.9% -17.3% -39.5%
2002 -67.9% -91.9% -53.5% -43.0% -25.2% -5.0% -13.1% -42.8%
2003 -69.8% -92.8% -50.7% -43.0% -20.7% -8.7% -18.7% -43.5%
2004 -71.7% -85.1% -52.7% -48.1% -32.7% -11.0% -25.8% -46.7%
2005 -74.5% -92.7% -53.1% -48.4% -28.9% -5.0% -20.9% -46.2%
2006 -75.2% -93.6% -56.9% -49.4% -28.1% -14.1% -21.6% -48.4%
2007 -78.3% -94.1% -59.5% -51.0% -25.2% -11.8% -21.7% -48.8%
2008 -80.7% -93.8% -63.1% -51.9% -30.6% -19.6% -25.6% -52.2%
2009 -81.0% -94.6% -68.2% -55.8% -38.2% -27.4% -30.9% -56.6%
2010 -82.0% -95.9% -71.0% -56.2% -37.5% -26.7% -27.5% -56.7%
2011 -81.2% -95.6% -76.3% -55.9% -34.6% -27.8% -26.5% -56.8%
2012 -82.8% -94.9% -77.0% -58.7% -37.1% -32.6% -25.0% -58.3%
2013 -83.8% -95.7% -80.9% -57.7% -32.2% -34.1% -33.5% -59.7%
2014 -84.6% -98.0% -80.0% -56.8% -35.2% -34.9% -32.8% -60.3%
2015 -84.5% -98.8% -84.2% -58.9% -38.8% -37.1% -31.8% -62.0%

Table 3: Emission Inventory in millions of short tons

CO 09  

14

SO2 09  

14

NO2 09  

14

PM10 09  

14

PM2.5 09  

14

VOC 09  

14

Motor Vehicle 43.36 36.30 0.25 0.10 9.60 7.16 0.54 0.49 0.49 0.35 5.12 4.12
Fuel Comb. 4.45 4.60 7.47 4.09 4.75 3.59 0.98 0.98 0.84 0.84 0.58 0.63
Industry Comb. 1.82 1.97 0.70 0.58 1.06 1.18 1.16 0.94 0.45 0.40 6.72 6.94
Waste Recycle 1.29 1.11 0.02 0.02 0.09 0.08 0.22 0.19 0.19 0.16 0.17 0.13
Misc. 21.84 23.78 0.15 0.20 0.28 0.40 18.29 18.06 4.06 4.29 4.91 5.81
Total 72.75 67.76 9.09 4.99 15.77 12.41 21.20 20.62 5.99 6.03 17.58 17.62

Source: Emissions are from EPA emission inventory summary at https://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/national_transportation_ statistics/index.html  Tables 4.45 to 4.50

 

Table 4: Percentage Point Improvement for each pollutant (2009-2015)

Pollutant CO Lead SO2 NO2 PM10 PM2.5 Ozone VOC Aggregate
% Point Reduction 3.5 4.2 16 3.1 0.6 9.7 0.9 N/A 5.4
% Emission Reduction 6.9 N/A 45.1 21.3 2.7 0 N/A 0 N/A

Note: SO2 and PM2.5 account for over two thirds of the aggregate improvement of air quality

 

Regulatory Impacts

A number of major regulations have been implemented since 2009. The motor vehicle industry saw a dramatic increase in the requirements for higher Corporate Average Fuel Economy, and tighter emission guidelines. Electric power plants have seen the most impact from regulation including the Mercury & Air Toxics Rule (MATS), the Cross State Air Pollution Rule (CSAPR), the Carbon Pollution Standard for New Power Plants which established New Source Performance Standards (NSPS), and the Clean Power Plan (CPP), all targeted at reducing the use of coal. Two reductions in the NAAQS for maximum Ozone levels tightened the standard by 12.5% and impacts all applications burning fossil fuels.

The EPA reports the primary health impacts of pollutants are related to fine particulate matter (PM2.5) and Ozone. Motor vehicles have a small impact on fine particles (6%), but are the greatest influence on Ozone precursors providing 58% of the Nitrogen Dioxide, 54% of the Carbon Monoxide, 23% of the Volatile Organic Compounds. Between 2009 and 2014 (latest data available) motor vehicle miles driven increased 2.3%, fuel use increased 3%, and average fuel economy actually decreased 1/2 % from 17.6 MPG to 17.5. The EPA reported tons of emissions from motor vehicles dropped between 2009 and 2014; CO by 16%, VOC by 20%, and NO2 by 26%.  Despite dramatic new regulations on motor vehicles, Ozone ambient levels came down less than 1% in seven years. Clearly, the tougher motor vehicle standards had very little impact on ambient levels of Ozone.

We suspect the lack of progress in improving Ozone levels is related to the fact we are most likely approaching natural background levels. It takes a very small amount of NO to fill its catalytic role, and the supply needed is readily available from sunlight interacting with just about any level of NO2. We compared Ozone levels over several years in very urban Wilmington, DE to very rural Lewes, DE. Ozone levels were essentially the same both on average and for peak times during the May through September Ozone Season. We found no correlation between daily NO2 levels and Ozone despite the fact NO2 averaged six times as high in Wilmington. Similarly, almost 95% of manmade VOC’s come from motor vehicle and industrial sources. We expect Wilmington to have very high levels of manmade VOC’s while Lewes would have almost none (VOC’s are not measured in Lewes). Yet the Ozone levels were essentially the same. At this point, naturally occurring Ozone is swamping human impacts.

Coal-fired power plants account for up to 82% of Sulphur Dioxide (SO2) emissions which are precursors to fine particles, and about 40% of direct fine particle (PM2.5) emissions. Only about 1/2% of Americans live in areas above air quality standards for SO2, and 7% live in areas above the fine particle standard. As noted above, reduced SO2 and PM2.5 account for about two thirds of the aggregate improvement in air quality from 2009 to 2015. EPA emission inventory shows direct PM2.5 emissions didn’t change during the period but SO2 emissions were cut in half.

The key question is how much of the improvement in power plant emission reduction was caused by EPA regulations. As shown in Chart 1 below, natural gas prices dropped significantly starting about 2009 driven by an increase in supply from the deployment of hydraulic fracturing and horizontal well drilling technology in shale formations. EPA regulations began taking effect in 2012. Lower prices played a major role in a switch from coal to natural gas for electric generation starting in 2009, and regulations impacted generation capacity starting in 2012.

Chart 1

chart-1

Source: US Energy Information Agency

Total electric generation has been relatively constant since 2003, but increased almost 3% from 2009 to 2016 as the economy recovered from the recession (Chart 2 below). That increase in demand was met with wind and solar power growth driven by state Renewable Portfolio Standards along with federal and state subsidies. Coal-fired generation was relatively constant until 2008, and began to fall in 2009. The fall paralleled declining natural gas prices. Natural gas generation has been increasing for decades at a relatively constant rate.

Chart 2

searching-root-causes-chart-2

Source: US Energy Information Agency

EPA regulations did impact coal-fired generation capacity as shown in Chart 3. Many older, smaller power plants were shut down rather than invest in expensive filtration equipment that would be needed to meet new standards. The downturn in coal capacity coincides with new regulation implementation beginning in 2012.

Chart3

searching-root-causes-chart-3

Source: US Energy Information Agency

However, more important to coal-fired generation was the change in how often power plants ran in comparison to natural gas-fired power plants over time (Capacity Factor) which is shown in Chart 4.  The decline tracks the falling natural gas price curve.

Chart 4

searching-root-causes-chart-4

Source: US Energy Information Agency

We can parse the relative impact on generation between regulatory induced capacity reductions and price driven capacity factor shifts from fuel switching. In 2008, before any impact of lower natural gas prices or new regulations, there was 1,986 million megawatt-hours of coal fired power produced by 337,300 megawatts of capacity at a 73% capacity factor. In 2016, 1,211 million megawatt-hours of power was produced from 295,986 megawatts of capacity at a 51 % capacity factor for a net loss of 775 megawatt-hour, or a 39% reduction. If the capacity factor had stayed the same, the lower 2016 capacity would have produced 1,743 million megawatt-hours of power for a 243 megawatt-hour, or 12% reduction. So, lower natural gas prices resulted in 69% (532/775) of the power reduction and 31% (243/775) was a result of new regulations. All generation data is from the US EIA Electric Power Monthly.

The final calculation is to adjust each of the aggregate reduction contributors for non- regulatory change impacts (Table 5). There were no new regulations for lead and PM10. Motor vehicles and power plants accounted for 54% of CO emissions, 87% of NO2 emissions, and we assume 50% for Ozone although it could be as low as 10%. Therefore, air quality only improved 1.9% from 2009 to 2015 because of regulations, or about 0.27%/year.

Table 5: Adjusted Aggregate Improvement in Air Quality 2009 to 2015

Pollutant % Point Reduction % from Reg. Change Net Point Reduction from Reg.
CO 3.5 54 1.9
Lead 4.2 0 0
SO2 16 31 5
NO2 3.1 87 2.7
PM10 0.6 5 0
PM2.5 9.7 31 3
Ozone 0.9 50 0.5
Total/7 Pollutants 1.9

 

Carbon Dioxide Emissions

According to the U.S. Energy Information Agency total carbon dioxide emissions fell 12% from 2005 to 2015 from 6,023 million metric tons to 5,300. Electric generation accounted for 68% of that reduction as the industry switched from coal to natural gas which has about half the carbon dioxide emissions per megawatt-hour as coal. Most of the balance of reductions came from the transportation sector.  As calculated above, lower natural gas prices drove 69% of the electric generation reductions, so in total, market forces drove about 47% of the total carbon dioxide reduction, or 226 million metric tons. Regulations cut emissions by 497 million metric tons.  That reduction will lower global temperatures by 0.007°C by 2100.

 

Going Forward

The air quality impact of new regulations promulgated by the Obama Administration have pretty much run their course. The MATS regulation failed to follow the Administrative Procedures Act by not completing a proper cost/benefit analysis and was overturned by the courts. The Impact of MATS was already completed by the time the courts ruled, and those impacts duplicated most of the potential impact of the Cross State regulation. It is likely the Clean Power Plan will be overturned by the courts, and will certainly be withdrawn by the Trump Administration.

Natural gas prices are unlikely to fall further. In fact, it is more likely they will increase. European natural gas prices are running 2.5 times higher than U. S. prices. There is a huge drive to export from the U. S. to Europe which requires expensive capital investment to liquefy the gas to allow shipment in an efficient manner. A number of LNG plants are under construction, and prices should rise as exports begin. Higher natural gas prices should lead to a slight electric generation shift back to coal raising coal generation capacity factors. Some planned closings of coal-fired power plants will likely continue, but the closing trend would end under either administration.

The gasoline mileage targets set by the Obama Administration are unrealistically high, and are unlikely to have been met. The Trump Administration will certainly review the targets and cut them back to more realistic levels. Plus, it takes fifteen years to turn-over the vehicle fleet so progress on reducing pollution will be slow. As discussed above, it appears no regulatory or market action will likely improve Ozone ambient levels as we are so close to natural background levels. Ozone levels were reduced by less than 1% from 2009 to 2015, but higher temperatures in the US in 2016 will likely wipe out even that small gain.

 

Conclusion

There are two pollutants listed for action in the Clean Air Act that still have potential negative health impacts; fine particles (PM2.5) and Ozone.  Dramatically tightened rules from the Obama Administration on power plants, motor vehicles, and the Ozone National Ambient Air Quality Standard had essentially no impact on emission levels of those two pollutants. Fine particle levels were reduced by 3%in seven years, but 93% of the U. S. population already lives in areas in compliance with national standards. There was less than 1% reduction in Ozone levels between 2009 and 2015, and it is likely 2016 Ozone levels will show zero improvement from 2009 as hot summers lead to higher ozone levels. It is unlikely the regulations will have any additional significant impact going forward. The regulations reduced Carbon dioxide emissions roughly 0.5 billion metric tons, but the impact of that on global temperatures in 2100 will be less than 0.01°C

David T. Stevenson, Director

Center for Energy Competitiveness

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

8/16/2016

Gina McCarthy

Administrator

United States Environmental Protection Agency

Ariel Rios Building

1200 Pennsylvania Avenue, N.W.

Mail Code: 1101A

Washington, DC 20460

 

RE: Public Comments on EPA-HQ-OAR-2016-0347, Section 126 Petition from Delaware and Connecticut on Brunner Island Power Plant

 

We urge the EPA to deny the petition of these states that would require the Brunner Island power plant to add Selective Catalytic Reduction (SCR) technology, to switch to 100% natural gas fuel to reduce nitrous oxide emissions, or to move to a 24 hour maximum average emissions regimen for the following reasons:

  • The Brunner Island power plant meets the EPA mandated Pennsylvania State Implementation Plan which limits the nitrous oxide emissions rate to 0.35lbs per million British Thermal Units averaged over 30 days. Meanwhile, Delaware has met the EPA National Ambient Air Quality Standard (NAAQS) of 8 hour maximum limit of 75 parts per billion (PPB) for the fourth highest day, averaged for ozone over the last three years, and even met the new 70 PPB limit in 2015.  No action is required under current regulations.
  • A $100 million construction project to convert the Brunner Island power plant to co-firing potential with coal or natural gas will be complete in the spring of 2017, and will significantly lower nitrous oxide emissions in the ozone season (May 1 to September 30) reducing any impact on Delaware.
  • Power plants account for only 7% of nitrogen dioxide (NO2) levels in Delaware, and totally eliminating this source would not significantly change ozone levels.
  • A key assumption of the petitioner’s claims is higher NO2 levels yield higher ozone levels. An analysis of ambient levels of nitrogen dioxide (NO2) and ozone (O3) in New Castle County, Delaware, from 2013 to 2015, show no correlation between higher levels of NO2 and higher levels of ozone.

 

Brunner Island to Switch to Natural Gas from Coal during the Ozone Season in 2017

A $100 million construction project to convert the Brunner Island power plant to co-firing potential with coal or natural gas will be complete in the spring of 2017, and will significantly lower nitrous oxide emissions which are a precursor for ground level ozone.  Natural gas inherently emits 80% less nitrous oxide during combustion compared to coal.  Natural gas is used as the primary space heating fuel in 56% of homes in the United States according to the US Energy Information Agency so, prices peak in the winter when demand is high (Graph 1). This is why average generation with natural gas fired power plants peaks every summer when prices are lower (Graph 2).  There is a very high probability natural gas will be the fuel used at Brunner Island during the Ozone Season (May 1 to September 30), and would have been used all year in 2015 except for the winter.  The co-firing project meets the same ozone season nitrous oxide emission goals as a $600 million1 SCR project would while offering a lower cost impact for electric customers.  The project also cuts carbon dioxide emissions in half and lowers sulfur dioxide emissions during the period natural gas is used.  Co-firing also offers fuel diversity critical to maintaining electric grid reliability.  Over dependence on natural gas could lead to blackouts during severe winters in the future when natural gas is in tight supply and pipelines might freeze as happened during the 2014 polar vortex.

 

Graph 1: Pennsylvania Power Plant Fuel Cost 2015 by Month – $/MMBTU

BI graph one

Source: US Energy Information Agency Electric Power Monthly Tables 4.10A and 4.13A

Note: Coal prices are adjusted for lower heat rates but higher operating costs for FGD use  

 

Graph 2: Seasonal Electric Generating Unit Coal vs. Natural Gas Generation

BI graph two

Source: U.S. Energy Information Administration, Electric Power Monthly, Short-Term Energy Outlook

                                   

Upwind Power Plants Account for a Small Percent of Delaware’s Ambient NO2 Levels

The Delaware petitioner claims that upwind emission sources account for 94% of Delaware’s ozone levels.  By omission, the petitioner leaves the impression the transport of ozone from upwind sources is the problem.  Ground level (tropospheric) ozone is actually produced locally in two general chemical reactions2:

  • The energy of sunlight splits a nitrogen dioxide molecule (NO2) into a nitric oxide molecule (NO) and a free oxygen atom (O). The free oxygen atom combines with an oxygen dioxide molecule (O2) to form ozone (O3).  The reaction reverses fairly quickly as nitric oxide and ozone are very reactive.  Coal fired power plants emit a combination of nitrogen dioxide and nitric oxide (which quickly reacts to become nitrogen dioxide) and can be transported by the wind.  NO2 also occurs naturally, and from a variety of manmade sources, primarily motor vehicles.
  • A sunlight split nitrogen dioxide molecule can also react in a complex way with a wide range of Volatile Organic Compounds (VOC) to form ozone which tends to be longer lasting. VOCs can be generated by natural sources, such as vegetation, and by manmade manufacturing and combustion.  Natural sources can be overwhelming in places like the Great Smokey Mountain National Park which derives its name from naturally occurring ozone in the form of smog.  The VOC source is pinetene from pine trees and ozone levels exceed national air quality standards!

 

In both cases nitrogen dioxide is considered a catalyst, the reaction can’t occur without it but the amount of nitrogen dioxide is ultimately unchanged over a 24 hour period.  Ozone is highly reactive with any physical surface and can cause injury to plants and animals, especially sensitive people with asthma or COPD.  The local nature of ozone is confirmed by Graph 3 below which shows how ozone forms in the day and falls to essentially zero overnight.  Ozone is also formed in the stratosphere and can be mixed by downdrafts with ground level ozone but that generally occurs in mountainous areas such as the Rockies.

 

Graph 3: Diurnal Ozone Production

BI graph three

Source: NASA Earth Observatory

 

There are a number of variables in ozone creation including the amount of sunlight, temperature, wind, humidity, the amount of VOCs, and even ocean breezes as ozone has a longer shelf life over water.  The highest ozone days are on hot summer days grouped around the summer solstice, with low wind and moderate humidity, in urban areas with high VOCs.

The petitioner also leaves the false impression power plants are the main source of ozone precursors.  Power plants account for only 7% of NO2 levels in Delaware.  Electric Generating Units (EGU) emissions are overwhelmed by vehicle and other emission sources as shown in Graph 4 below.  The claim the Brunner Island power plant has a significant impact on ground level ozone levels in Delaware is simply wrong.

 

Graph 4: NOX Contribution Sources in Delaware

BI graph four

Source: Delmarva Power 2012 IRP “Air Quality & Health Impacts Assessment”, ICF International using 2010 to 2013 average data

 

There is No Correlation between Higher Levels of Nitrogen Dioxide and Higher Levels of Ozone

The Petitioner relies on modeling from Sonoma Technology Inc. (STI).  They used a computer model based on work done by the United States Environmental Protection Agency to determine downwind dispersion of various emissions, including nitrous oxide, and the chemical reactions related to the emissions.  The model used is the Comprehensive Air Quality Model with Extensions (CAMx) with Ozone Source Apportionment Technology (OSAT). According to the Sonoma report, page 12, “OSAT uses reactive tracers to track the fate of these precursor emissions and the ozone formation resulting from them within a CAMx simulation”.  Unfortunately, STI did no real world, on the ground verification of the validity of the tracers.

Ambient levels of NO2 are currently averaging 19 PPB daily one-hour maximum during the ozone season with a range of 5 to 50 PPB over the years 2013 to 2015 (measured at the Martin Luther King Blvd. air quality monitoring station in Wilmington, Delaware).  The Wilmington site is the only air monitoring station in Delaware regularly measuring NO2.  Monitoring equipment doesn’t always work so we only had data for 346 days out of a possible 459.  The 19 PPB is 80% below the NAAQS 98th percentile, three year average maximum allowed of 100 PPB.  When we ran a statistical correlation between NO2 levels and ozone levels we found the correlation was 0.08, so essentially there was no correlation between the two!  Zero equals no correlation and 1 equals perfect correlation.  The computer may have done an excellent job tracking NO2 concentrations, but the Brunner Island simulation only added 1.9 PPB average to ozone levels with a range of 0.7 to 4.9 PPB according to STI.  However, real world data does not confirm the computer tracer module results.  There was no impact from Brunner Island on Delaware ozone levels.

For further verification we looked at 2013 data from the Lewes, Delaware, air monitoring station which measured NO2 that year.  Lewes is a rural station while Wilmington is more urban.  The Lewes station showed an ozone season average ambient level of NO2 of only 3 PPB, one-sixth as much as Wilmington, with a range of 0.3 to 10 PPB.  The statistical correlation was only 0.01, or once again essentially zero.

 

Conclusion

The facts do not support the Petitioner’s request to require shorter periods for nitrous oxide emission averaging, such as a 24 hour cap, or to add SCR pollution control equipment at Brunner Island.  We note the link to the report is on a Sierra Club website alongside its “Beyond Coal” campaign that counts down how many coal-fired power plants have been closed on the way to zero.  We suspect the Delaware and Connecticut Air Quality Divisions have responded to an advocacy group call for action to end the use of coal at Brunner Island.   It would not make economic sense to spend $600 million on Brunner Island for SCR on top of the $100 million on-going project to convert to the ability to co-fire with natural gas.  If the EPA grants the petitioner’s request the Brunner Island facility will simply convert 100% to natural gas and the Sierra Club can scratch off another coal plant.  However, electric customers will be worse off with higher winter time electric rates, and the lost reliability of having fuel diversity.  The environmental outcome for ozone comes out the same either way.

 

Notes:

1 – Press release from Four Corners Power Plant, Fairmount, NM showing 1636 MW capacity SCR project now under way will cost $635 million.  Brunner Island is about 5% smaller at 1549 MW.

2 – “Chemistry in the Sunlight”, NASA Earth Observatory, http://earthobservatory.nasa.gov/Features/ChemistrySunlight/

 

 

David T. Stevenson

Director, Center for Energy Competitiveness

e-mail: DavidStevenson@CaesarRodney.org

Phone: 302-236-2050

Fax: 302-827-4558

Delaware and Maryland utility commissions have one more shot to convince electric grid regulators to lower the cost of the Artificial Island Transmission Line.  Governors Markell and Hogan have joined forces to fight the burdensome cost of this project, but a new approach is needed.  If we want to win this fight we need to negotiate using an alternative approach.  More local power generation could replace the transmission line.  This could lead to lower electric rates instead of higher rates, to a more robust economy, and to improved electric reliability.

 

The Artificial Island project is a technical response to importation of power.  Maryland and Delaware are the second and fifth highest electricity importing states in the country.  In 2015 Maryland imported 41% of its power, and Delaware imported 32%.

 

Importing power lowers electric grid reliability.  It also adds cost.  Regional grid manager, PJM Interconnection, is responsible for maintaining reliability with a combination of pricing mechanisms, and transmission line policy.  There are line charges to compensate for longer power transmission distances, congestion charges to encourage lower peak demand, and capacity charges to encourage more local generation.  See the graph below to see how these premiums can go.  These premium charges roughly equal the added monthly costs of the proposed transmission line, are already added to our electric bills, and most of the cost will continue even if the new transmission line is built!

 

Cost Premiums in Delaware & Maryland for Grid Congestion and Transmission Cost

dave stevenson Artificial Island

Source: PJM Interconnection Real Time Statistics

So, how do we boost local generation?  Start by asking electric generation and distribution companies already invested in the state what state policies would encourage more generation.  State policies led to lower local generation in very real ways and changed policies can help reverse the trend.  Prepare to kill some sacred cows when we hear the answers.

 

Maryland and Delaware are the only two states in the thirteen state PJM region with a tax on carbon dioxide emissions from power plants.  The cost of that tax is passed on as a hidden tax on electric bills.  Our generating facilities burning coal and natural gas have to charge more, and lose bids to supply power.  Consequently, local power plants operate less frequently.  For example, the Indian River power plant in Millsboro, Delaware, is only operating 20% of the time compared to an average of 55% for coal fired plants nationally.

 

The tax was designed to reduce emissions but all it has really done is shifted the emissions out of state, and discouraged power plant construction locally.  The revenue was supposed to be used for energy efficiency and renewable energy projects, but after a decade of work only a quarter of annual tax revenue is being spent on such projects.  Ending the tax would lower electricity prices and would allow more power to be generated locally.

 

In Delaware we only need to build the equivalent of three to four new power plants to become self-sufficient.  Calpine recently completed a new natural gas fired power unit in Dover and has the permits needed for a second unit.  What incentive does Calpine need to build the second unit?

 

Exelon recently acquired Delmarva Power, the state’s largest electric distribution company, and is one of the largest generation companies in the nation.  A decade ago distribution companies owned all the generation facilities as well with a guaranteed rate of return regulated by the Public Service Commission.  Delaware and Maryland joined a handful of other states in deregulating the price of generated power thinking this would increase competition and lower electric cost.  The actual result was the sale of generating facilities and a 70% increase in electric rates in the deregulated states.  Partial reregulation might encourage distribution companies to build at least some new generation capacity.

 

Exelon is one of the largest builders of large scale solar farms in the country.  A little known fact is utility scale solar is now essentially competitive with conventional power plants during high demand daylight hours.  Delaware policy has emphasized building smaller scale systems that actually add cost to our electric bills.  Yes, in this case bigger is better and a policy change is needed.

 

Land acquisition is a barrier to building more solar.  The state could offer marginal state owned open space land for long term lease for solar farms to lower start-up costs.  The revenue could be used for state park operations.

 

No doubt a dialogue to boost local power generation would uncover more opportunities.  The result would not only avoid the added cost of the Artificial Island project but might lower existing electric rates by as much as 15% removing a barrier to job creation, and could lead to up to a billion dollars in new construction projects.   

David T. Stevenson, Director

Center for Energy Competitiveness

                               

 

State support for higher education is slipping with one large exception at the University of Delaware. One department, actually one individual, at the university is slated for a 38% increase according to the latest draft of the state budget.  This is in contrast to the state contribution for university operating expenses falling from about 21% in 2000 to about 12%, according to the University’s 2015 Investment Office Annual Report.

The currently proposed 2017 Fiscal Year proposed budget consists of fifty-nine pages of tables of budget numbers by department, and two hundred and twenty-six pages of “epilogue” language.  The epilogue pages are similar to footnotes and most of it is innocuous and a pretty boring read.  It can also be a place where bad policy goes to hide.

This may be the case with Section 285, page 199, which reads:

Section 285. Section 1 of this Act makes an appropriation to Higher Education, University of Delaware  (90-01-01) for the College of Arts and Sciences. Of this amount, $290,000 shall be allocated to the Center for Energy and Environmental Policy for research supervised by Dr. John Byrne as principal investigator

Yes, while other departments struggle as costs rise faster than state contributions, Dr. Byrne is expecting $290,000 to use as he sees fit, not even with direction for what he is researching.  The transfer effectively raises the earth sciences budget 38%.  Dr. Byrne and the University of Delaware have not responded to requests for comment.  A similar transfer was authorized in the last three year’s budgets but was designated more generally to the Center for Energy and Environmental Policy run by Dr. Byrne.

Unlike specific legislative bills there is no acknowledged sponsor of epilogue language.  However, Dr. Byrne and State Senator Harris McDowell (D – Wilmington North) have worked together for over a decade.  Senator McDowell is Co-Chairman of the Joint Finance Committee that writes the budget, and of the Senate Energy Committee.  Dr. Byrne and Senator McDowell jointly chaired the Sustainable Energy Utility (SEU) and its Oversight Committee over the last decade.  Dr. Byrne would be expected to consult with Senator McDowell in his role with the Center for Energy and Environmental Policy.  The obvious question is Dr. Byrne getting special treatment in the state budget because of his relationship with Senator McDowell.  Senator McDowell has not responded to requests for comment.

Senator Greg Lavelle (R – Sharpley) commented, “Based on the fact Dr. Byrne’s name is specifically mentioned in the epilogue language is a unique event, and we will be asking questions”.  He went on to say. “It would make one think that authority for use of the funds rests with Dr. Byrne and not the Center for Energy & Environmental Policy”, or the University.

David T. Stevenson, Policy Director

Center for Economic Policy

 

Brexit Insight

Texas has sued the federal government forty-four times since President Obama began his campaign of executive overreach, and has often won in the courts.  The presidential election will offer an opportunity to reverse many of this administrations attempts at over regulation.  Britain, and other members of the European Union have no legal recourse or a direct election to fight back on similar over regulation and overreach by technocrats in the EU.  That was the primary reason Britain voted to leave the EU.

By happenstance I was in the United Kingdom for the run up to the election, and was following the campaign for personal investment reasons.  The chance to talk to people in London and Scotland left little doubt “Leave” would win.  Britain, like America, has a long history of valuing independence and individual freedom.  After all this is where the Magna Carta was signed, and where the only successful attack on the Tower of London fortress was carried out by the common people when military attacks all failed.

The same strains exist in the US and will play a major role in the coming election, including a desire for more control of our borders.  People here are just as tired of senseless rules coming out of Washington as the British were with senseless rules coming out of Brussels.  Look for the same vicious attacks on those who want better immigration controls here as argued by the “Remain” campaign.  You can also expect the same polling bias.  Late polls showed “Remain” leading 52% to 48%, but “Leave” won with 52%.  Betting pools and the trading futures market also badly missed the results.  I suspect some “Leave” supporters lied to pollsters in fear of expressing their real feelings on the matter.

Expect volatility in the stock markets for a time as this vote really was a hinge point in history and it will take a while for things to settle down.  In the long run the world economy will be stronger and we will see specific benefits in the US and the UK.  The UK has one of the fastest growing economies in Europe and is the second largest European economy.  Older voters who supported the referendum remembered the time before the EU and how their country was successful and sovereign.  It will be so again.

There is a lot of press on this issue. For the best analysis I’ve seen follow this Wall Street Journal link:  http://www.wsj.com/articles/brexit-a-very-british-revolution-1466800383

David T. Stevenson, Policy Director

Center for Economic Policy