Would-be practitioners of "climate engineering," once called "geoengineering," are stumbling across a minefield of problems. Early investigations assumed the key issue would be finding ways to block sunlight from reaching the lower atmosphere. [1] [2] Reducing solar inputs could retard and possibly reverse warming trends. However, more recent investigations, using weather modeling and weather records after large volcanic eruptions, show that blocking sunlight reduces rainfall. [3] Land areas already at low rainfall could become deserts.
Discovery of major hazards from blocking sunlight sparked renewed interest in recapturing carbon dioxide already released by human activity, a difficult prospect that would face three key challenges:
(1) a very large amount of carbon dioxide to be recaptured
(2) low concentration of carbon dioxide in the atmosphere
(3) lack of storage capacity for gaseous carbon dioxide
The total carbon dioxide released to the atmosphere from human activities has been about 800 billion tons since the early 1800s. [4] [5] [6] A large majority came from burning coal. Since 2000, the total has been increasing an average of 2.0 percent per year. [4] Those observations set practical requirements for any proposals to recapture carbon dioxide. A realistic approach must extract and permanently store several hundred billion tons.
Carbon dioxide penetrates some solid materials, including many rubbers and plastics, more than other gases do, making possible separation by a solid, semi-permeable membrane. Other potential membrane separations depend on molecular size differences and porous membranes. [7] Commercial membrane systems for removing carbon dioxide from pressurized gas streams are available. As applied to recapture from the atmosphere, key limitations are the need to compress very large air volumes, the need for a cascade of separation stages because of the low carbon dioxide concentration, and the low permeabilities and flow kinetics of known membranes. Recapture systems using membranes would be enormous, energy-intensive and costly; practical systems have not yet been demonstrated.
Absorption of carbon dioxide by strong alkali is a well known separation technique, widely applied in equipment that maintains sealed environments. It has been demonstrated for recovery of carbon dioxide at atmospheric concentrations, and a closed-cycle process is known. [8] The last process stage is calcining lime at very high temperatures, as used to make cement. It yields concentrated carbon dioxide but takes large amounts of energy, about 2 MWh per ton of carbon dioxide. [9] To recapture the atmospheric inventory of carbon dioxide released by human activities would require a total of about 2 billion GWh. Supplying that energy from fossil fuels would work at cross-purposes. Supplying it from nuclear power would take 5,000 large, 1 GWe reactors about 50 years. Costs would approach US$100 trillion for energy, [10] plus costs of chemical processing steps.
Those and other methods of recapturing carbon dioxide would be useless alone, because there would be no place to put all the carbon dioxide. Even when compressed to a liquid, carbon dioxide occupies about six times the volume of the same amount of carbon as coal. In all the world's mines and wells combined, there is no space for more than a small fraction of the carbon dioxide that human activity has released. Most mines and wells have rock fissures that allow carbon dioxide to seep back to the atmosphere. Permanent storage requires combining carbon dioxide into a stable, solid mineral. While not difficult, most mineralization processes start with a substrate that was made from a carbonate, by driving off carbon dioxide. Obviously that will not do.
Rock formations containing substantial fractions of calcium and magnesium oxides readily combine with carbon dioxide, making carbonates. The formations useful as substrates are geologically young, because when weathered alkaline earth oxides have been consumed. Suitable formations are uncommon and variable in reactivity. [11] Rock formations containing substantial calcium silicate as wollastonite or magnesium silicate as forsterite are also potential substrates. [12] [13] Suitable formations are more common than those containing alkaline earth oxides but are also variable in reactivity. Reaction rates are slower than those of alkaline earth oxides, taking many hours to reach only modest yields.
Silicate carbonation is enhanced when rock substrates are pretreated at very high temperatures and ground to very fine dust. About three-fourths of silicate will then carbonate with a half-hour exposure. The process is energy-intensive; costs have been estimated at about US$70 per ton of carbon dioxide. [14] An unanswered question is emission of carbon dioxide from high-temperature pretreatment. Using the process to store the inventory of carbon dioxide released by human activities, costs would approach US$50 trillion.
Known technologies can recapture carbon dioxide from the air and store it permanently. However, potential costs of applying them to recapture all carbon dioxide released by human activities probably approach US$200 trillion. With total emissions of carbon dioxide increasing at two percent per year, incremental costs to recapture from the atmosphere the current carbon dioxide emissions probably approach US$4 trillion per year. Such an amount could be viewed as remediation of potential environmental damage. It could be raised by taxing carbon dioxide emissions at about US$900 per ton of carbon. That is far more than US$1 to US$50 tax rates factoring in recent political controversies.
Taxing carbon dioxide emissions enough to pay for their recapture from the air and their permanent storage, using those known technologies, would probably raise U.S. retail gasoline prices from about US$3 to about US$6 per gallon. It would probably raise wholesale U.S. prices for coal-fired electricity from about US$.05 to about US$.60 per KWh. Ending further carbon dioxide additions and recapturing all the releases from human activity, carried out over 50 years, would probably cost about 12 percent of the gross world product, estimated from the current level. Less expensive technologies may eventually be developed. For example, carbon dioxide capture from power-plant flue gases is being tested and will probably be less costly. Catalysts that reduce energy consumption have been conjectured, but so far no economically effective catalyst has been found. Substantial improvements are not likely to be found quickly in such longstanding, well known areas of technology.
[1] James E. Hansen and Andrew A. Lacis, Sun and dust versus greenhouse gases, Nature 346:713-719, August 23, 1990.
[2] Edward M. Teller, Lowell Wood and Roderick Hyde, Prospects for physics-based modulation of global change, UCR Livermore National Laboratory Report UCRL-JC-128715, August 15, 1997, available at www.osti.gov/accomplishments/documents/fullText/ACC0229.pdf.
[3] Gabriele C. Hegerl and Susan Solomon, Risks of climate engineering, Science 325:955-956, August 21, 2009.
[4] Pieter Tans, Mauna Loa carbon dioxide records, U.S. National Oceanic and Atmospheric Administration, Earth Systems Research Laboratory, 2010, available through www.esrl.noaa.gov/gmd/ccgg/trends/.
[5] D.M. Etheridge, L.P. Steele, R.L. Langenfelds, R.J. Francey, J-M. Barnola and V.I. Morgan, Historical CO2 record derived from ice cores, Australia Commonwealth Scientific and Industrial Research Organization, Division of Atmospheric Research, 1998, available at http://cdiac.ornl.gov/ftp/trends/co2/lawdome.smoothed.yr20.
[6] Kevin E. Trenberth and Lesley Smith, The mass of the atmosphere, Journal of Climate 18(6):864-875, 2005.
[7] Colin A. Scholes, Sandra E. Kentish and Geoff W. Stevens, Carbon dioxide separation through polymeric membrane systems for flue gas applications, Recent Patents on Chemical Engineering 1:52-66, 2008, available at www.bentham.org/cheng/samples/cheng%201-1/Sandra%20E.%20Kentish.pdf.
[8] Gregory V. Lowry, Joshuah Stolaroff and David Keith, CO2 extraction from ambient air using alkali-metal hydroxide solutions, American Chemical Society, Division of Fuel Chemistry Proceedings 49(1):362-363, 2004, available at www.anl.gov/PCS/acsfuel/preprint%20archive/Files/49_1_Anaheim_03-04_0861.pdf.
[9] Wicky Moffat and M.R.W. Walmsley, Understanding lime calcination kinetics for energy cost reduction, Australian Pulp and Paper Industry Technical Association Proceedings 59:487-494, 2005, available at www.tappsa.co.za/archive2/Journal_papers/Understanding_lime_calcination/understanding_lime_calcination.html.
[10] Craig A. Severance, Business risks and costs of new nuclear power, Electricity Journal 22(4):112-120, 2009, draft version available at http://climateprogress.org/wp-content/uploads/2009/01/nuclear-costs-2009.pdf.
[11] N. Koukouzas, V. Gemeni and H.J. Ziock, Sequestration of CO2 in magnesium silicates, International Journal of Mineral Processing 93:179-186, 2009, available at www.lanl.gov/source/orgs/ees/ees14/pdfs/09/Koukouzas09.pdf.
[12] Sebastian Teir, Sanni Eloneva and Ron Zevenhoven, Production of precipitated calcium carbonate from calcium silicates and carbon dioxide, Energy Conversion and Management 46(18):2954-2979, 2005.
[13] George D. Guthrie, Jr., J. William Carey, Deborah Bergfeld, Darrin Byler, Steve Chipera, Hans-Joachim Ziock and Klaus Lackner, Geochemical aspects of the carbonation of magnesium silicates, Los Alamos National Laboratory, National Conference on Carbon Sequestration, Washington D.C., May 14-17, 2001, available at www.netl.doe.gov/publications/proceedings/01/carbon_seq/6c4.pdf.
[14] W.K. O'Connor, D C. Dahlin, G. E. Rush, C. L. Dahlin and W. K. Collins, Carbon dioxide sequestration by direct mineral carbonation, Minerals and Metallurgical Processing 19(2):95-101, 2002.
Wednesday, October 6, 2010
Monday, May 31, 2010
Disaster by design, the Deepwater Horizon blowout
The April 20, 2010, blowout of an oil and gas well in the Gulf of Mexico, south of the Louisiana coast, created the worst environmental crisis for the United States since the massive dust storms of Great Depression years. Both occurred because of mismanaged natural resources, but otherwise they greatly differed. The Dust Bowl was a result of hundreds of thousands of farmers tilling marginal land without crop rotation, leaving soils vulnerable to severe drought. [1] The well blowout came from a highly concentrated activity, involving a few hundred people attempting to access a high-pressure reservoir, drilling from the high-technology Deepwater Horizon platform in about one mile water depth without adequate margins of safety. [2]
Both disasters might have been prevented by adequate government regulation. In the 1920s, when it would have mattered most, there was hardly any government presence in agriculture other than the field stations set up by states and the federal government to assist with, but not to regulate, crop management. The federal government and many states were in the grip of deeply conservative, even reactionary administrations, firmly opposed to government regulations. Their closest approach had been the federal Pure Food and Drug Act of 1906, passed during the Theodore Roosevelt administration and largely aimed at unsanitary meat packing. [3]
The 2010 Gulf of Mexico well blowout came 41 years after a similar disaster, the 1969 well blowout in Santa Barbara Channel, a few miles off the California coast. Shocked by gross pollution of the Pacific coastline, Congress swiftly passed the National Environmental Policy Act of 1969. [4] It formed a basis of regulation that had become institutionalized in missions of government agencies by the time of the 2010 disaster. Yet like the Pure Food and Drug Act, the National Environmental Policy Act proved susceptible to manipulation and evasion. Regulations created and enforced under it failed to prevent a catastrophe, even though when one occurred the federal government was a progressive administration committed to environmental protection.
The major cause of the 2010 Gulf of Mexico well blowout was quickly assessed, only several days after public release of a well schematic. [5] Dr. Arthur Berman, a Houston petroleum geologist, showed that unsafe design for the Macondo 1 well had left unrestrained areas of bare drillhole, above a high-pressure oil and gas reservoir, connected to the sea floor through an annulus between metal casings. [6] His analysis of the final cementing operation was soon confirmed through a public release of data from the well owner. [7] What had yet to be released at that point were documents showing the faulty design as submitted to and approved by the Minerals Management Service (MMS), an agency of the U.S. Department of the Interior set up to supervise offshore oil and gas operations.
As of 2010, MMS had managed federal leases of outer continental shelf lands and supervised their operations for 28 years, under authority of the Federal Oil & Gas Royalty Management Act of 1982. Many responsibilities were created by the National Environmental Policy Act, which requires environmental impact statements for such activities. During several years before the 2010 blowout, MMS had been repeatedly troubled by mismanagement and corruption. In 1998 and subsequent years major blunders occurred. Faulty contracts allowed leaseholders to avoid many billions of dollars in oil and gas royalties, disclosed by the New York Times February 15, 2006. Although the problems were discovered within MMS in 2004, MMS took no action to correct them until the public disclosure, according to the inspector general for the Interior Department. [8]
MMS had long paid cash bonuses to employees for expediting work related to oil and gas development, a key element in creating a corrupt job environment. [9] In 2008 MMS was found by its inspector general to host what he called a "culture of ethical failure." Abuses cited included patronage, inside dealing, kickbacks, revolving door employment and misuse of federal property--extending over a period of at least four years. As a result of the investigation several employees were reassigned, some quit, and at least one was convicted of a felony. [10]
In 2010 the Macondo 1 well blowout in the Gulf of Mexico led reporters to discover that its lease and many other projects in the Gulf of Mexico had been exempted by MMS from environmental reviews. As a result, companies had not been required to prepare and document emergency responses. The Deepwater Horizon platform lacked a fail-safe blowout preventer, and the Macondo 1 well owner lacked salvage equipment. In budget documents MMS had claimed efficiency from using "categorical exclusion" for a "streamlined" form of environmental review. [11] What the agency did was generate a prepackaged deal for companies. A pro-forma environmental review was prepared by and approved within the agency. After companies paid for leases, they were automatically exempted from reviews, and their applications to conduct operations were, quite literally, rubber-stamped.
The Macondo 1 well was mainly regulated under a "multisale EIS" (Environmental Impact Statement) covering 11 Gulf of Mexico leases, prepared by MMS staff in 2007. Its risk analysis finds that over 40 years, "there is a 69-86 percent chance of one or more spills [of] 1,000 barrels [or more] occurring" [page 4-231]. The "multisale EIS" finds substantial risk that a spill of 1,000 or more barrels will pollute many miles of coastline [page 4-234]. It also indicates that pollution can persist for many years [page 4-238]. Thus MMS knew that a disaster in this area was likely and that consequences would probably be widespread and long-lasting. [12]
The exploration plan filed with MMS to drill the Macondo 1 well described a worst-case oil discharge as 300,000 barrels per day, giving a number without saying "barrels." However, MMS instructions for such plans show daily volume in barrels. In less than 12 days such a discharge would exceed the world's worst ocean oil disaster, the 1979 Ixtoc 1 well blowout, also in the Gulf of Mexico. MMS knew the Macondo 1 well had the potential to cause a catastrophe, yet it gave the plan routine approval, letting the owner go ahead without documented procedures for responding to such a radical emergency. [13]
Immediately after the Macondo 1 well blowout the U.S. Coast Guard failed to mount coordinated rescue, control and salvage operations. Years of focusing on terrorism rather than natural and industrial disasters had left it unprepared for such an event. MMS permitted relief wells without requiring any more safety preparation than it had required for the well that blew out. The U.S. National Oceanic and Atmospheric Administration distributed a hasty assessment of the crude oil discharge rate that was soon shown to be scientifically faulty, and then it refused to release data and methods. The U.S. Environmental Protection Agency issued a hasty decision endorsing untested use of large quantities of dispersants, when environmental evidence showed that similar chemicals had led to long term environmental damage. [14]
Despite contributions to the problems, the Coast Guard and MMS were put in charge of an initial investigation. [15] Outrage over crude oil reaching beaches and marshland and protests over a compromised investigation led to a rapid series of actions: reorganization plans for the MMS, resignation of the MMS director, suspension of all offshore drilling in deep water, new drilling permits and offshore oil and gas leasing, and appointment of a Presidential investigating commission. [16] The U.S. Geological Survey prepared an estimate of the discharge, putting it at 12 to 19 thousand barrels (500 to 800 thousand gallons) of crude oil per day. [17]
Through May, 2010, the Macondo 1 well owner tried a series of maneuvers to trap or plug the oil discharge, without much success. Similar maneuvers had been tried with previous subsea well blowouts, notably the 1979 135F platform, Ixtoc 1 well blowout in the Bay of Campeche off Mexico. Despite the same kinds of attempts, that blowout flowed for 290 days, discharging an estimated 120-200 million gallons of crude oil into the southern Gulf of Mexico, the world's greatest accidental ocean oil disaster so far. [18]
Sometimes such maneuvers succeeded, as with the 1977 Bravo platform, well B14 blowout in the North Sea off Norway. But when reservoir pressure was high and consequent gas flow was strong they failed, as they recently did with the Montara platform, well H1 blowout in the Timor Sea off northwest Australia, which flowed for 70 days. [19] Company and U.S. officials lied, saying the Macondo 1 well blowout was "unprecedented," and success of the maneuvers would be unpredictable. All that was really unprecedented was water depth. There was otherwise substantial experience with similar blowouts, but there was an unprepared industry and a similarly unprepared government. [20]
The blowout preventer (BOP) configured for the Deepwater Horizon platform failed; otherwise the blowout would have been prevented. That failure was also by design, as the U.S. Minerals Management Service has been made fully aware. [21] Current-generation blowout preventers depend on shearing blind rams (SBRs) to cut drill pipe, so as to allow floating platforms like Deepwater Horizon to seal a well, disconnect from it and move away. Current-generation SBRs cannot cut through pipe joints, the enlarged, hardened sections of steel that join segments of drill pipe. About ten percent of the lineal extent of drill pipe is joint. However, BOP rams do not close with a snap. Their hydraulic systems are regulated, and they take most of a minute to close. During that time the force of a blowout is pushing drill pipe upward. As an SBR nears the point of full closure, inevitably an upward-moving pipe joint lodges in it. After trapping the pipe joint, the SBR then cannot cut it.
U.S. government says it will revise offshore oil and gas regulations and agency organizations. However, few if any people working in U.S. government actually know what to do. In the aftermath of the 1969 Santa Barbara disaster laws were written, but then they were often ignored. If the aftermath of the 1979 Bay of Campeche catastrophe, industry developed a slightly improved blowout preventer (in use at the Macondo 1 well), and U.S. government prepared a few internal studies. [22] As a result, MMS knew that existing offshore oil and gas well development was unsafe and knew that neither government nor industry was prepared for a major emergency, but it failed to generate plans, conduct relevant research, arrange for improved equipment and supplies, perform engineering evaluations or coordinate such efforts with companies or other agencies. Decades of opportunity were squandered, leading to another catastrophe.
[1] R. Douglas Hurt, The Dust Bowl: An Agricultural and Social History, Burnham, 1981.
[2] Tom Fowler, Experts have their doubts on well's design, Houston Chronicle, May 26, 2010, available at www.chron.com/disp/story.mpl/business/deepwaterhorizon/7022355.html. Ian Urbina, Documents show early worries about safety of rig, New York Times, May 30, 2010, available at www.nytimes.com/2010/05/30/us/30rig.html.
[3] James Harvey Young, Pure Food: Securing the Federal Food and Drugs Act of 1906, Princeton University Press, 1989.
[4] Matthew J. Lindstrom and Zachary A. Smith, The National Environmental Policy Act: Judicial Misconstruction, Legislative Indifference and Executive Neglect, Texas A&M University Press, 2002.
[5] U.S. House Energy and Commerce Committee, Testimony of Timothy Probert, May 12, 2010, available at http://energycommerce.house.gov/Press_111/20100512/Probert.Testimony.05.12.2010.pdf.
[6] Arthur E. Berman, What caused the Deepwater Horizon disaster? The Oil Drum, May 21, 2010, available at www.theoildrum.com/node/6493.
[7] U.S. House Energy and Commerce Committee, BP presentation: Deepwater Horizon interim incident investigation, May 24, 2010, available at http://energycommerce.house.gov/documents/20100527/BP.Presentation.pdf (19 MB), page 14.
[8] Edmund L. Andrews, U.S. has royalty plan to give windfall to oil companies, New York Times, February 15, 2006, available at www.nytimes.com/2006/02/14/business/14oil.html. Edmund L. Andrews, Oil lease chief knew of error, report asserts, New York Times, January 18, 2007, available at www.nytimes.com/2007/01/17/washington/17royalty.html. Inspector General, Interior Department, Lack of price thresholds in Gulf of Mexico oil and gas leases, January 2007, available at www.doioig.gov/upload/MMS%20ROI%20REDACTED.pdf.
[9] Edmund L. Andrews, As profits soar, companies pay U.S. less for gas rights, New York Times, January 24, 2006, available at www.nytimes.com/2006/01/23/politics/23leases.html. William Yardley, Arctic drilling proposal advanced amid concern, New York Times, May 20, 2010, available at www.nytimes.com/2010/05/20/science/earth/20alaska.html. Juliet Eilperin, U.S. agency overseeing oil drilling ignored warnings of risks, Washington Post, May 25, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/24/AR2010052401974.html.
[10] Charlie Savage, Sex, drug use and graft cited in Interior Department, New York Times, September 10, 2008, available at www.nytimes.com/2008/09/11/washington/11royalty.html. Inspector General, Interior Department, OIG investigations of MMS employees, Re: Gregory W. Smith, MMS Oil Marketing Group and Federal Business Solutions contracts, September 9, 2008, available at www.doioig.gov/upload/FBS%20REDACTED%20with%20Transmittal%209_10%20date.pdf.
[11] Juliet Eilperin, U.S. exempted BP's Gulf of Mexico drilling from environmental impact study, Washington Post, May 5, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/04/AR2010050404118.html. Minerals Management Service, Budget justification and performance information, fiscal year 2010, available at www.mms.gov/adm/PFD/2007BudgetJustification.pdf, page 85.
[12] Minerals Management Service, Gulf of Mexico Oil and Gas Lease Sales, 2007-2012, Nos. 204, 205, 206, 207, 208, 210, 213, 215, 216, 218 and 222, Final Environmental Assessment, Volumes 1 and 2, April 2007, available at www.gomr.mms.gov/PDFs/2007/2007-018-Vol1.pdf and www.gomr.mms.gov/PDFs/2007/2007-018-Vol2.pdf.
[13] Minerals Management Service, Initial exploration plan, lease OCS-G32306, block 252 Mississippi Canyon area, March 10, 2009, available at www.gomr.mms.gov/PI/PDFImages/PLANS/29/29977.pdf (rubber-stamped NOTED-SCHEXNALIDRE). Minerals Management Service, Contents of plan (Appendix A NTL No. 2006-G14 Guidance for MMS-137 OCS Plan Information Form, August 2003), available at www.gomr.mms.gov/homepg/regulate/regs/ntls/ntl03-g17.pdf.
[14] Scott Berinato, Coast Guard, DHS and Deepwater: same ship, different day, CSO Magazine, May 1, 2004, available at www.csoonline.com/article/219221/Coast_Guard_DHS_and_Deepwater_Same_Ship_Different_Day. Susan Saulny, Finger-pointing, but few answers at hearings on drilling, New York Times, May 12, 2010, available at www.nytimes.com/2010/05/12/us/12spill.html. Ian Urbina, U.S. said to allow drilling without needed permits, New York Times, May 14, 2010, available at www.nytimes.com/2010/05/14/us/14agency.html. Justin Gillis, Scientists fault U.S. response in assessing Gulf oil spill, New York Times, May 20, 2010, available at www.nytimes.com/2010/05/20/science/earth/20noaa.html. Lynn Yaris, Caution required for Gulf oil spill clean-up, Lawrence Berkeley National Laboratory, May 4, 2010, available at http://newscenter.lbl.gov/feature-stories/2010/05/04/gulf-oil-spill-clean-up/. Jason Dearen and Ray Henry, Associated Press, Chemicals used to fight Gulf of Mexico oil spill a trade-off, New Orleans Times-Picayune, May 5, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/chemicals_used_to_fight_gulf_o.html.
[15] The White House, President Barack Obama, Administration-wide response to BP spill, May 3, 2010, available at www.whitehouse.gov/blog/2010/05/03/comprehensive-update-administration-wide-response-bp-spill. "Secretary Napolitano and Secretary Salazar signed an order establishing the next steps for a joint investigation that is currently underway into the causes of the explosion of the drilling rig Deepwater Horizon in the Gulf of Mexico. The U.S. Coast Guard (USCG) and the Minerals Management Service (MMS) share jurisdiction for the investigation." Matthew L. Wald, Independent inquiry into oil spill is urged, New York Times, May 15, 2010, available at www.nytimes.com/2010/05/15/us/politis/15inquire.html.
[16] John M. Broder and Shaila Dewan, White House to create panel to study Gulf oil spill, New York Times, May 18, 2010, available at www.nytimes.com/2010/05/18/us/18spill.html. Juliet Eilperin and Scott Wilson, Birnbaum 'took fall' after MMS played catch-up after lapses in ethics, oversight, Washington Post, May 29, 2010 available at www.washingtonpost.com/wp-dyn/content/article/2010/05/28/AR2010052804855.html. Debbi Wilgoren and Michael D. Shear, Obama to ban new deepwater oil wells, cancel lease sales off Virginia and Alaska coasts, Washington Post, May 27, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/27/AR2010052701172.html. Juliet Eilperin and David A. Fahrenthold, Graham, Reilly to lead investigation of oil spill, Washington Post, May 22, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/21/AR2010052102403.html. The White House, President Barack Obama, Executive order, National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling. May 22, 2010, available at www.whitehouse.gov/the-press-office/executive-order-national-commission-bp-deepwater-horizon-oil-spill-and-offshore-dri.
[17] Tom Zeller, Jr., Estimates suggest spill is biggest in U.S. history, New York Times, May 28, 2010, available at www.nytimes.com/2010/05/28/us/28flow.html. Flow Rate Technical Group, U.S. Geological Survey, Flow Rate Group provides preliminary best estimate of oil flowing from BP oil well, May 27, 2010, available at www.doi.gov/news/pressreleases/Flow-Rate-Group-Provides-Preliminary-Best-Estimate-Of-Oil-Flowing-from-BP-Oil-Well.cfm.
[18] Energy Resources Co., Ixtoc oil spill assessment, final report, U.S. Bureau of Land Management, March, 1982, available at www.gomr.mms.gov/PI/PDFImages/ESPIS/3/3977.pdf. March Schliefstein, BP's "top kill" process fails, forced officials to attempt yet another strategy, New Orleans Times-Picayune, May 30, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/bps_ballyhooed_top_kill_proces.html. Jeffrey Kluger, As top kill drags on, BP's credibility problems grow, Time, May 28, 2010, available at www.time.com/time/health/article/0,8599,1992627,00.html.
[19] David Prestipino, Cause of western Australia oil spill revealed, Western Australia Today, November 10, 2009, available at www.watoday.com.au/environment/cause-of-wa-oil-spill-revealed-20091109-i59k.html. Montara Commission of Inquiry, Australia Ministry for Resources and Energy, multiple documents available at www.montarainquiry.gov.au.
[20] Steven Mufson and Michael D. Shear, Pressure grows for action by BP, Washington Post, May 1, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/04/30/AR2010043002715.html. Debbi Wilgoren, Joel Achenbach and Anne E. Kornblut, Gulf Coast oil spill may take months to contain, officials say, Washington Post, May 3, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/03/AR2010050301669.html
[21] West Engineering Services, Shear ram capabilities study, Minerals Management Service, September, 2004, available at www.mms.gov/tarprojects/463/(463)%20West%20Engineering%20Final%20Report.pdf.
[22] PCCI Marine and Environmental Engineering, Oil spill containment, remote sensing and tracking for deepwater blowouts, Minerals Management Service, August, 1999, available at www.mms.gov/tarprojects/311/311AA.pdf. West Engineering Services, Mini shear study, Minerals Management Service, December, 2002, available at www.mms.gov/tarprojects/455/Final%20Report.pdf. West Engineering Services, Evaluation of secondary intervention methods in well control, Minerals Management Service, March, 2003, available at www.mms.gov/tarprojects/431/FinalReport431.pdf.
Both disasters might have been prevented by adequate government regulation. In the 1920s, when it would have mattered most, there was hardly any government presence in agriculture other than the field stations set up by states and the federal government to assist with, but not to regulate, crop management. The federal government and many states were in the grip of deeply conservative, even reactionary administrations, firmly opposed to government regulations. Their closest approach had been the federal Pure Food and Drug Act of 1906, passed during the Theodore Roosevelt administration and largely aimed at unsanitary meat packing. [3]
The 2010 Gulf of Mexico well blowout came 41 years after a similar disaster, the 1969 well blowout in Santa Barbara Channel, a few miles off the California coast. Shocked by gross pollution of the Pacific coastline, Congress swiftly passed the National Environmental Policy Act of 1969. [4] It formed a basis of regulation that had become institutionalized in missions of government agencies by the time of the 2010 disaster. Yet like the Pure Food and Drug Act, the National Environmental Policy Act proved susceptible to manipulation and evasion. Regulations created and enforced under it failed to prevent a catastrophe, even though when one occurred the federal government was a progressive administration committed to environmental protection.
The major cause of the 2010 Gulf of Mexico well blowout was quickly assessed, only several days after public release of a well schematic. [5] Dr. Arthur Berman, a Houston petroleum geologist, showed that unsafe design for the Macondo 1 well had left unrestrained areas of bare drillhole, above a high-pressure oil and gas reservoir, connected to the sea floor through an annulus between metal casings. [6] His analysis of the final cementing operation was soon confirmed through a public release of data from the well owner. [7] What had yet to be released at that point were documents showing the faulty design as submitted to and approved by the Minerals Management Service (MMS), an agency of the U.S. Department of the Interior set up to supervise offshore oil and gas operations.
As of 2010, MMS had managed federal leases of outer continental shelf lands and supervised their operations for 28 years, under authority of the Federal Oil & Gas Royalty Management Act of 1982. Many responsibilities were created by the National Environmental Policy Act, which requires environmental impact statements for such activities. During several years before the 2010 blowout, MMS had been repeatedly troubled by mismanagement and corruption. In 1998 and subsequent years major blunders occurred. Faulty contracts allowed leaseholders to avoid many billions of dollars in oil and gas royalties, disclosed by the New York Times February 15, 2006. Although the problems were discovered within MMS in 2004, MMS took no action to correct them until the public disclosure, according to the inspector general for the Interior Department. [8]
MMS had long paid cash bonuses to employees for expediting work related to oil and gas development, a key element in creating a corrupt job environment. [9] In 2008 MMS was found by its inspector general to host what he called a "culture of ethical failure." Abuses cited included patronage, inside dealing, kickbacks, revolving door employment and misuse of federal property--extending over a period of at least four years. As a result of the investigation several employees were reassigned, some quit, and at least one was convicted of a felony. [10]
In 2010 the Macondo 1 well blowout in the Gulf of Mexico led reporters to discover that its lease and many other projects in the Gulf of Mexico had been exempted by MMS from environmental reviews. As a result, companies had not been required to prepare and document emergency responses. The Deepwater Horizon platform lacked a fail-safe blowout preventer, and the Macondo 1 well owner lacked salvage equipment. In budget documents MMS had claimed efficiency from using "categorical exclusion" for a "streamlined" form of environmental review. [11] What the agency did was generate a prepackaged deal for companies. A pro-forma environmental review was prepared by and approved within the agency. After companies paid for leases, they were automatically exempted from reviews, and their applications to conduct operations were, quite literally, rubber-stamped.
The Macondo 1 well was mainly regulated under a "multisale EIS" (Environmental Impact Statement) covering 11 Gulf of Mexico leases, prepared by MMS staff in 2007. Its risk analysis finds that over 40 years, "there is a 69-86 percent chance of one or more spills [of] 1,000 barrels [or more] occurring" [page 4-231]. The "multisale EIS" finds substantial risk that a spill of 1,000 or more barrels will pollute many miles of coastline [page 4-234]. It also indicates that pollution can persist for many years [page 4-238]. Thus MMS knew that a disaster in this area was likely and that consequences would probably be widespread and long-lasting. [12]
The exploration plan filed with MMS to drill the Macondo 1 well described a worst-case oil discharge as 300,000 barrels per day, giving a number without saying "barrels." However, MMS instructions for such plans show daily volume in barrels. In less than 12 days such a discharge would exceed the world's worst ocean oil disaster, the 1979 Ixtoc 1 well blowout, also in the Gulf of Mexico. MMS knew the Macondo 1 well had the potential to cause a catastrophe, yet it gave the plan routine approval, letting the owner go ahead without documented procedures for responding to such a radical emergency. [13]
Immediately after the Macondo 1 well blowout the U.S. Coast Guard failed to mount coordinated rescue, control and salvage operations. Years of focusing on terrorism rather than natural and industrial disasters had left it unprepared for such an event. MMS permitted relief wells without requiring any more safety preparation than it had required for the well that blew out. The U.S. National Oceanic and Atmospheric Administration distributed a hasty assessment of the crude oil discharge rate that was soon shown to be scientifically faulty, and then it refused to release data and methods. The U.S. Environmental Protection Agency issued a hasty decision endorsing untested use of large quantities of dispersants, when environmental evidence showed that similar chemicals had led to long term environmental damage. [14]
Despite contributions to the problems, the Coast Guard and MMS were put in charge of an initial investigation. [15] Outrage over crude oil reaching beaches and marshland and protests over a compromised investigation led to a rapid series of actions: reorganization plans for the MMS, resignation of the MMS director, suspension of all offshore drilling in deep water, new drilling permits and offshore oil and gas leasing, and appointment of a Presidential investigating commission. [16] The U.S. Geological Survey prepared an estimate of the discharge, putting it at 12 to 19 thousand barrels (500 to 800 thousand gallons) of crude oil per day. [17]
Through May, 2010, the Macondo 1 well owner tried a series of maneuvers to trap or plug the oil discharge, without much success. Similar maneuvers had been tried with previous subsea well blowouts, notably the 1979 135F platform, Ixtoc 1 well blowout in the Bay of Campeche off Mexico. Despite the same kinds of attempts, that blowout flowed for 290 days, discharging an estimated 120-200 million gallons of crude oil into the southern Gulf of Mexico, the world's greatest accidental ocean oil disaster so far. [18]
Sometimes such maneuvers succeeded, as with the 1977 Bravo platform, well B14 blowout in the North Sea off Norway. But when reservoir pressure was high and consequent gas flow was strong they failed, as they recently did with the Montara platform, well H1 blowout in the Timor Sea off northwest Australia, which flowed for 70 days. [19] Company and U.S. officials lied, saying the Macondo 1 well blowout was "unprecedented," and success of the maneuvers would be unpredictable. All that was really unprecedented was water depth. There was otherwise substantial experience with similar blowouts, but there was an unprepared industry and a similarly unprepared government. [20]
The blowout preventer (BOP) configured for the Deepwater Horizon platform failed; otherwise the blowout would have been prevented. That failure was also by design, as the U.S. Minerals Management Service has been made fully aware. [21] Current-generation blowout preventers depend on shearing blind rams (SBRs) to cut drill pipe, so as to allow floating platforms like Deepwater Horizon to seal a well, disconnect from it and move away. Current-generation SBRs cannot cut through pipe joints, the enlarged, hardened sections of steel that join segments of drill pipe. About ten percent of the lineal extent of drill pipe is joint. However, BOP rams do not close with a snap. Their hydraulic systems are regulated, and they take most of a minute to close. During that time the force of a blowout is pushing drill pipe upward. As an SBR nears the point of full closure, inevitably an upward-moving pipe joint lodges in it. After trapping the pipe joint, the SBR then cannot cut it.
U.S. government says it will revise offshore oil and gas regulations and agency organizations. However, few if any people working in U.S. government actually know what to do. In the aftermath of the 1969 Santa Barbara disaster laws were written, but then they were often ignored. If the aftermath of the 1979 Bay of Campeche catastrophe, industry developed a slightly improved blowout preventer (in use at the Macondo 1 well), and U.S. government prepared a few internal studies. [22] As a result, MMS knew that existing offshore oil and gas well development was unsafe and knew that neither government nor industry was prepared for a major emergency, but it failed to generate plans, conduct relevant research, arrange for improved equipment and supplies, perform engineering evaluations or coordinate such efforts with companies or other agencies. Decades of opportunity were squandered, leading to another catastrophe.
[1] R. Douglas Hurt, The Dust Bowl: An Agricultural and Social History, Burnham, 1981.
[2] Tom Fowler, Experts have their doubts on well's design, Houston Chronicle, May 26, 2010, available at www.chron.com/disp/story.mpl/business/deepwaterhorizon/7022355.html. Ian Urbina, Documents show early worries about safety of rig, New York Times, May 30, 2010, available at www.nytimes.com/2010/05/30/us/30rig.html.
[3] James Harvey Young, Pure Food: Securing the Federal Food and Drugs Act of 1906, Princeton University Press, 1989.
[4] Matthew J. Lindstrom and Zachary A. Smith, The National Environmental Policy Act: Judicial Misconstruction, Legislative Indifference and Executive Neglect, Texas A&M University Press, 2002.
[5] U.S. House Energy and Commerce Committee, Testimony of Timothy Probert, May 12, 2010, available at http://energycommerce.house.gov/Press_111/20100512/Probert.Testimony.05.12.2010.pdf.
[6] Arthur E. Berman, What caused the Deepwater Horizon disaster? The Oil Drum, May 21, 2010, available at www.theoildrum.com/node/6493.
[7] U.S. House Energy and Commerce Committee, BP presentation: Deepwater Horizon interim incident investigation, May 24, 2010, available at http://energycommerce.house.gov/documents/20100527/BP.Presentation.pdf (19 MB), page 14.
[8] Edmund L. Andrews, U.S. has royalty plan to give windfall to oil companies, New York Times, February 15, 2006, available at www.nytimes.com/2006/02/14/business/14oil.html. Edmund L. Andrews, Oil lease chief knew of error, report asserts, New York Times, January 18, 2007, available at www.nytimes.com/2007/01/17/washington/17royalty.html. Inspector General, Interior Department, Lack of price thresholds in Gulf of Mexico oil and gas leases, January 2007, available at www.doioig.gov/upload/MMS%20ROI%20REDACTED.pdf.
[9] Edmund L. Andrews, As profits soar, companies pay U.S. less for gas rights, New York Times, January 24, 2006, available at www.nytimes.com/2006/01/23/politics/23leases.html. William Yardley, Arctic drilling proposal advanced amid concern, New York Times, May 20, 2010, available at www.nytimes.com/2010/05/20/science/earth/20alaska.html. Juliet Eilperin, U.S. agency overseeing oil drilling ignored warnings of risks, Washington Post, May 25, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/24/AR2010052401974.html.
[10] Charlie Savage, Sex, drug use and graft cited in Interior Department, New York Times, September 10, 2008, available at www.nytimes.com/2008/09/11/washington/11royalty.html. Inspector General, Interior Department, OIG investigations of MMS employees, Re: Gregory W. Smith, MMS Oil Marketing Group and Federal Business Solutions contracts, September 9, 2008, available at www.doioig.gov/upload/FBS%20REDACTED%20with%20Transmittal%209_10%20date.pdf.
[11] Juliet Eilperin, U.S. exempted BP's Gulf of Mexico drilling from environmental impact study, Washington Post, May 5, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/04/AR2010050404118.html. Minerals Management Service, Budget justification and performance information, fiscal year 2010, available at www.mms.gov/adm/PFD/2007BudgetJustification.pdf, page 85.
[12] Minerals Management Service, Gulf of Mexico Oil and Gas Lease Sales, 2007-2012, Nos. 204, 205, 206, 207, 208, 210, 213, 215, 216, 218 and 222, Final Environmental Assessment, Volumes 1 and 2, April 2007, available at www.gomr.mms.gov/PDFs/2007/2007-018-Vol1.pdf and www.gomr.mms.gov/PDFs/2007/2007-018-Vol2.pdf.
[13] Minerals Management Service, Initial exploration plan, lease OCS-G32306, block 252 Mississippi Canyon area, March 10, 2009, available at www.gomr.mms.gov/PI/PDFImages/PLANS/29/29977.pdf (rubber-stamped NOTED-SCHEXNALIDRE). Minerals Management Service, Contents of plan (Appendix A NTL No. 2006-G14 Guidance for MMS-137 OCS Plan Information Form, August 2003), available at www.gomr.mms.gov/homepg/regulate/regs/ntls/ntl03-g17.pdf.
[14] Scott Berinato, Coast Guard, DHS and Deepwater: same ship, different day, CSO Magazine, May 1, 2004, available at www.csoonline.com/article/219221/Coast_Guard_DHS_and_Deepwater_Same_Ship_Different_Day. Susan Saulny, Finger-pointing, but few answers at hearings on drilling, New York Times, May 12, 2010, available at www.nytimes.com/2010/05/12/us/12spill.html. Ian Urbina, U.S. said to allow drilling without needed permits, New York Times, May 14, 2010, available at www.nytimes.com/2010/05/14/us/14agency.html. Justin Gillis, Scientists fault U.S. response in assessing Gulf oil spill, New York Times, May 20, 2010, available at www.nytimes.com/2010/05/20/science/earth/20noaa.html. Lynn Yaris, Caution required for Gulf oil spill clean-up, Lawrence Berkeley National Laboratory, May 4, 2010, available at http://newscenter.lbl.gov/feature-stories/2010/05/04/gulf-oil-spill-clean-up/. Jason Dearen and Ray Henry, Associated Press, Chemicals used to fight Gulf of Mexico oil spill a trade-off, New Orleans Times-Picayune, May 5, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/chemicals_used_to_fight_gulf_o.html.
[15] The White House, President Barack Obama, Administration-wide response to BP spill, May 3, 2010, available at www.whitehouse.gov/blog/2010/05/03/comprehensive-update-administration-wide-response-bp-spill. "Secretary Napolitano and Secretary Salazar signed an order establishing the next steps for a joint investigation that is currently underway into the causes of the explosion of the drilling rig Deepwater Horizon in the Gulf of Mexico. The U.S. Coast Guard (USCG) and the Minerals Management Service (MMS) share jurisdiction for the investigation." Matthew L. Wald, Independent inquiry into oil spill is urged, New York Times, May 15, 2010, available at www.nytimes.com/2010/05/15/us/politis/15inquire.html.
[16] John M. Broder and Shaila Dewan, White House to create panel to study Gulf oil spill, New York Times, May 18, 2010, available at www.nytimes.com/2010/05/18/us/18spill.html. Juliet Eilperin and Scott Wilson, Birnbaum 'took fall' after MMS played catch-up after lapses in ethics, oversight, Washington Post, May 29, 2010 available at www.washingtonpost.com/wp-dyn/content/article/2010/05/28/AR2010052804855.html. Debbi Wilgoren and Michael D. Shear, Obama to ban new deepwater oil wells, cancel lease sales off Virginia and Alaska coasts, Washington Post, May 27, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/27/AR2010052701172.html. Juliet Eilperin and David A. Fahrenthold, Graham, Reilly to lead investigation of oil spill, Washington Post, May 22, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/21/AR2010052102403.html. The White House, President Barack Obama, Executive order, National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling. May 22, 2010, available at www.whitehouse.gov/the-press-office/executive-order-national-commission-bp-deepwater-horizon-oil-spill-and-offshore-dri.
[17] Tom Zeller, Jr., Estimates suggest spill is biggest in U.S. history, New York Times, May 28, 2010, available at www.nytimes.com/2010/05/28/us/28flow.html. Flow Rate Technical Group, U.S. Geological Survey, Flow Rate Group provides preliminary best estimate of oil flowing from BP oil well, May 27, 2010, available at www.doi.gov/news/pressreleases/Flow-Rate-Group-Provides-Preliminary-Best-Estimate-Of-Oil-Flowing-from-BP-Oil-Well.cfm.
[18] Energy Resources Co., Ixtoc oil spill assessment, final report, U.S. Bureau of Land Management, March, 1982, available at www.gomr.mms.gov/PI/PDFImages/ESPIS/3/3977.pdf. March Schliefstein, BP's "top kill" process fails, forced officials to attempt yet another strategy, New Orleans Times-Picayune, May 30, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/bps_ballyhooed_top_kill_proces.html. Jeffrey Kluger, As top kill drags on, BP's credibility problems grow, Time, May 28, 2010, available at www.time.com/time/health/article/0,8599,1992627,00.html.
[19] David Prestipino, Cause of western Australia oil spill revealed, Western Australia Today, November 10, 2009, available at www.watoday.com.au/environment/cause-of-wa-oil-spill-revealed-20091109-i59k.html. Montara Commission of Inquiry, Australia Ministry for Resources and Energy, multiple documents available at www.montarainquiry.gov.au.
[20] Steven Mufson and Michael D. Shear, Pressure grows for action by BP, Washington Post, May 1, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/04/30/AR2010043002715.html. Debbi Wilgoren, Joel Achenbach and Anne E. Kornblut, Gulf Coast oil spill may take months to contain, officials say, Washington Post, May 3, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/05/03/AR2010050301669.html
[21] West Engineering Services, Shear ram capabilities study, Minerals Management Service, September, 2004, available at www.mms.gov/tarprojects/463/(463)%20West%20Engineering%20Final%20Report.pdf.
[22] PCCI Marine and Environmental Engineering, Oil spill containment, remote sensing and tracking for deepwater blowouts, Minerals Management Service, August, 1999, available at www.mms.gov/tarprojects/311/311AA.pdf. West Engineering Services, Mini shear study, Minerals Management Service, December, 2002, available at www.mms.gov/tarprojects/455/Final%20Report.pdf. West Engineering Services, Evaluation of secondary intervention methods in well control, Minerals Management Service, March, 2003, available at www.mms.gov/tarprojects/431/FinalReport431.pdf.
Saturday, May 22, 2010
Making an energy extraction disaster worse
Extracting energy from natural resources often carries hazards that are not well known. Because of the April, 2010, explosion at the Upper Big Branch mine in West Virginia, some hazards of coal mining are once again widely publicized, [1] although coal mine disasters have been common for near two centuries. [2] But other coal mining hazards, including stream disturbance from subsidence, methane discharges, underground fires and the vast destruction of environment from surface mining, remain little known to most of the public. [3]
When disasters occur while extracting energy from natural resources, human errors can make them worse. April of 2010 has been a cruel month. Several incidents during the Macondo 1 well blowout in the Gulf of Mexico, including origins of the blowout itself, appear to come from human errors that should have been preventable. [4] Few of the many errors are more vexing than acts of U.S. government agencies trying to respond to that disaster.
Evidence from news reports suggests little or no U.S. Coast Guard planning and coordination for responses to the immense fire. Water, sprayed from several vessels on the fire, entered pontoons of the semi-submersible Deepwater Horizon platform, causing it to capsize and sink after about a day and a half. [5] The huge volumes of natural gas and oil discharges continued to burn at the sea surface, but water sprays were then used to extinguish the fire. As previous ocean oil disasters showed, like the 1979 Ixtoc 1 well blowout in the southern Gulf of Mexico, sea surface fires can burn more than half of blowout discharges, reducing environmental impacts. [6] Through mid-May, 2010, the Coast Guard had provided no detailed public explanation of its actions.
The U.S. Environmental Protection Agency issued instructions allowing the U.S. Air Force and BP, owner of the Macondo 1 well, to apply hundreds of thousands of gallons of dispersant chemicals, both on the sea surface and on the sea floor in the vicinity of discharges from the Macondo 1 well. [7] Short-term effects of dispersant chemicals on marine environments are only partly known, and long-term effects are often unknown.
There have been controversies over the use of dispersants in ocean oil disasters ever since their first major application, following the 1967 Torrey Canyon disaster off the southwest coast of England. Studies suggest long-term hazards, leaving treated coastal environments more disturbed than environments where no cleanup was attempted. [8] The EPA has had decades to evaluate dispersants, but its research has been meager, leaving the agency unprepared in emergencies to respond on the basis of thorough scientific knowledge. In an apparent attempt to mitigate hazards of dispersants being used for the Macondo 1 well blowout, EPA issued supplementary instructions to BP on May 20, 2010. [9] A simultaneous press release said that EPA intended to require use of "less toxic" chemicals. [10]
EPA maintains short-term acute toxicity information for dispersants. [11] Two marine species are used to rate "50 percent lethal concentration" (LC50) in parts per million for approved dispersants: the inland silverside (Menidia beryllina), an estuary fish, after 96 hours exposure, and the oppossum shrimp (Mysidopsis bahia), also an estuary dweller, after 48 hours exposure. In addition, there are "effectiveness" ratings for two crude oils, "Prudhoe Bay Crude" and "South Louisiana Crude." EPA has published testing procedures for the ratings. [12]
As of mid-May, 2010, the EPA-maintained National Contingency Plan Product Schedule included fifteen dispersant products, three of them under multiple trade names. [13] They are listed here in the order of least toxic to most toxic, by 96-hour exposure LC50 ratings in parts per million for Menidia beryllina:
In the May 20, 2010, EPA instructions to BP the key sentence reads, "...BP shall identify...dispersant products from the National Contingency Plan Product Schedule that...have a toxicity value less than or equal to 23.00 ppm LC50 toxicity value for Menidia or 18.00 ppm LC50 for Mysidopsis...." News reports indicated BP was following EPA instructions literally, [14] saying BP had been using Corexit EC9500A, rated at 96-hour LC50 of 25.2 parts per million for Menidia beryllina, but after the May 20 EPA instructions was ordering Dispersit SPC 1000, rated at 96-hour LC50 of 3.5 parts per million for Menidia beryllina.
EPA has provided no rationale for the specific criteria in its May 20 instructions. Their obvious effect is to allow use of the dispersant products Finasol OSR 52, Dispersit SPC 100 and JD-109. It is not clear whether Spillclean would qualify; it has LC50 for Mysidopsis less than 18 but LC50 for Menidia greater than 23, and it lacks an "effectiveness" rating. It is also not clear whether Corexit EC9527A or Biodispers would qualify; they have LC50 for Menidia less than 23 but LC50 for Mysidopsis greater than 18. The instructions say "or" as to LC50 ratings but have ambiguous grammar.
Well known to environmental workers, "a lower LC50 means the substance is more toxic," such as effects of metal ions in fish ponds. [15] Whoever wrote and whoever approved the May 20 EPA instructions apparently did not know that lower LC50 means higher toxicity. Whoever generated specific criteria for dispersants seems to have been choosing products to endorse rather than applying environmental knowledge. Superior products in EPA listings, on the basis of their LC50 toxicity ratings, include Mare Clean 200 and JD-2000. However, those products would not satisfy the misguided EPA criteria.
Adverse consequences in this situation were avoided. BP cancelled its order for Dispersit SPC 100 and responded to EPA that it could not find a qualifying dispersant "in sufficiently large quantities to be useful at the time of the spill." EPA rescinded the erroneous instructions, saying it would issue new ones. [16] It is likely that someone at BP saw through the mistake and realized its potential to make an energy extraction disaster worse. Major news media never told and therefore most of the public never learned about gross incompetence shown by the government during this incident.
[1] Jerry Markon, David A. Fahrenthold and Kimberly Kindy, Mine company faulted on safety issues, Washington Post, April 8, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/04/06/AR2010040604984.html.
[2] H. B. Humphrey, Historical summary of coal mine explosions in the United States, Bulletin 586, U.S. Bureau of Mines, U.S. Government Printing Office (1960). United States Mine Rescue Association, Historical data on mine disasters in the United States, available at www.usmra.com/saxsewell/historical.htm. U.S. Mine Safety and Health Administration, Coal fatalities, 1900-2009, available at www.msha.gov/stats/centurystats/coalstats.asp.
[3] Pennsylvania Department of Environmental Protection, The Effects of Subsidence Resulting from Underground Bituminous Coal Mining on Surface Structures and Features and Water Resources (2005), 25 files, available at www.dep.state.pa.us/dep/deputate/minres/bmr/act54_2004_report/toc_01_pdf.htm. Robert R. Seal II, Environmental processes that affect mineral deposits in the eastern United States, U.S. Geological Survey, U.S. Department of the Interior (1999), available at http://pubs.usgs.gov/info/seal1/. Evironment: The price of strip mining, Time 97(12), March 22, 1971, available at www.time.com/time/magazine/article/0,9171,904921,00.html. Davie Rennie, How China's scramble for 'black gold' is causing a green disaster, London Telegraph, February 1, 2002, available at www.telegraph.co.uk/news/worldnews/asia/china/1383465/How-Chinas-scramble-for-black-gold-is-causing-a-green-disaster.html.
[4] Janet McConnaughey and Holbrook Mohr, Associated Press, Oil rig reported explosion 3 hours before fire, WFMJ, Youngstown, OH, April 22, 2010, available at www.wfmj.com/Global/story.asp?S=12353917. "James," Deepwater Horizon: A firsthand account, Mark Levin Show, WABC, New York City, April 30, 2010, transcription available at http://nigeriavillagesquare.com/forum/main-square/54217-deepwater-horizon-firsthand-account.html.
[5] Campbell Robertson, Search continues after oil rig blast, New York Times, April 22, 2010, available at www.nytimes.com/2010/04/22/us/22rig.html. Russell Gold, Safety device questioned in 2004, Wall Street Journal, May 3, 2010, available at http://online.wsj.com/article/SB10001424052748703969204575220630638397628.html. Les Blumenthal, McClatchy, Blowout preventers often fail, report says, Tacoma, WA, News Tribune, May 1, 2010, available at www.thenewstribune.com/2010/04/30/1169719/us-report-found-failure-of-offshore.html. Michael Kunzelman and Richard T. Pienciak, Associated Press, Feds let BP avoid filing blowout plan for Gulf rig, WTOP, May 6, 2010, available at www.wtop.com/?nid=111&sid=1950669. Susan Saulny, Finger-pointing, but few answers at hearings on drilling, New York Times, May 12, 2010, available at www.nytimes.com/2010/05/12/us/12spill.html. Scott Pelley, interviewer, Blowout: The Deepwater Horizon disaster, 60 Minutes, CBS News, May 16, 2010, available at www.cbsnews.com/stories/2010/05/16/60minutes/main6490197.shtml.
[6] Energy Resources Co., Ixtoc oil spill assessment, final report, Bureau of Land Management, U.S. Department of the Interior (1982), available at www.gomr.mms.gov/PI/PDFImages/ESPIS/3/3977.pdf
[7] Jason Dearen and Ray Henry, Associated Press, Chemicals used to fight Gulf of Mexico oil spill a trade-off, New Orleans Times-Picayune, May 5, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/chemicals_used_to_fight_gulf_o.html. Ted Jackovics, Air Force C-130s spray chemical to help break up oil spill, Tampa Tribune, May 10, 2010, available at www2.tbo.com/content/2010/may/10/air-force-c-130s-spray-chemical-help-break-oil-spi/. U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive for subsurface dispersant application, May 10, 2010, available at www.epa.gov/bpspill/dispersants/subsurface-dispersant-directive-final.pdf.
[8] Committee on Effectiveness of Oil Spill Dispersants, Marine Board, National Research Council, Using Oil Spill Dispersants on the Sea, National Academies Press (1989), Appendix B, Torrey Canyon, pp. 317-318, available at www.nap.edu/openbook.php?record_id=736&page=317. Robert J. Fiocco and Alun Lewis, Oil spill dispersants, in Pure and Applied Chemistry 71(1), 1999, special issue on oil spill countermeasures, pp. 27-42, available at http://old.iupac.org/publications/pac/special/0199/pdfs/fiocco.pdf.
[9] U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive, Addendum 2, May 20, 2010, available at www.epa.gov/bpspill/dispersants/directive-addendum2.pdf.
[10] U.S. Environmental Protection Agency, EPA: BP must use less toxic dispersant, May 20, 2010, available at http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/0897f55bc6d9a3ba852577290067f67f!OpenDocument.
[11] U.S. Environmental Protection Agency, FSOC dispersant pre-approval guidelines and checklist (1995), Table 1, LC50 toxicities and toxicity indices of crude oils for marine organisms, p. A-10.
[12] U.S. Environmental Protection Agency, Methods for measuring the acute toxicity of effluents and receiving waters to freshwater and marine organisms, at www.epa.gov/waterscience/methods/wet/disk2/. U.S Environmental Protection Agency, Swirling flask dispersant effectiveness test, 40 CFR 300, Appendix C (1997), pp. 224-246, available at www.epa.gov/oem/docs/oil/cfr/appendix_c.pdf.
[13] U.S. Environmental Protection Agency, National Contingency Plan Product Schedule, for Category select Dispersant, at www.epa.gov/emergencies/content/ncp/product_schedule.htm.
[14] Campbell Robertson and Elisabeth Rosenthal, Agency orders use of a less toxic chemical in Gulf, New York Times, May 21, 2010, available at www.nytimes.com/2010/05/21/science/earth/21disperse.html.
[15] Tim Gilbert, Copper in fish ponds, Koi Fish Ponds, Denver, Colorado, at www.koifishponds.com/copper.htm.
[16] Paul Purpura, BP can continue using controversial dispersant, New Orleans Times-Picayune, May 24, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/epa_bp_can_continue_using_cont.html.
When disasters occur while extracting energy from natural resources, human errors can make them worse. April of 2010 has been a cruel month. Several incidents during the Macondo 1 well blowout in the Gulf of Mexico, including origins of the blowout itself, appear to come from human errors that should have been preventable. [4] Few of the many errors are more vexing than acts of U.S. government agencies trying to respond to that disaster.
Evidence from news reports suggests little or no U.S. Coast Guard planning and coordination for responses to the immense fire. Water, sprayed from several vessels on the fire, entered pontoons of the semi-submersible Deepwater Horizon platform, causing it to capsize and sink after about a day and a half. [5] The huge volumes of natural gas and oil discharges continued to burn at the sea surface, but water sprays were then used to extinguish the fire. As previous ocean oil disasters showed, like the 1979 Ixtoc 1 well blowout in the southern Gulf of Mexico, sea surface fires can burn more than half of blowout discharges, reducing environmental impacts. [6] Through mid-May, 2010, the Coast Guard had provided no detailed public explanation of its actions.
The U.S. Environmental Protection Agency issued instructions allowing the U.S. Air Force and BP, owner of the Macondo 1 well, to apply hundreds of thousands of gallons of dispersant chemicals, both on the sea surface and on the sea floor in the vicinity of discharges from the Macondo 1 well. [7] Short-term effects of dispersant chemicals on marine environments are only partly known, and long-term effects are often unknown.
There have been controversies over the use of dispersants in ocean oil disasters ever since their first major application, following the 1967 Torrey Canyon disaster off the southwest coast of England. Studies suggest long-term hazards, leaving treated coastal environments more disturbed than environments where no cleanup was attempted. [8] The EPA has had decades to evaluate dispersants, but its research has been meager, leaving the agency unprepared in emergencies to respond on the basis of thorough scientific knowledge. In an apparent attempt to mitigate hazards of dispersants being used for the Macondo 1 well blowout, EPA issued supplementary instructions to BP on May 20, 2010. [9] A simultaneous press release said that EPA intended to require use of "less toxic" chemicals. [10]
EPA maintains short-term acute toxicity information for dispersants. [11] Two marine species are used to rate "50 percent lethal concentration" (LC50) in parts per million for approved dispersants: the inland silverside (Menidia beryllina), an estuary fish, after 96 hours exposure, and the oppossum shrimp (Mysidopsis bahia), also an estuary dweller, after 48 hours exposure. In addition, there are "effectiveness" ratings for two crude oils, "Prudhoe Bay Crude" and "South Louisiana Crude." EPA has published testing procedures for the ratings. [12]
As of mid-May, 2010, the EPA-maintained National Contingency Plan Product Schedule included fifteen dispersant products, three of them under multiple trade names. [13] They are listed here in the order of least toxic to most toxic, by 96-hour exposure LC50 ratings in parts per million for Menidia beryllina:
| Dispersant | Toxicity LC50, ppm | Toxicity LC50, ppm | Effectiveness | |
| Product | Menidia beryllina | Mysidopsis bahia | So. La. Crude | |
| MARE CLEAN 200 | 1996 96-hr | 938 48-hr | 84.1% | |
| JD-2000 | 407.00 96-hr | 90.50 48-hr | 77.8% | |
| NEOS AB3000 | 91.1 96-hr | 33.0 48-hr | 89.8% | |
| NOKOMIS 3-AA | 34.22 96-hr | 20.16 48-hr | 65.7% | |
| ZI-400 | 31.76 96-hr | 20.96 48-hr | 89.8% | |
| SEA BRAT #4 | 30.00 96-hr | 14.00 48-hr | 60.6% | |
| NOKOMIS 3-F4 | 29.80 96-hr | 32.20 48-hr | 64.9% | |
| SAF-RON GOLD | 29.43 96-hr | 63.00 48-hr | 53.8% | |
| COREXIT EC9500A | 25.20 96-hr | 32.23 48-hr | 54.7% | |
| SPILLCLEAN | 24.30 96-hr | 10.00 48-hr | N/A | |
| COREXIT EC9527A | 14.57 96-hr | 24.14 48-hr | 63.4% | |
| BIODISPERS | 13.46 96-hr | 78.90 48-hr | 63.0% | |
| FINASOL OSR 52 | 11.66 96-hr | 9.37 48-hr | 71.6% | |
| DISPERSIT SPC 1000 | 3.5 96-hr | 16.6 48-hr | 105 % | |
| JD-109 | 1.90 96-hr | 1.18 48-hr | 91 % |
In the May 20, 2010, EPA instructions to BP the key sentence reads, "...BP shall identify...dispersant products from the National Contingency Plan Product Schedule that...have a toxicity value less than or equal to 23.00 ppm LC50 toxicity value for Menidia or 18.00 ppm LC50 for Mysidopsis...." News reports indicated BP was following EPA instructions literally, [14] saying BP had been using Corexit EC9500A, rated at 96-hour LC50 of 25.2 parts per million for Menidia beryllina, but after the May 20 EPA instructions was ordering Dispersit SPC 1000, rated at 96-hour LC50 of 3.5 parts per million for Menidia beryllina.
EPA has provided no rationale for the specific criteria in its May 20 instructions. Their obvious effect is to allow use of the dispersant products Finasol OSR 52, Dispersit SPC 100 and JD-109. It is not clear whether Spillclean would qualify; it has LC50 for Mysidopsis less than 18 but LC50 for Menidia greater than 23, and it lacks an "effectiveness" rating. It is also not clear whether Corexit EC9527A or Biodispers would qualify; they have LC50 for Menidia less than 23 but LC50 for Mysidopsis greater than 18. The instructions say "or" as to LC50 ratings but have ambiguous grammar.
Well known to environmental workers, "a lower LC50 means the substance is more toxic," such as effects of metal ions in fish ponds. [15] Whoever wrote and whoever approved the May 20 EPA instructions apparently did not know that lower LC50 means higher toxicity. Whoever generated specific criteria for dispersants seems to have been choosing products to endorse rather than applying environmental knowledge. Superior products in EPA listings, on the basis of their LC50 toxicity ratings, include Mare Clean 200 and JD-2000. However, those products would not satisfy the misguided EPA criteria.
Adverse consequences in this situation were avoided. BP cancelled its order for Dispersit SPC 100 and responded to EPA that it could not find a qualifying dispersant "in sufficiently large quantities to be useful at the time of the spill." EPA rescinded the erroneous instructions, saying it would issue new ones. [16] It is likely that someone at BP saw through the mistake and realized its potential to make an energy extraction disaster worse. Major news media never told and therefore most of the public never learned about gross incompetence shown by the government during this incident.
[1] Jerry Markon, David A. Fahrenthold and Kimberly Kindy, Mine company faulted on safety issues, Washington Post, April 8, 2010, available at www.washingtonpost.com/wp-dyn/content/article/2010/04/06/AR2010040604984.html.
[2] H. B. Humphrey, Historical summary of coal mine explosions in the United States, Bulletin 586, U.S. Bureau of Mines, U.S. Government Printing Office (1960). United States Mine Rescue Association, Historical data on mine disasters in the United States, available at www.usmra.com/saxsewell/historical.htm. U.S. Mine Safety and Health Administration, Coal fatalities, 1900-2009, available at www.msha.gov/stats/centurystats/coalstats.asp.
[3] Pennsylvania Department of Environmental Protection, The Effects of Subsidence Resulting from Underground Bituminous Coal Mining on Surface Structures and Features and Water Resources (2005), 25 files, available at www.dep.state.pa.us/dep/deputate/minres/bmr/act54_2004_report/toc_01_pdf.htm. Robert R. Seal II, Environmental processes that affect mineral deposits in the eastern United States, U.S. Geological Survey, U.S. Department of the Interior (1999), available at http://pubs.usgs.gov/info/seal1/. Evironment: The price of strip mining, Time 97(12), March 22, 1971, available at www.time.com/time/magazine/article/0,9171,904921,00.html. Davie Rennie, How China's scramble for 'black gold' is causing a green disaster, London Telegraph, February 1, 2002, available at www.telegraph.co.uk/news/worldnews/asia/china/1383465/How-Chinas-scramble-for-black-gold-is-causing-a-green-disaster.html.
[4] Janet McConnaughey and Holbrook Mohr, Associated Press, Oil rig reported explosion 3 hours before fire, WFMJ, Youngstown, OH, April 22, 2010, available at www.wfmj.com/Global/story.asp?S=12353917. "James," Deepwater Horizon: A firsthand account, Mark Levin Show, WABC, New York City, April 30, 2010, transcription available at http://nigeriavillagesquare.com/forum/main-square/54217-deepwater-horizon-firsthand-account.html.
[5] Campbell Robertson, Search continues after oil rig blast, New York Times, April 22, 2010, available at www.nytimes.com/2010/04/22/us/22rig.html. Russell Gold, Safety device questioned in 2004, Wall Street Journal, May 3, 2010, available at http://online.wsj.com/article/SB10001424052748703969204575220630638397628.html. Les Blumenthal, McClatchy, Blowout preventers often fail, report says, Tacoma, WA, News Tribune, May 1, 2010, available at www.thenewstribune.com/2010/04/30/1169719/us-report-found-failure-of-offshore.html. Michael Kunzelman and Richard T. Pienciak, Associated Press, Feds let BP avoid filing blowout plan for Gulf rig, WTOP, May 6, 2010, available at www.wtop.com/?nid=111&sid=1950669. Susan Saulny, Finger-pointing, but few answers at hearings on drilling, New York Times, May 12, 2010, available at www.nytimes.com/2010/05/12/us/12spill.html. Scott Pelley, interviewer, Blowout: The Deepwater Horizon disaster, 60 Minutes, CBS News, May 16, 2010, available at www.cbsnews.com/stories/2010/05/16/60minutes/main6490197.shtml.
[6] Energy Resources Co., Ixtoc oil spill assessment, final report, Bureau of Land Management, U.S. Department of the Interior (1982), available at www.gomr.mms.gov/PI/PDFImages/ESPIS/3/3977.pdf
[7] Jason Dearen and Ray Henry, Associated Press, Chemicals used to fight Gulf of Mexico oil spill a trade-off, New Orleans Times-Picayune, May 5, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/chemicals_used_to_fight_gulf_o.html. Ted Jackovics, Air Force C-130s spray chemical to help break up oil spill, Tampa Tribune, May 10, 2010, available at www2.tbo.com/content/2010/may/10/air-force-c-130s-spray-chemical-help-break-oil-spi/. U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive for subsurface dispersant application, May 10, 2010, available at www.epa.gov/bpspill/dispersants/subsurface-dispersant-directive-final.pdf.
[8] Committee on Effectiveness of Oil Spill Dispersants, Marine Board, National Research Council, Using Oil Spill Dispersants on the Sea, National Academies Press (1989), Appendix B, Torrey Canyon, pp. 317-318, available at www.nap.edu/openbook.php?record_id=736&page=317. Robert J. Fiocco and Alun Lewis, Oil spill dispersants, in Pure and Applied Chemistry 71(1), 1999, special issue on oil spill countermeasures, pp. 27-42, available at http://old.iupac.org/publications/pac/special/0199/pdfs/fiocco.pdf.
[9] U.S. Environmental Protection Agency, Dispersant monitoring and assessment directive, Addendum 2, May 20, 2010, available at www.epa.gov/bpspill/dispersants/directive-addendum2.pdf.
[10] U.S. Environmental Protection Agency, EPA: BP must use less toxic dispersant, May 20, 2010, available at http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/0897f55bc6d9a3ba852577290067f67f!OpenDocument.
[11] U.S. Environmental Protection Agency, FSOC dispersant pre-approval guidelines and checklist (1995), Table 1, LC50 toxicities and toxicity indices of crude oils for marine organisms, p. A-10.
[12] U.S. Environmental Protection Agency, Methods for measuring the acute toxicity of effluents and receiving waters to freshwater and marine organisms, at www.epa.gov/waterscience/methods/wet/disk2/. U.S Environmental Protection Agency, Swirling flask dispersant effectiveness test, 40 CFR 300, Appendix C (1997), pp. 224-246, available at www.epa.gov/oem/docs/oil/cfr/appendix_c.pdf.
[13] U.S. Environmental Protection Agency, National Contingency Plan Product Schedule, for Category select Dispersant, at www.epa.gov/emergencies/content/ncp/product_schedule.htm.
[14] Campbell Robertson and Elisabeth Rosenthal, Agency orders use of a less toxic chemical in Gulf, New York Times, May 21, 2010, available at www.nytimes.com/2010/05/21/science/earth/21disperse.html.
[15] Tim Gilbert, Copper in fish ponds, Koi Fish Ponds, Denver, Colorado, at www.koifishponds.com/copper.htm.
[16] Paul Purpura, BP can continue using controversial dispersant, New Orleans Times-Picayune, May 24, 2010, available at www.nola.com/news/gulf-oil-spill/index.ssf/2010/05/epa_bp_can_continue_using_cont.html.
Thursday, February 18, 2010
Nuclear fallout
Among the biggest nuclear power hazards in the United States have been financial ones. Of 259 orders for nuclear power reactors from 1955 through 2005, 124 were cancelled and 3 terminated for other causes. Making it through to an operating license were 132 reactor orders [1], a success rate of 51 percent. Nuclear fallout continued with early shutdowns of the licensed reactors. Through 2005, 28 had been shut down, leaving 104 in operation. Operating lives of the reactors shut down ranged from less than 1 year to 35 years, all less than the expected 40 years, with an average operating life of 14.1 years [2]. Survival rate to mature operation was 40 percent.
Of the 124 reactor orders cancelled, 15 were under construction. All those abandoned reactors occurred between 1982 and 1988 for construction that started between 1972 and 1977 [3]. Financial losses totalled $22.3 billion at times of abandonment, or $60 billion adjusted to the start of 2010. Following is a list of the abandoned United States nuclear power reactors (reactor name, location, start year, stop year, adjusted loss):
This discussion and the list of abandoned reactors do not count military or research programs, including the Clinch River Breeder Reactor at Oak Ridge, TN, abandoned in 1983 after spending about $1.6 billion in then-current dollars. Nor do they count losses from the 109 power reactors cancelled before construction, which have rarely been reported and never summarized. Those losses may have totalled $100 billion or more in 2010 dollars, based on a Missouri rate increase approved, but never implemented, for an unbuilt reactor [4]. The last reactor order cancellation occurred in 1994, ending a long run of heavy losses for electric utilities.
The period from the mid-1970s through the mid-1980s was a wild ride for the nuclear power industry. For a few years around the Arab Oil Embargo of 1973 orders surged. Then the industry found new demands for electricity well short of projections. At the same time, federal regulations rapidly tightened safety requirements, a trend that strengthened after the disaster at Three Mile Island 2 in 1979, greatly increasing construction costs. Hyperinflation of the late 1970s further increased costs, as interest rates on construction loans spiraled. When planned in 1971, the Vogtle plant in Georgia was estimated to cost $0.66 billion for four reactors, but when completed in 1989 it actually cost $8.87 billion for two reactors, including financing [5]. Cost escalation per reactor was about a factor of 9, adjusted for inflation.
The U.S. began a second half-century of nuclear power with promises of "third generation" reactors that would be safer, more reliable and more predictable to build and operate. The new reactor designs are supposed to be certified for operation before starting construction, unlike the earlier generations that were certified only on licensing to operate. There are more than twenty orders pending for those reactors. However, risks of failure remain high. As of early 2010 the construction cost for 1,200 MW of nuclear power capacity was estimated at around $7.9 billion [6], while the construction cost for the same coal-fired capacity was estimated at around $4.2 billion [7]. As of 2010, no proposed reactor could be built without a loan guarantee from the federal government. Protracted negotiations were needed to set loan guarantee fees. There also remain liability caps for major disasters (the Price-Anderson Act of 1957) underwritten by the federal government.
Dr. Paul Joskow, an MIT economist, estimated the cost of bulk power from "third generation" commercial nuclear reactors at 6.7 cents per kWh in 2006, based on $2.4 billion in construction costs for 1,200 MW of capacity [8]. In comparison, he estimated costs from 3.8 to 5.2 cents per kWh for power from coal-fired and gas-fired units. Dr. Joskow based his estimates on so-called "overnight" costs of construction, without interest or inflation, but of course reactors cannot be built overnight, so his models include some allowances for cost growth.
In view of the nuclear power industry's history, radically underestimating construction costs and cost growth, it would be prudent to substitute current, fully loaded cost estimates in place of the "overnight" costs, hoping that actual cost escalation will not break the budget of allowances in economic models. At $7.9 billion for 1,200 MW of capacity, the cost for nuclear power in Dr. Joskow's estimates would grow to 17.7 cents per kWh [9].
Recently Dr. John Parsons, an MIT Sloan School economist, showed that published costs for "third generation" nuclear plants use different approaches [10]. Some bundle in transmission upgrades; some include interest; some allow for cost escalation. The variations produce large discrepancies. Dr. Parsons' estimate of the "overnight" cost in 2007 for the power plant in reference [6] works out to $5.7 billion for 1,200 MW of capacity.
Probably more significant than specifics of estimates is a pattern of cost growth. The works of both Dr. Joskow and Dr. Parsons indicate that they trusted a 2002 "base case" of $2.00 a watt for the "overnight" cost of a "third generation" nuclear power plant. As of 2007, Dr. Parsons' estimate became $3.95 a watt, for an average of 5 plants with 10 reactors [10]. Cost estimates from these economists nearly doubled in only 5 years.
Only radical increases in costs of fossil-fuel plants and prices of fossil fuels could compensate for such huge differences between costs of power from nuclear and competing new sources. For the forseeable future, nuclear power looks like a high-risk, high-cost option for the United States, and for that reason it is unlikely to grow rapidly, even with strong support from the federal government.
[1] U.S. Energy Information Agency, History of energy in the United States: Nuclear Energy (2002), available at www.eia.doe.gov/emeu/aer/eh/nuclear.html.
[2] U.S. Energy Information Agency, Nuclear generating units 1955-2008 (2009), available at www.eia.doe.gov/emeu/aer/pdf/pages/sec9_3.pdf. U.S. Nuclear Regulatory Commission, Commercial nuclear power reactors formerly licensed to operate (2005), available at www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/v1/part07.html.
[3] Compiled from public records, Cancelled nuclear units ordered in the United States (2005), available at http://clonemaster.homestead.com/files/cancel.htm
[4] U.S. PIRG, A history of action in the public interest, 1980s (2002), available at www.uspirg.org/results/a-history-of-action-in-the-public-interest/1980s.
[5] U.S. Energy Information Administration, Vogtle nuclear power plant, Georgia (2009), available at www.eia.doe.gov/cneaf/nuclear/page/at_a_glance/reactors/vogtle.html.
[6] Rob Pavey, Feds back two new reactors at Plant Vogtle, Augusta Chronicle, February 16, 2010, available at http://chronicle.augusta.com/latest-news/2010-02-16/obama-announce-loan-guarantee-vogtle (two 1,100 MW units).
[7] Stacey Roberts, Utility's rate-rise request tapered, Arkansas Democrat-Gazette, October 15, 2009, available at www.arkansasonline.com/news/2009/oct/15/utilitys-rate-rise-request-tapered-20091015/ (one 600 MW unit).
[8] Paul L. Joskow, Prospects for nuclear power, a U.S. perspective (2006), available at http://econ-www.mit.edu/files/1187. See Comparative Base Load Costs, page 23.
[9] See Craig A. Severance, Business risks and costs of new nuclear power, Electricity Journal 22(4):112-120 (2009), draft version available at http://climateprogress.org/wp-content/uploads/2009/01/nuclear-costs-2009.pdf. Extended analysis in this study predicts bulk cost for nuclear power from "third generation" nuclear reactors of 25-30 cents per kWh.
[10] John E. Parsons, Financing new nuclear generation (2009, updating Future of nuclear power, 2003), available at www.mit.edu/~jparsons/Presentations/090709%20EPRG%20CEEPR%20GDF%20Summer%20Workshop.pdf. See Table 4.
Of the 124 reactor orders cancelled, 15 were under construction. All those abandoned reactors occurred between 1982 and 1988 for construction that started between 1972 and 1977 [3]. Financial losses totalled $22.3 billion at times of abandonment, or $60 billion adjusted to the start of 2010. Following is a list of the abandoned United States nuclear power reactors (reactor name, location, start year, stop year, adjusted loss):
| WNP-1 | Hanford, WA | 1975 | 1982 | $2.0 billion |
| WNP-4 | Hanford, WA | 1975 | 1982 | $1.4 billion |
| WNP-5 | Satsop, WA | 1977 | 1982 | $1.6 billion |
| Zimmer 1 | Moscow, OH | 1972 | 1983 | $5.5 billion |
| Cherokee 1 | Gaffney, SC | 1976 | 1983 | $1.7 billion |
| WNP-3 | Satsop, WA | 1977 | 1983 | $1.6 billion |
| Midland 1 | Midland, MI | 1973 | 1984 | $4.4 billion |
| Midland 2 | Midland, MI | 1973 | 1984 | $7.6 billion |
| Marble Hill 1 | New Washington, IN | 1977 | 1984 | $4.7 billion |
| Marble Hill 2 | New Washington, IN | 1977 | 1984 | $2.4 billion |
| Perry 2 | North Perry, OH | 1974 | 1985 | $2.7 billion |
| Bellefonte 1 | Hollywood, AL | 1974 | 1988 | $9.3 billion |
| Bellefonte 2 | Hollywood, AL | 1974 | 1988 | $6.2 billion |
| Seabrook 2 | Portsmouth, NH | 1976 | 1988 | $4.9 billion |
| Watts Bar 2 | Spring City, TN | 1977 | 1988 | $4.1 billion |
This discussion and the list of abandoned reactors do not count military or research programs, including the Clinch River Breeder Reactor at Oak Ridge, TN, abandoned in 1983 after spending about $1.6 billion in then-current dollars. Nor do they count losses from the 109 power reactors cancelled before construction, which have rarely been reported and never summarized. Those losses may have totalled $100 billion or more in 2010 dollars, based on a Missouri rate increase approved, but never implemented, for an unbuilt reactor [4]. The last reactor order cancellation occurred in 1994, ending a long run of heavy losses for electric utilities.
The period from the mid-1970s through the mid-1980s was a wild ride for the nuclear power industry. For a few years around the Arab Oil Embargo of 1973 orders surged. Then the industry found new demands for electricity well short of projections. At the same time, federal regulations rapidly tightened safety requirements, a trend that strengthened after the disaster at Three Mile Island 2 in 1979, greatly increasing construction costs. Hyperinflation of the late 1970s further increased costs, as interest rates on construction loans spiraled. When planned in 1971, the Vogtle plant in Georgia was estimated to cost $0.66 billion for four reactors, but when completed in 1989 it actually cost $8.87 billion for two reactors, including financing [5]. Cost escalation per reactor was about a factor of 9, adjusted for inflation.
The U.S. began a second half-century of nuclear power with promises of "third generation" reactors that would be safer, more reliable and more predictable to build and operate. The new reactor designs are supposed to be certified for operation before starting construction, unlike the earlier generations that were certified only on licensing to operate. There are more than twenty orders pending for those reactors. However, risks of failure remain high. As of early 2010 the construction cost for 1,200 MW of nuclear power capacity was estimated at around $7.9 billion [6], while the construction cost for the same coal-fired capacity was estimated at around $4.2 billion [7]. As of 2010, no proposed reactor could be built without a loan guarantee from the federal government. Protracted negotiations were needed to set loan guarantee fees. There also remain liability caps for major disasters (the Price-Anderson Act of 1957) underwritten by the federal government.
Dr. Paul Joskow, an MIT economist, estimated the cost of bulk power from "third generation" commercial nuclear reactors at 6.7 cents per kWh in 2006, based on $2.4 billion in construction costs for 1,200 MW of capacity [8]. In comparison, he estimated costs from 3.8 to 5.2 cents per kWh for power from coal-fired and gas-fired units. Dr. Joskow based his estimates on so-called "overnight" costs of construction, without interest or inflation, but of course reactors cannot be built overnight, so his models include some allowances for cost growth.
In view of the nuclear power industry's history, radically underestimating construction costs and cost growth, it would be prudent to substitute current, fully loaded cost estimates in place of the "overnight" costs, hoping that actual cost escalation will not break the budget of allowances in economic models. At $7.9 billion for 1,200 MW of capacity, the cost for nuclear power in Dr. Joskow's estimates would grow to 17.7 cents per kWh [9].
Recently Dr. John Parsons, an MIT Sloan School economist, showed that published costs for "third generation" nuclear plants use different approaches [10]. Some bundle in transmission upgrades; some include interest; some allow for cost escalation. The variations produce large discrepancies. Dr. Parsons' estimate of the "overnight" cost in 2007 for the power plant in reference [6] works out to $5.7 billion for 1,200 MW of capacity.
Probably more significant than specifics of estimates is a pattern of cost growth. The works of both Dr. Joskow and Dr. Parsons indicate that they trusted a 2002 "base case" of $2.00 a watt for the "overnight" cost of a "third generation" nuclear power plant. As of 2007, Dr. Parsons' estimate became $3.95 a watt, for an average of 5 plants with 10 reactors [10]. Cost estimates from these economists nearly doubled in only 5 years.
Only radical increases in costs of fossil-fuel plants and prices of fossil fuels could compensate for such huge differences between costs of power from nuclear and competing new sources. For the forseeable future, nuclear power looks like a high-risk, high-cost option for the United States, and for that reason it is unlikely to grow rapidly, even with strong support from the federal government.
[1] U.S. Energy Information Agency, History of energy in the United States: Nuclear Energy (2002), available at www.eia.doe.gov/emeu/aer/eh/nuclear.html.
[2] U.S. Energy Information Agency, Nuclear generating units 1955-2008 (2009), available at www.eia.doe.gov/emeu/aer/pdf/pages/sec9_3.pdf. U.S. Nuclear Regulatory Commission, Commercial nuclear power reactors formerly licensed to operate (2005), available at www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/v1/part07.html.
[3] Compiled from public records, Cancelled nuclear units ordered in the United States (2005), available at http://clonemaster.homestead.com/files/cancel.htm
[4] U.S. PIRG, A history of action in the public interest, 1980s (2002), available at www.uspirg.org/results/a-history-of-action-in-the-public-interest/1980s.
[5] U.S. Energy Information Administration, Vogtle nuclear power plant, Georgia (2009), available at www.eia.doe.gov/cneaf/nuclear/page/at_a_glance/reactors/vogtle.html.
[6] Rob Pavey, Feds back two new reactors at Plant Vogtle, Augusta Chronicle, February 16, 2010, available at http://chronicle.augusta.com/latest-news/2010-02-16/obama-announce-loan-guarantee-vogtle (two 1,100 MW units).
[7] Stacey Roberts, Utility's rate-rise request tapered, Arkansas Democrat-Gazette, October 15, 2009, available at www.arkansasonline.com/news/2009/oct/15/utilitys-rate-rise-request-tapered-20091015/ (one 600 MW unit).
[8] Paul L. Joskow, Prospects for nuclear power, a U.S. perspective (2006), available at http://econ-www.mit.edu/files/1187. See Comparative Base Load Costs, page 23.
[9] See Craig A. Severance, Business risks and costs of new nuclear power, Electricity Journal 22(4):112-120 (2009), draft version available at http://climateprogress.org/wp-content/uploads/2009/01/nuclear-costs-2009.pdf. Extended analysis in this study predicts bulk cost for nuclear power from "third generation" nuclear reactors of 25-30 cents per kWh.
[10] John E. Parsons, Financing new nuclear generation (2009, updating Future of nuclear power, 2003), available at www.mit.edu/~jparsons/Presentations/090709%20EPRG%20CEEPR%20GDF%20Summer%20Workshop.pdf. See Table 4.
Sunday, June 28, 2009
A climate puzzle
Despite widely advertised commitment to open government,[1] on climate issues the Obama administration seems to have become as intolerant as its predecessor, although with different bias. CBS News reported June 26, 2009,[2] that EPA officials had suppressed in mid-March a paper by Dr. Alan Carlin, a senior economist in the National Center for Environmental Economics, working at EPA since 1971.
Dr. Carlin's error was a review of climate change skeptical about the potential for carbon dioxide emissions to explain it.[3] The report has been made available on a Web site maintained by political opponents of government regulation. Dr. Carlin was reassigned from climate change analysis to updating a grants database. CBS News may have picked up the story from WorldNet Daily, which reported it about a day earlier.[4]
Dr. Carlin began investigating climate change issues in 2003 and does not have a career invested in them. He operates as an outside critic, looking for problems with assumptions, methods and data. The main theme of his March, 2009, paper was to ask whether global temperature measurements since the last major review by the U.N. Intergovernmental Panel on Climate Change (IPCC) called into question that review's conclusions about rising temperatures and their potential associations with carbon dioxide emissions.
In contrast to a rapid run-up of temperatures leading to a spike in 1998, the last three years show a declining trend in satellite temperature measurements, about 0.1 Centigrade degrees per year, based on data summarized by the Hadley Center at the University of Alabama, Huntsville. Until moderated by the current deep recession, world carbon dioxide emissions continued to accelerate. Dr. Carlin shows that recent temperature measurements are in substantial disagreement with IPCC predictions published in 2007.
In an article published the year before his run-in with EPA management,[5] Dr. Carlin surveyed familiar potential contributors to global temperatures: solar output, clouds and water vapor, greenhouse gases, aerosols and urbanization of land. He describes IPCC numerical modeling and notes its susceptibility to the choices of data used to estimate effects that cannot be adequately described by physical principles alone. He recalls fears of an impending ice age that seized climate researchers a few decades ago and emphasizes major uncertainties remaining in determining conditions that could lead to run-away temperature changes under positive feedback.
Dr. Carlin's main conclusion in [5] was that it is impossible to estimate reliably the economic consequences of decreasing emissions of greenhouse gases (GHGs) as the exclusive approach used to control global warming: "Climate sensitivity, the key technical variable describing climate [response] to increased GHG levels, appears to be unknowable in advance."[6] His reasoning calls to mind the discovery of intrinically chaotic mathematics by Prof. Edward Lorenz at MIT in 1961, while trying to develop models of weather systems.[7]
The suppressed Carlin paper later develops an adversarial tone: "One of the most glaring problems of all with the EPA's Endangerment TSD (technical support document) is the nearly complete disregard of observed trends...."[8] The paper contains internal evidence suggesting a document that circulated within its agency over an extended period. For example, a footnote on p. 67 says "comment by Ken Gregory--June 21, 2008." A discussion of climate model assumptions notes that IPCC modeling assumed nearly constant global humidity, while long-term data show declining trends, opposing the effects of increases in atmospheric concentrations of carbon dioxide.[9]
Dr. Carlin's style tends to hyperbole, for example, the assertion that climate sensitivity is "unknowable in advance," which could be a factor in his current situation. The article he cites from Gerard S. Roe and Marcia B. Baker [6] shows instead that climate sensitivity can be described through probability distributions. However, the distributions are extremely broad, with significant probabilities over a tenfold or greater range. So in terms of economics, Dr. Carlin appears to be correct. Based on available evidence, we cannot reliably predict effects of control strategies that depend on climate sensitivities to greenhouse gases.
In a 2007 article,[10] Dr. Carlin reviewed mid-1990s proposals by Dr. Edward Teller and collaborators, reported from Livermore National Laboratory, for airborne or spaceborne solar reflectors.[11] The Teller report, in turn, claims derivation from ideas of Dr. James Hansen and collaborators at NASA Goddard Institute for Space Studies, published several years earlier.[12] Some ill-informed criticism of those proposals [13] suggests that physical intervention in solar absorption would be inconsistent with claims about lack of reliable ability to predict climate. However, some of the approaches proposed in the Teller report are reversible or have short decay times, allowing them to be adapted to ongoing climate behavior. The central point of Dr. Carlin's review is that the probable cost of solar reflection would be far lower than the probable cost of greenhouse gas control.
[1] Lisa P. Jackson, Statement by Administrator-designate, U.S. Environmental Protection Agency, January 23, 2009, available at http://yosemite.epa.gov/opa/admpress.nsf/0/2297C12A9F4773D285257547006497D4. "...I will ensure EPA’s efforts to address the environmental crises of today are rooted in three fundamental values: science-based policies and programs, adherence to the rule of law, and overwhelming transparency."
[2] Declan McCullagh, EPA may have suppressed report skeptical of global warming, CBS News, June 26, 2009, available at www.cbsnews.com/blogs/2009/06/26/politics/politicalhotsheet/entry5117890.shtml.
[3] Proposed NCEE comments on draft technical support document for endangerment analysis for greenhouse gas emissions under the Clean Air Act, U.S. National Center for Environmental Economics, March 16, 2009, made available at http://cei.org/cei_files/fm/active/0/DOC062509-004.pdf.
[4] Chelsea Schilling, EPA's own research expert 'shut up' on climate change, WorldNet Daily, June 25, 2009, at www.worldnetdaily.com/index.php?fa=PAGE.view&pageId=102031 (retrieved June 27, 2009, from Google cache).
[5] Alan Carlin, Why a different approach is required if global climate change is to be controlled efficiently or even at all, Environmental Law and Policy Review, 32(3):685-757, 2008, full text available on the Internet at http://carlineconomics.googlepages.com/Endangermentcommentsv7b1.pdf.
[6] Cited: Gerard S. Roe and Marcia B. Baker, Why is climate sensitivity so unpredictable?, Science 318(5850):629-632, October 26, 2007, full text available on the Internet at http://earthweb.ess.washington.edu/roe/Publications/RoeBaker_Science07.pdf.
[7] Recounted in: James Gleick, Chaos: Making a New Science (1987, Viking), The butterfly effect, pp. 11-31.
[8] Ref. [3], p. 64.
[9] Ref. [3], pp. 67-70.
[10] Alan Carlin, Global climate change control: Is there a better strategy than reducing greenhouse gas emissions?, University of Pennsylvania Law Review 155(6):1401-1497, June, 2007, available at http://pennumbra.com/issues/pdfs/155-6/Carlin.pdf.
[11] Edward M. Teller, Lowell Wood and Roderick Hyde, Global warming and ice ages: Prospects for physics-based modulation of global change, UCR Livermore National Laboratory Report UCRL-JC-128715, August 15, 1997, available at www.osti.gov/accomplishments/documents/fullText/ACC0229.pdf.
[12] James E. Hansen and Andrew A. Lacis, Sun and dust versus greenhouse gases: An assessment of their relative
roles in global climate change, Nature 346:713-719, August 23, 1990.
[13] "Eris,"Re: CEI releases global warming study censored by EPA, Message 3, Colbert Nation, June 27, 2009, at http://forum.colbertnation.com/tcr/board/message?board.id=conspiracy&message.id=4655. "Carlin appears to be a big fan of geo-engineering, but how this squares with his apparent belief that we know nothing about what drives climate, is puzzling. A sine qua non of geo-engineering is that we need models to be able to predict what is likely to happen."
Dr. Carlin's error was a review of climate change skeptical about the potential for carbon dioxide emissions to explain it.[3] The report has been made available on a Web site maintained by political opponents of government regulation. Dr. Carlin was reassigned from climate change analysis to updating a grants database. CBS News may have picked up the story from WorldNet Daily, which reported it about a day earlier.[4]
Dr. Carlin began investigating climate change issues in 2003 and does not have a career invested in them. He operates as an outside critic, looking for problems with assumptions, methods and data. The main theme of his March, 2009, paper was to ask whether global temperature measurements since the last major review by the U.N. Intergovernmental Panel on Climate Change (IPCC) called into question that review's conclusions about rising temperatures and their potential associations with carbon dioxide emissions.
In contrast to a rapid run-up of temperatures leading to a spike in 1998, the last three years show a declining trend in satellite temperature measurements, about 0.1 Centigrade degrees per year, based on data summarized by the Hadley Center at the University of Alabama, Huntsville. Until moderated by the current deep recession, world carbon dioxide emissions continued to accelerate. Dr. Carlin shows that recent temperature measurements are in substantial disagreement with IPCC predictions published in 2007.
In an article published the year before his run-in with EPA management,[5] Dr. Carlin surveyed familiar potential contributors to global temperatures: solar output, clouds and water vapor, greenhouse gases, aerosols and urbanization of land. He describes IPCC numerical modeling and notes its susceptibility to the choices of data used to estimate effects that cannot be adequately described by physical principles alone. He recalls fears of an impending ice age that seized climate researchers a few decades ago and emphasizes major uncertainties remaining in determining conditions that could lead to run-away temperature changes under positive feedback.
Dr. Carlin's main conclusion in [5] was that it is impossible to estimate reliably the economic consequences of decreasing emissions of greenhouse gases (GHGs) as the exclusive approach used to control global warming: "Climate sensitivity, the key technical variable describing climate [response] to increased GHG levels, appears to be unknowable in advance."[6] His reasoning calls to mind the discovery of intrinically chaotic mathematics by Prof. Edward Lorenz at MIT in 1961, while trying to develop models of weather systems.[7]
The suppressed Carlin paper later develops an adversarial tone: "One of the most glaring problems of all with the EPA's Endangerment TSD (technical support document) is the nearly complete disregard of observed trends...."[8] The paper contains internal evidence suggesting a document that circulated within its agency over an extended period. For example, a footnote on p. 67 says "comment by Ken Gregory--June 21, 2008." A discussion of climate model assumptions notes that IPCC modeling assumed nearly constant global humidity, while long-term data show declining trends, opposing the effects of increases in atmospheric concentrations of carbon dioxide.[9]
Dr. Carlin's style tends to hyperbole, for example, the assertion that climate sensitivity is "unknowable in advance," which could be a factor in his current situation. The article he cites from Gerard S. Roe and Marcia B. Baker [6] shows instead that climate sensitivity can be described through probability distributions. However, the distributions are extremely broad, with significant probabilities over a tenfold or greater range. So in terms of economics, Dr. Carlin appears to be correct. Based on available evidence, we cannot reliably predict effects of control strategies that depend on climate sensitivities to greenhouse gases.
In a 2007 article,[10] Dr. Carlin reviewed mid-1990s proposals by Dr. Edward Teller and collaborators, reported from Livermore National Laboratory, for airborne or spaceborne solar reflectors.[11] The Teller report, in turn, claims derivation from ideas of Dr. James Hansen and collaborators at NASA Goddard Institute for Space Studies, published several years earlier.[12] Some ill-informed criticism of those proposals [13] suggests that physical intervention in solar absorption would be inconsistent with claims about lack of reliable ability to predict climate. However, some of the approaches proposed in the Teller report are reversible or have short decay times, allowing them to be adapted to ongoing climate behavior. The central point of Dr. Carlin's review is that the probable cost of solar reflection would be far lower than the probable cost of greenhouse gas control.
[1] Lisa P. Jackson, Statement by Administrator-designate, U.S. Environmental Protection Agency, January 23, 2009, available at http://yosemite.epa.gov/opa/admpress.nsf/0/2297C12A9F4773D285257547006497D4. "...I will ensure EPA’s efforts to address the environmental crises of today are rooted in three fundamental values: science-based policies and programs, adherence to the rule of law, and overwhelming transparency."
[2] Declan McCullagh, EPA may have suppressed report skeptical of global warming, CBS News, June 26, 2009, available at www.cbsnews.com/blogs/2009/06/26/politics/politicalhotsheet/entry5117890.shtml.
[3] Proposed NCEE comments on draft technical support document for endangerment analysis for greenhouse gas emissions under the Clean Air Act, U.S. National Center for Environmental Economics, March 16, 2009, made available at http://cei.org/cei_files/fm/active/0/DOC062509-004.pdf.
[4] Chelsea Schilling, EPA's own research expert 'shut up' on climate change, WorldNet Daily, June 25, 2009, at www.worldnetdaily.com/index.php?fa=PAGE.view&pageId=102031 (retrieved June 27, 2009, from Google cache).
[5] Alan Carlin, Why a different approach is required if global climate change is to be controlled efficiently or even at all, Environmental Law and Policy Review, 32(3):685-757, 2008, full text available on the Internet at http://carlineconomics.googlepages.com/Endangermentcommentsv7b1.pdf.
[6] Cited: Gerard S. Roe and Marcia B. Baker, Why is climate sensitivity so unpredictable?, Science 318(5850):629-632, October 26, 2007, full text available on the Internet at http://earthweb.ess.washington.edu/roe/Publications/RoeBaker_Science07.pdf.
[7] Recounted in: James Gleick, Chaos: Making a New Science (1987, Viking), The butterfly effect, pp. 11-31.
[8] Ref. [3], p. 64.
[9] Ref. [3], pp. 67-70.
[10] Alan Carlin, Global climate change control: Is there a better strategy than reducing greenhouse gas emissions?, University of Pennsylvania Law Review 155(6):1401-1497, June, 2007, available at http://pennumbra.com/issues/pdfs/155-6/Carlin.pdf.
[11] Edward M. Teller, Lowell Wood and Roderick Hyde, Global warming and ice ages: Prospects for physics-based modulation of global change, UCR Livermore National Laboratory Report UCRL-JC-128715, August 15, 1997, available at www.osti.gov/accomplishments/documents/fullText/ACC0229.pdf.
[12] James E. Hansen and Andrew A. Lacis, Sun and dust versus greenhouse gases: An assessment of their relative
roles in global climate change, Nature 346:713-719, August 23, 1990.
[13] "Eris,"Re: CEI releases global warming study censored by EPA, Message 3, Colbert Nation, June 27, 2009, at http://forum.colbertnation.com/tcr/board/message?board.id=conspiracy&message.id=4655. "Carlin appears to be a big fan of geo-engineering, but how this squares with his apparent belief that we know nothing about what drives climate, is puzzling. A sine qua non of geo-engineering is that we need models to be able to predict what is likely to happen."
Saturday, November 22, 2008
Economics of electric vehicles
While the electrically powered Tesla Roadster is a toy for the rich, at over $100,000, the Chevrolet and Toyota gasoline-electricity hybrids expected in 2010 aim at bigger U.S. markets for electric vehicles. Like the Tesla, they will initially appeal to enthusiasts drawn by personal attitudes. To reach substantial volumes they must compete on conventional grounds, including economics. With few performance measurements and little 21st-century sales experience for electric vehicles, one can only estimate.
We can compare forthcoming electrically powered vehicles with efficient gasoline-powered vehicles from popular makes, including the conventional Honda Civic, Toyota Corolla and Chevrolet Aveo. EPA average efficiency ratings for the 2009 models of these vehicles are 29-31 mpg.[1] The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2]
Energy costs depend on prices. U.S. residential electricity prices vary widely by geographic region but do not vary as much over time.[3] In recent years residential retail electricity rates per kWh have been as low as $.08 in some mountain states but have reached over $.20 in some northeastern states. For 12,000 miles, electric vehicle efficiency of 3.1 mi/kWh, and a range of prices per kWh, annual energy costs for electricity are:
/kWh /yr
0.08 $310
0.12 $465
0.16 $619
0.20 $774
U.S. gasoline prices do not vary as much by region but have seen large price changes over time.[4] During the past five years average U.S. regional prices per gallon regular ranged from $1.40 to $4.60. For 12,000 miles, gasoline vehicle efficiency of 30 mpg, and a range of prices per gallon, annual energy costs for gasoline are:
/gal /yr
1.50 .$600
2.50 $1000
3.50 $1400
4.50 $1800
Whether or not one saves on energy costs with an electric vehicle, and how much, depends on location, on trends in petroleum prices and, for gasoline-electricity hybrids, on what fraction of use is powered by externally generated electricity. In an unfavorable case, with electricity above $.15 per kWh and gasoline at $1.50 per gallon, electricity is more expensive. In a mid-range case, with electricity as $.11 per kWh and gasoline at $2.20 per gallon, for 12,000 miles per year an electrically powered vehicle operating at 3.1 mi/kWh will save about $450 per year over a gasoline powered vehicle operating at 30 mpg. At those energy prices, the highly efficient Toyota Prius gasoline hybrid, with current EPA ratings of 45 to 48 mpg,[1] saves about $570 per year as compared to popular, conventional vehicles.
The balances can change when comparing external electricity costs and gasoline costs in a high-efficiency, gasoline-electricity hybrid. Owners of such vehicles will be able to select the lower-cost source of energy. If such a vehicle achieves an electrical efficiency of 3.1 mi/kWh and gasoline efficiency of 45 mpg, then electricity at $0.11 per kWh will be cost-equivalent to gasoline at $1.60 per gallon.
How much extra will a cost-aware customer pay for an electric vehicle? The announced Chevrolet gasoline-electric hybrid is projected to sell for about $37,000,[5] as compared to efficient gasoline-powered vehicles from popular makes at $12,000 to $15,000.[6] In comparison, the Toyota Prius was introduced in 2000 at about $20,000 [7] and now sells at under $22,000.[6] Where the Toyota Prius has a price premium of about $7,00o to $10,000 over efficient gasoline-powered vehicles from popular makes, the projected Chevrolet vehicle price premium would be from about $22,000 to $25,000.
Depending on circumstances, ten years differences in energy costs, using an electric vehicle, might save from nothing to several thousand dollars. That will be offset by service costs to replace batteries, estimated in the thousands of dollars and with unknown service intervals. Projected pricing of the Chevrolet gasoline-electricity hybrid vehicle is out of line with pricing patterns of gasoline hybrid vehicles and appears unsustainable. After a starting surge of enthusiast buyers, it looks unwise for makers of electric vehicles to expect large-market premiums of more than several thousand dollars per vehicle.
[1] U.S. Environmental Protection Agency, Fuel Economy Guide, 2009, at www.fueleconomy.gov/feg/FEG2009.pdf.
[2] Don Sherman, New York Times, Nov. 13, 2008, at www.nytimes.com/2008/11/16/automobiles/16STICKER.html, ratings converted from published units of kWh per 100 miles.
[3] U.S. Energy Information Administration, Average Retail price of Electricity, at www.eia.doe.gov/cneaf/electricity/epm/table5_6_b.html and www.eia.doe.gov/cneaf/electricity/epm/table5_3.html, omitting Alaska and Hawaii.
[4] U.S. Energy Information Administration, U.S Retail Gasoline Prices, at www.eia.doe.gov/oil_gas/petroleum/data_publications/wrgp/mogas_home_page.html, omitting Alaska and Hawaii
[5] Micheline Maynard, New York Times, Nov. 22, 2008, at www.nytimes.com/2008/11/22/business/22volt.html.
[6] Edmunds New Car Prices, at www.edmunds.com/new/.
[7] Internet Autoguide, 2001 Toyota Prius Lineup, at www.internetautoguide.com/reviews/09-int/2001/toyota/prius/lineup.html.
Some hybrid and electric vehicles use regenerative braking. The gasoline-powered 2009 Prius hybrid achieves EPA ratings of 45 mpg highway and 48 mpg urban.[1] The usual inefficiencies of urban driving are reversed, providing about a 7 percent in-town advantage, primarily because of regenerative braking. The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2] This electric vehicle also achieves an in-town advantage, but only about 3 percent. It appears to have room for some improvement.
We can compare forthcoming electrically powered vehicles with efficient gasoline-powered vehicles from popular makes, including the conventional Honda Civic, Toyota Corolla and Chevrolet Aveo. EPA average efficiency ratings for the 2009 models of these vehicles are 29-31 mpg.[1] The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2]
Energy costs depend on prices. U.S. residential electricity prices vary widely by geographic region but do not vary as much over time.[3] In recent years residential retail electricity rates per kWh have been as low as $.08 in some mountain states but have reached over $.20 in some northeastern states. For 12,000 miles, electric vehicle efficiency of 3.1 mi/kWh, and a range of prices per kWh, annual energy costs for electricity are:
/kWh /yr
0.08 $310
0.12 $465
0.16 $619
0.20 $774
U.S. gasoline prices do not vary as much by region but have seen large price changes over time.[4] During the past five years average U.S. regional prices per gallon regular ranged from $1.40 to $4.60. For 12,000 miles, gasoline vehicle efficiency of 30 mpg, and a range of prices per gallon, annual energy costs for gasoline are:
/gal /yr
1.50 .$600
2.50 $1000
3.50 $1400
4.50 $1800
Whether or not one saves on energy costs with an electric vehicle, and how much, depends on location, on trends in petroleum prices and, for gasoline-electricity hybrids, on what fraction of use is powered by externally generated electricity. In an unfavorable case, with electricity above $.15 per kWh and gasoline at $1.50 per gallon, electricity is more expensive. In a mid-range case, with electricity as $.11 per kWh and gasoline at $2.20 per gallon, for 12,000 miles per year an electrically powered vehicle operating at 3.1 mi/kWh will save about $450 per year over a gasoline powered vehicle operating at 30 mpg. At those energy prices, the highly efficient Toyota Prius gasoline hybrid, with current EPA ratings of 45 to 48 mpg,[1] saves about $570 per year as compared to popular, conventional vehicles.
The balances can change when comparing external electricity costs and gasoline costs in a high-efficiency, gasoline-electricity hybrid. Owners of such vehicles will be able to select the lower-cost source of energy. If such a vehicle achieves an electrical efficiency of 3.1 mi/kWh and gasoline efficiency of 45 mpg, then electricity at $0.11 per kWh will be cost-equivalent to gasoline at $1.60 per gallon.
How much extra will a cost-aware customer pay for an electric vehicle? The announced Chevrolet gasoline-electric hybrid is projected to sell for about $37,000,[5] as compared to efficient gasoline-powered vehicles from popular makes at $12,000 to $15,000.[6] In comparison, the Toyota Prius was introduced in 2000 at about $20,000 [7] and now sells at under $22,000.[6] Where the Toyota Prius has a price premium of about $7,00o to $10,000 over efficient gasoline-powered vehicles from popular makes, the projected Chevrolet vehicle price premium would be from about $22,000 to $25,000.
Depending on circumstances, ten years differences in energy costs, using an electric vehicle, might save from nothing to several thousand dollars. That will be offset by service costs to replace batteries, estimated in the thousands of dollars and with unknown service intervals. Projected pricing of the Chevrolet gasoline-electricity hybrid vehicle is out of line with pricing patterns of gasoline hybrid vehicles and appears unsustainable. After a starting surge of enthusiast buyers, it looks unwise for makers of electric vehicles to expect large-market premiums of more than several thousand dollars per vehicle.
[1] U.S. Environmental Protection Agency, Fuel Economy Guide, 2009, at www.fueleconomy.gov/feg/FEG2009.pdf.
[2] Don Sherman, New York Times, Nov. 13, 2008, at www.nytimes.com/2008/11/16/automobiles/16STICKER.html, ratings converted from published units of kWh per 100 miles.
[3] U.S. Energy Information Administration, Average Retail price of Electricity, at www.eia.doe.gov/cneaf/electricity/epm/table5_6_b.html and www.eia.doe.gov/cneaf/electricity/epm/table5_3.html, omitting Alaska and Hawaii.
[4] U.S. Energy Information Administration, U.S Retail Gasoline Prices, at www.eia.doe.gov/oil_gas/petroleum/data_publications/wrgp/mogas_home_page.html, omitting Alaska and Hawaii
[5] Micheline Maynard, New York Times, Nov. 22, 2008, at www.nytimes.com/2008/11/22/business/22volt.html.
[6] Edmunds New Car Prices, at www.edmunds.com/new/.
[7] Internet Autoguide, 2001 Toyota Prius Lineup, at www.internetautoguide.com/reviews/09-int/2001/toyota/prius/lineup.html.
Some hybrid and electric vehicles use regenerative braking. The gasoline-powered 2009 Prius hybrid achieves EPA ratings of 45 mpg highway and 48 mpg urban.[1] The usual inefficiencies of urban driving are reversed, providing about a 7 percent in-town advantage, primarily because of regenerative braking. The 2009 Tesla Roadster has EPA ratings of 3.0 mi/kWh highway and 3.1 mi/kWh urban.[2] This electric vehicle also achieves an in-town advantage, but only about 3 percent. It appears to have room for some improvement.
Saturday, November 15, 2008
Emissions from using electric vehicles
The U.S. Environmental Protection Agency is currently constructing "miles per gallon" ratings for electric vehicles, in what has become a political rather than a scientific exercise. While we cannot evaluate electric-powered and hybrid-electric vehicle efficiencies and gasoline-powered vehicle efficiencies on exactly the same basis, we can compare carbon dioxide emissions caused in powering them.
The hucksters for electric vehicles encourage people to think of them powered by low-polluting sources. Decades from now they might be. But today, at any given time, the U.S. electrical grid rarely has spare capacity from nuclear, hydro or renewable power. Added demands for electricity, demands that might have been met with some other form of energy, will usually cause coal-fired generators to come on line and run harder. Vehicles that might have been powered by burning gasoline will instead be powered by burning more coal.
The 2009 Tesla Roadster is rated as consuming 28 kWh of external electrical energy to travel 100 miles [1] on an EPA combined-cycle test. The 2010 Chevrolet Volt was measured to consume 8 kWh of internal electrical energy to travel 40 miles [2] under unstated conditions, or 20 kWh per 100 miles. We do not know the added amount of external energy consumed by charging and battery losses.
The U.S. government most recently rated average carbon dioxide emissions for coal-fired power [3] at 2.1 lb/kWh. This yields carbon dioxide emission estimates for the Tesla and for the Volt, when battery powered, as follows:
Tesla 2.1 * 28 / 100 = 0.59 lb/mi carbon dioxide
Volt 2.1 * 20 / 100 = 0.42 lb/mi carbon dioxide, plus losses
The Honda Civic is a popular, efficient, gasoline-powered vehicle. Carbon dioxide emissions have been measured for the 2009 Hybrid model at 109 g/km [4] and for the 2009 conventional Civic at 159 g/km [5] or, in U.S. units:
Civic 1.609 * 159 / 453.6 = 0.56 lb/mi carbon dioxide
Hybrid 1.609 * 109 / 453.6 = 0.39 lb/mi carbon dioxide
Thus, when powered by the U.S. electrical grid, those electric vehicles, while avoiding use of gasoline, result in more carbon dioxide emissions than efficient gasoline-powered vehicles.
[1] Tesla Motors, 2008, at www.teslamotors.com.
[2] General Motors, 2008, at www.gm-volt.com/index.php?s=translates.
[3] U.S. Office of Energy Efficiency and Renewable Energy, Carbon Dioxide Emissions from the Generation of Electric Power, 1999 (Table 1), at www.eia.doe.gov/cneaf/electricity/page/co2_report/co2report.html.
[4] ZerCustoms, 2008, at www.zercustoms.com/news/Honda-Civic-Hybrid-and-British-Airways.html. Also rated by GreenConsumerGuide, 116 g/km, 2008, at http://www.greenconsumerguide.com/honda_feature.php.
[5] WhatGreenCar, 2008, at www.whatgreencar.com/view-car/6674/honda-civic_type_s-1_8_i_VTEC_S.
There's much wonkery around, strong on philosophy. What comes out the smokestacks pays no heed. As demands come to the grid, interconnects respond. Renewables are maxed out by regulation, Nuclear and hydro are almost always saturated, priced for base load. In a few areas combined cycle sometimes has capacity but depends on imported gas. Almost always the low-bid reserve is coal, so what comes out the stacks is more coal smoke. Build millions of windmills, and at some point we see nuclear shutins and wind reserve, maybe in 50 years. The promise of electric vehicles that can be operated now is not to improve the environment but to replace imported fuels.
The hucksters for electric vehicles encourage people to think of them powered by low-polluting sources. Decades from now they might be. But today, at any given time, the U.S. electrical grid rarely has spare capacity from nuclear, hydro or renewable power. Added demands for electricity, demands that might have been met with some other form of energy, will usually cause coal-fired generators to come on line and run harder. Vehicles that might have been powered by burning gasoline will instead be powered by burning more coal.
The 2009 Tesla Roadster is rated as consuming 28 kWh of external electrical energy to travel 100 miles [1] on an EPA combined-cycle test. The 2010 Chevrolet Volt was measured to consume 8 kWh of internal electrical energy to travel 40 miles [2] under unstated conditions, or 20 kWh per 100 miles. We do not know the added amount of external energy consumed by charging and battery losses.
The U.S. government most recently rated average carbon dioxide emissions for coal-fired power [3] at 2.1 lb/kWh. This yields carbon dioxide emission estimates for the Tesla and for the Volt, when battery powered, as follows:
Tesla 2.1 * 28 / 100 = 0.59 lb/mi carbon dioxide
Volt 2.1 * 20 / 100 = 0.42 lb/mi carbon dioxide, plus losses
The Honda Civic is a popular, efficient, gasoline-powered vehicle. Carbon dioxide emissions have been measured for the 2009 Hybrid model at 109 g/km [4] and for the 2009 conventional Civic at 159 g/km [5] or, in U.S. units:
Civic 1.609 * 159 / 453.6 = 0.56 lb/mi carbon dioxide
Hybrid 1.609 * 109 / 453.6 = 0.39 lb/mi carbon dioxide
Thus, when powered by the U.S. electrical grid, those electric vehicles, while avoiding use of gasoline, result in more carbon dioxide emissions than efficient gasoline-powered vehicles.
[1] Tesla Motors, 2008, at www.teslamotors.com.
[2] General Motors, 2008, at www.gm-volt.com/index.php?s=translates.
[3] U.S. Office of Energy Efficiency and Renewable Energy, Carbon Dioxide Emissions from the Generation of Electric Power, 1999 (Table 1), at www.eia.doe.gov/cneaf/electricity/page/co2_report/co2report.html.
[4] ZerCustoms, 2008, at www.zercustoms.com/news/Honda-Civic-Hybrid-and-British-Airways.html. Also rated by GreenConsumerGuide, 116 g/km, 2008, at http://www.greenconsumerguide.com/honda_feature.php.
[5] WhatGreenCar, 2008, at www.whatgreencar.com/view-car/6674/honda-civic_type_s-1_8_i_VTEC_S.
There's much wonkery around, strong on philosophy. What comes out the smokestacks pays no heed. As demands come to the grid, interconnects respond. Renewables are maxed out by regulation, Nuclear and hydro are almost always saturated, priced for base load. In a few areas combined cycle sometimes has capacity but depends on imported gas. Almost always the low-bid reserve is coal, so what comes out the stacks is more coal smoke. Build millions of windmills, and at some point we see nuclear shutins and wind reserve, maybe in 50 years. The promise of electric vehicles that can be operated now is not to improve the environment but to replace imported fuels.
Thursday, August 21, 2008
Beginning a solar power industry
Spurred by California's renewable energy law, on August 14, 2008, Pacific Gas and Electric announced the launch of major photovoltaic facilities.[1] It is contracting with OptiSolar of Hayward, CA, to purchase the power produced by a 550 peak MW thin film, fixed mount photovoltaic plant and with SunPower of San Jose, CA, to purchase the power produced by a 250 peak MW crystalline, single-axis moving mount photovoltaic plant.
Both facilities are planned for sites in San Luis Obispo County, CA. OptiSolar filed a permit application[2] on July 18, 2008, for a Topaz Solar Farms project, describing a 6,200-acre site north of CA 58 (Carrisa Rd.) and spanning Bitterwater Rd. SunPower announced plans for a California Solar Ranch project to be built on a 2240 acre site south of CA 58 and east of Soda Lake Rd.
In 2007 Ausra of Palo Alto, CA, announced plans[3] for a 177 peak MW solar thermal plant to be built for PG&E on 640 acres in San Luis Obispo County, CA, near CA 58 and east of Bitterwater Rd. PG&E also has previous contracts to purchase power from 800 peak MW of solar thermal plants located in California's Mojave desert,[3] while Southern California Edison is building a 500 peak MW solar thermal planT there.[4]
Sites of the San Luis Obispo County facilities are planned in the northern and central Carrizo (or Cariso or Carrisa) Plain, a valley between the Tremblor Range to the northeast and Coast Ranges to the southwest. The southern part of the Carrizo Plain and adjacent parts of the Tremblor and Caliente Ranges are protected as the Carrizo Plain National Monument.[5] Located just north of the unincorporated town of California Valley, CA, the sites are about 150 air miles northwest of Los Angeles.
Carrizo Plain is about 40 miles long and up to 7 miles wide. Land is used mainly for dryland farming; much of the land is unused. Located in the rain shadow of the Coast Ranges, Carrizo Plain often has cloud cover from November through February but is usually sunny in warmer months. It receives on average about 8 inches of annual rainfall. It has experienced major earthquakes. The announced solar facilities will occupy a little over 10 percent of Carrizo Plain.
NASA records for average insolation around the Carrizo Plain solar facility sites are 5.1 KWh/sqm-day,[6] comparable to Scottsdale, AZ, and better than major European facility sites at Serpa, Portugal, and Brandis, Germany. OptiSolar estimates a 23% annual capacity factor for Topaz Solar Farm. SunPower estimates a 25% annual capacity factor for California Valley Solar Ranch. Compared to insolation and performance for the largest current photovoltaic plant at Brandis, the OptiSolar and SunPower estimates appear optimistic by about 15 percent, possibly justified by sparser layouts.
These projects have created a solar power industry in California, in which solar technology companies are constructing and in some cases WILL operatE industrial scale facilities.
[1] David Sneed, PG&E to buy power from 2 solar farms, San Luis Obispo Tribune, August 15, 2008, at www.sanluisobispo.com/news/local/story/439934.html. Matt Nauman, PG&E, SunPower announce major solar deal, San Jose Mercury News, August 15, 2008, at www.mercurynews.com/ci_10204811.
[2] Optisolar, Topaz Solar Farm Application Submittal, July 18, 2008, at www.slocounty.ca.gov/planning/environmental/EnvironmentalNotices/Optisolar-Topaz_Solar_Farm/Optisolar-Topaz_Solar_Farm_Application_Submittal.htm.
[3] Michael Kanellos, PG&E links with Ausra for 177 megawatts of solar thermal power, CNet News, November 5, 2007, at http://news.cnet.com/8301-11128_3-9810199-54.html.
[4] Michael Kanellos, Ausra goes for a gigawatt, CNet News, September 27, 2007, at http://news.cnet.com/8301-10784_3-9786445-7.html.
[5] U.S. Geological Survey, Carrizo Plain National Monument, 2004, at http://3dparks.wr.usgs.gov/carrizo/index2.htm.
[6] U.S. National Aeronautics and Space Administration, Surface meteorology and solar energy database, at http://eosweb.larc.nasa.gov/sse.
Both facilities are planned for sites in San Luis Obispo County, CA. OptiSolar filed a permit application[2] on July 18, 2008, for a Topaz Solar Farms project, describing a 6,200-acre site north of CA 58 (Carrisa Rd.) and spanning Bitterwater Rd. SunPower announced plans for a California Solar Ranch project to be built on a 2240 acre site south of CA 58 and east of Soda Lake Rd.
In 2007 Ausra of Palo Alto, CA, announced plans[3] for a 177 peak MW solar thermal plant to be built for PG&E on 640 acres in San Luis Obispo County, CA, near CA 58 and east of Bitterwater Rd. PG&E also has previous contracts to purchase power from 800 peak MW of solar thermal plants located in California's Mojave desert,[3] while Southern California Edison is building a 500 peak MW solar thermal planT there.[4]
Sites of the San Luis Obispo County facilities are planned in the northern and central Carrizo (or Cariso or Carrisa) Plain, a valley between the Tremblor Range to the northeast and Coast Ranges to the southwest. The southern part of the Carrizo Plain and adjacent parts of the Tremblor and Caliente Ranges are protected as the Carrizo Plain National Monument.[5] Located just north of the unincorporated town of California Valley, CA, the sites are about 150 air miles northwest of Los Angeles.
Carrizo Plain is about 40 miles long and up to 7 miles wide. Land is used mainly for dryland farming; much of the land is unused. Located in the rain shadow of the Coast Ranges, Carrizo Plain often has cloud cover from November through February but is usually sunny in warmer months. It receives on average about 8 inches of annual rainfall. It has experienced major earthquakes. The announced solar facilities will occupy a little over 10 percent of Carrizo Plain.
NASA records for average insolation around the Carrizo Plain solar facility sites are 5.1 KWh/sqm-day,[6] comparable to Scottsdale, AZ, and better than major European facility sites at Serpa, Portugal, and Brandis, Germany. OptiSolar estimates a 23% annual capacity factor for Topaz Solar Farm. SunPower estimates a 25% annual capacity factor for California Valley Solar Ranch. Compared to insolation and performance for the largest current photovoltaic plant at Brandis, the OptiSolar and SunPower estimates appear optimistic by about 15 percent, possibly justified by sparser layouts.
These projects have created a solar power industry in California, in which solar technology companies are constructing and in some cases WILL operatE industrial scale facilities.
[1] David Sneed, PG&E to buy power from 2 solar farms, San Luis Obispo Tribune, August 15, 2008, at www.sanluisobispo.com/news/local/story/439934.html. Matt Nauman, PG&E, SunPower announce major solar deal, San Jose Mercury News, August 15, 2008, at www.mercurynews.com/ci_10204811.
[2] Optisolar, Topaz Solar Farm Application Submittal, July 18, 2008, at www.slocounty.ca.gov/planning/environmental/EnvironmentalNotices/Optisolar-Topaz_Solar_Farm/Optisolar-Topaz_Solar_Farm_Application_Submittal.htm.
[3] Michael Kanellos, PG&E links with Ausra for 177 megawatts of solar thermal power, CNet News, November 5, 2007, at http://news.cnet.com/8301-11128_3-9810199-54.html.
[4] Michael Kanellos, Ausra goes for a gigawatt, CNet News, September 27, 2007, at http://news.cnet.com/8301-10784_3-9786445-7.html.
[5] U.S. Geological Survey, Carrizo Plain National Monument, 2004, at http://3dparks.wr.usgs.gov/carrizo/index2.htm.
[6] U.S. National Aeronautics and Space Administration, Surface meteorology and solar energy database, at http://eosweb.larc.nasa.gov/sse.
Monday, July 14, 2008
Climate of discontent
Enthusiasts for action on climate change may have put the cart so far before the horse that there are no longer any reins and other horse tack connecting them. Worldwide solutions to projected problems carry enormous potential costs, tens to hundreds of trillions of dollars, or years to decades of the total economic output of the United States. Before there can be any sustained commitment approaching such scales, there will have to be general agreement and near total certainty as to benefits and costs. Today there is only limited agreement and great uncertainty. Areas of agreement are recent trends of rising temperatures, rising sea levels and rising concentrations of trace gases in the atmosphere. Uncertainties include distinguishing causes from effects, assessing relative strengths of causes and predicting future effects from human efforts directed at causes.
Key knowledge and projections of climate change are coming from a few hundred people worldwide, who rarely if ever expose details of their work candidly to public view. Most reports rest on hackneyed assumptions, stated or not, that have never been conclusively proven. Only insiders at the private clubs get meaningful access. However, mavericks among them have explained that no model achieves much accuracy in predicting many decades of observations based solely on the profile of the Earth and on physics, chemistry and scalable, validated engineering. Models are tweaked with arbitrary adjustments, parameters determined by statistical inference rather than from physical principles, so that they get the right answers to match observations[1]. Who has the crystal ball to tweak them correctly for future years? An article evaluating several thousand models showed that only 15 years into the future, global temperature projections varied up to nearly 15 degrees Farenheit[2].
That situation does not reflect some kind of "junk science" [3] but rather an endeavor of great complexity, comparable perhaps to understanding the causes of and cures for cancer, and similar in that about 50 years of science has produced partial knowledge and limited success, leaving vast territories yet to be covered. Atmosphere and ocean circulations are dynamic, chaotic and dissipative, with many interacting factors and much potential for novel and unpredictable behavior. After 50 years of science, we are able to predict weather fairly accurately for about two days, but at about two weeks all our supercomputing and automatic monitoring does not improve much over what we can predict from typical weather for a time of year.
Climate, of course, is weather, averaged over years, decades and centuries. On a historic time scale, let alone a geologic scale, our records are spotty and shallow. We have a handful of temperature series extending back a few hundred years, some measurements of atmospheric gases for about a century and a half, and direct if controversial measurements of solar output since 1979. The past thirty years have seen major improvements in the density and sophistication of measurements, but such an amount of time is at best marginal as a baseline for estimating climate. Solar output, a critical factor in climate, can be estimated from longer records of sunspot activity, but the correlations are noisy and imprecise.
Historical records tell about sizable shifts in climate before the Industrial Age, such as the Medieval Warm Period, a shift in annual temperatures up to 2 degrees Farenheit found in Europe from about 800 to 1,300 CE. We have little to explain some such events except unmeasured changes in solar output. Modern measurements of the geologic record over the last several million years tell about more dramatic episodes of warming and cooling, shifting annual temperatures by more than 20 degrees Farenheit, with some substantial changes taking place in less than 100 years. Persistence of some patterns over centuries and millenia, recurrences at intervals around 40,000 and 100,000 years, and abrupt spikes and dips make explanations appear unlikely other than orbital patterns and solar output changes, stimulating changes in atmosphere and ocean circulation. In some warming episodes, atmospheric carbon dioxide concentrations lag rather than lead temperatures, thus appearing as effects rather than causes.
Many current climate models fail to consider records older than about 100 years, but useful records extend to three times that age. Among other things, they indicate warming trends since the early 1700s, while large effects of the Industrial Age on atmospheric gases emerge in the mid-1800s. Adjustment factors of current climate models may be tuning them to correlations between temperatures and atmospheric gases that would not be found in records over longer periods. Atmospheric emissions from power plants, motor vehicles and agriculture exploded since the 1940s, yet although it has been shown that the average exchange time for carbon dioxide between atmosphere and ocean is about ten years, records of temperatures and sea levels do not show closely correlated accelerations of most trends.
Experts at climate modeling seem increasingly focused on inside pursuits, such as cross-comparisons and increased areal and time densities. However, development of the science shows greatest improvements from understanding new factors, such as cloud cover, aerosols and particulates. Trustworthy knowledge is more likely to emerge from thorough understanding of systematics and interactions than from refinements of calculations. Unless we can obtain robust, accurate models grounded on principles of physics, chemistry and engineering, few people will trust the models with their lives and fortunes. Critical issues are whether, how much and how rapidly climate change could now be affected by human efforts and what levels of efforts may be required. If it were to turn out that rises in sea levels had become practically unstoppable and irreversible, then we might better spend resources reinforcing or relocating coastal communities rather than rushing to build photovoltaic panels.
[1] A. Arakawa and W.H. Schubert, Interaction of a cumulus cloud ensemble with the large-scale environment, part 1, Journal of the Atmospheric Sciences 31(4):674-701, 1974. A.H. Van Tuyl, Physical initialization with the Arakawa-Schubert scheme in the Navy's operational global forecast model, Meteorology and Atmospheric Physics 60(1):47-55, 1996. T.M. Wagner and H-F. Graf, A spectral convection parameterisation with a dynamical Arakawa-Schubert quasi-equilibrium closure, Geophysical Research Abstracts 10, EGU2008-A-12443, 2008.
[2] D.A. Stainforth, et al., Uncertainty in predictions of the climate response to rising levels of greenhouse gases, Nature 433(1):403-406, January, 2005.
[3] Steven Milloy, ed., junkscience.com. Martin Durkin, dir., “The Great Global Warming Swindle,” British television film, March 8, 2007, revised edition available as DVD. Lars Mortensen, dir., "Doomsday Called Off," Danish television film, 2004, first shown in Canada, November 27, 2005. Hilary Lawson, dir., "The Greenhouse Conspiracy," British television film, August 12, 1990.
Key knowledge and projections of climate change are coming from a few hundred people worldwide, who rarely if ever expose details of their work candidly to public view. Most reports rest on hackneyed assumptions, stated or not, that have never been conclusively proven. Only insiders at the private clubs get meaningful access. However, mavericks among them have explained that no model achieves much accuracy in predicting many decades of observations based solely on the profile of the Earth and on physics, chemistry and scalable, validated engineering. Models are tweaked with arbitrary adjustments, parameters determined by statistical inference rather than from physical principles, so that they get the right answers to match observations[1]. Who has the crystal ball to tweak them correctly for future years? An article evaluating several thousand models showed that only 15 years into the future, global temperature projections varied up to nearly 15 degrees Farenheit[2].
That situation does not reflect some kind of "junk science" [3] but rather an endeavor of great complexity, comparable perhaps to understanding the causes of and cures for cancer, and similar in that about 50 years of science has produced partial knowledge and limited success, leaving vast territories yet to be covered. Atmosphere and ocean circulations are dynamic, chaotic and dissipative, with many interacting factors and much potential for novel and unpredictable behavior. After 50 years of science, we are able to predict weather fairly accurately for about two days, but at about two weeks all our supercomputing and automatic monitoring does not improve much over what we can predict from typical weather for a time of year.
Climate, of course, is weather, averaged over years, decades and centuries. On a historic time scale, let alone a geologic scale, our records are spotty and shallow. We have a handful of temperature series extending back a few hundred years, some measurements of atmospheric gases for about a century and a half, and direct if controversial measurements of solar output since 1979. The past thirty years have seen major improvements in the density and sophistication of measurements, but such an amount of time is at best marginal as a baseline for estimating climate. Solar output, a critical factor in climate, can be estimated from longer records of sunspot activity, but the correlations are noisy and imprecise.
Historical records tell about sizable shifts in climate before the Industrial Age, such as the Medieval Warm Period, a shift in annual temperatures up to 2 degrees Farenheit found in Europe from about 800 to 1,300 CE. We have little to explain some such events except unmeasured changes in solar output. Modern measurements of the geologic record over the last several million years tell about more dramatic episodes of warming and cooling, shifting annual temperatures by more than 20 degrees Farenheit, with some substantial changes taking place in less than 100 years. Persistence of some patterns over centuries and millenia, recurrences at intervals around 40,000 and 100,000 years, and abrupt spikes and dips make explanations appear unlikely other than orbital patterns and solar output changes, stimulating changes in atmosphere and ocean circulation. In some warming episodes, atmospheric carbon dioxide concentrations lag rather than lead temperatures, thus appearing as effects rather than causes.
Many current climate models fail to consider records older than about 100 years, but useful records extend to three times that age. Among other things, they indicate warming trends since the early 1700s, while large effects of the Industrial Age on atmospheric gases emerge in the mid-1800s. Adjustment factors of current climate models may be tuning them to correlations between temperatures and atmospheric gases that would not be found in records over longer periods. Atmospheric emissions from power plants, motor vehicles and agriculture exploded since the 1940s, yet although it has been shown that the average exchange time for carbon dioxide between atmosphere and ocean is about ten years, records of temperatures and sea levels do not show closely correlated accelerations of most trends.
Experts at climate modeling seem increasingly focused on inside pursuits, such as cross-comparisons and increased areal and time densities. However, development of the science shows greatest improvements from understanding new factors, such as cloud cover, aerosols and particulates. Trustworthy knowledge is more likely to emerge from thorough understanding of systematics and interactions than from refinements of calculations. Unless we can obtain robust, accurate models grounded on principles of physics, chemistry and engineering, few people will trust the models with their lives and fortunes. Critical issues are whether, how much and how rapidly climate change could now be affected by human efforts and what levels of efforts may be required. If it were to turn out that rises in sea levels had become practically unstoppable and irreversible, then we might better spend resources reinforcing or relocating coastal communities rather than rushing to build photovoltaic panels.
[1] A. Arakawa and W.H. Schubert, Interaction of a cumulus cloud ensemble with the large-scale environment, part 1, Journal of the Atmospheric Sciences 31(4):674-701, 1974. A.H. Van Tuyl, Physical initialization with the Arakawa-Schubert scheme in the Navy's operational global forecast model, Meteorology and Atmospheric Physics 60(1):47-55, 1996. T.M. Wagner and H-F. Graf, A spectral convection parameterisation with a dynamical Arakawa-Schubert quasi-equilibrium closure, Geophysical Research Abstracts 10, EGU2008-A-12443, 2008.
[2] D.A. Stainforth, et al., Uncertainty in predictions of the climate response to rising levels of greenhouse gases, Nature 433(1):403-406, January, 2005.
[3] Steven Milloy, ed., junkscience.com. Martin Durkin, dir., “The Great Global Warming Swindle,” British television film, March 8, 2007, revised edition available as DVD. Lars Mortensen, dir., "Doomsday Called Off," Danish television film, 2004, first shown in Canada, November 27, 2005. Hilary Lawson, dir., "The Greenhouse Conspiracy," British television film, August 12, 1990.
Saturday, July 12, 2008
A game of regulation with jokers in the deck
When courts call, the EPA folds. Most recently the call was for the U.S. Environmental Protection Agency, representing the Administration in office from 2001 to 2009, to justify its Clean Air Interstate Rule, which was under development from 2001 through 2003. The EPA lost everything. Its entire rulemaking action was canned, and the agency was told to start over, in a decision from the Third Circuit Court of Appeals, North Carolina v. Environmental Protection Agency, No. 05-1244, July 11, 2008.
From its beginnings, CAIR, the Clean Air Interstate Rule, was a scam purporting to regulate stringently the air pollution emitted by power-plants that flows from state to state, while actually offering power-plant operators a low cost, if not a free, ride. Emissions were to be regulated only on a regional basis, using a trading system through which power-plant operators could buy the rights to pollute. Pollution limits, on the other hand, were to be regulated on a local basis, requiring potentially draconian measures by cities and counties found out of compliance, but giving them no powers to stop emissions coming from somewhere else. Enforcement of local limits was scheduled for 2010, one convenient year after the Administration responsible for the system had left office, dumping inevitable problems onto its successor.
The tip-off to a scam was the EPA focus in CAIR on “highly cost-effective” emission controls. The agency was set up to regulate pollution, not industrial finance. It is charged by law to insure that power-plants use the "Best Available Control Technology" to reduce emissions when new plants are built or old ones are significantly renovated. As the Court of Appeals stated, "Because EPA evaluated whether its proposed emissions reductions were 'highly cost effective' at the regionwide level, assuming a trading program, it never measured the 'significant contribution' from sources within an individual state to downwind nonattainment areas." The EPA did not document the amounts of air pollution travelling from power-plants to local areas and had no plans to monitor them.
The power industry is now crying wolf and apparently influenced the New York Times to howl along. In an article published July 12, 2008, power industry representatives were quoted condemning the court decision, one spokesman saying, "one of the things we crave is certainty, and this goes in the other direction." The EPA Administrator during development of CAIR was a former governor who, according to the Times, had been criticized "in the name of attracting businesses" for having "compromised water pollution protections and cut spending for state offices that prosecute environmental abuses by industry." That was hardly enough, and the agency was routinely told what to do and sometimes how to do it. Evidence for its continuing manipulation can be read in an EPA proposal of July 11, 2008, to investigate regulating carbon dioxide, as the agency was instructed to do by a Supreme Court decision in Massachusetts v. Environmental Protection Agency, 549 U.S. 497, April 2, 2007. The recent announcement starts by exhibiting a letter to the current EPA Administrator from an appointee responsible for Regulatory Affairs in the President's Office of Management and Budget, saying what to do and how to do it.
But now the hands have been played, the game is almost over, and the jokers are leaving. The problems that CAIR would supposedly address are still with us, of course. Were we to take care in regulating pollution rather than CAIR, we would account not only for emissions but also for power flowing from state to state. Southern California, for example, is notorious for drawing heavily on coal-fired power-plants in the Southwest, thus enjoying "clean" power while sending most of the pollution somewhere else. One possible approach, in somewhat the spirit of the discredited CAIR, is to charge Southern California electricity consumers directly and explicitly for pollution emitted by their practices.
From its beginnings, CAIR, the Clean Air Interstate Rule, was a scam purporting to regulate stringently the air pollution emitted by power-plants that flows from state to state, while actually offering power-plant operators a low cost, if not a free, ride. Emissions were to be regulated only on a regional basis, using a trading system through which power-plant operators could buy the rights to pollute. Pollution limits, on the other hand, were to be regulated on a local basis, requiring potentially draconian measures by cities and counties found out of compliance, but giving them no powers to stop emissions coming from somewhere else. Enforcement of local limits was scheduled for 2010, one convenient year after the Administration responsible for the system had left office, dumping inevitable problems onto its successor.
The tip-off to a scam was the EPA focus in CAIR on “highly cost-effective” emission controls. The agency was set up to regulate pollution, not industrial finance. It is charged by law to insure that power-plants use the "Best Available Control Technology" to reduce emissions when new plants are built or old ones are significantly renovated. As the Court of Appeals stated, "Because EPA evaluated whether its proposed emissions reductions were 'highly cost effective' at the regionwide level, assuming a trading program, it never measured the 'significant contribution' from sources within an individual state to downwind nonattainment areas." The EPA did not document the amounts of air pollution travelling from power-plants to local areas and had no plans to monitor them.
The power industry is now crying wolf and apparently influenced the New York Times to howl along. In an article published July 12, 2008, power industry representatives were quoted condemning the court decision, one spokesman saying, "one of the things we crave is certainty, and this goes in the other direction." The EPA Administrator during development of CAIR was a former governor who, according to the Times, had been criticized "in the name of attracting businesses" for having "compromised water pollution protections and cut spending for state offices that prosecute environmental abuses by industry." That was hardly enough, and the agency was routinely told what to do and sometimes how to do it. Evidence for its continuing manipulation can be read in an EPA proposal of July 11, 2008, to investigate regulating carbon dioxide, as the agency was instructed to do by a Supreme Court decision in Massachusetts v. Environmental Protection Agency, 549 U.S. 497, April 2, 2007. The recent announcement starts by exhibiting a letter to the current EPA Administrator from an appointee responsible for Regulatory Affairs in the President's Office of Management and Budget, saying what to do and how to do it.
But now the hands have been played, the game is almost over, and the jokers are leaving. The problems that CAIR would supposedly address are still with us, of course. Were we to take care in regulating pollution rather than CAIR, we would account not only for emissions but also for power flowing from state to state. Southern California, for example, is notorious for drawing heavily on coal-fired power-plants in the Southwest, thus enjoying "clean" power while sending most of the pollution somewhere else. One possible approach, in somewhat the spirit of the discredited CAIR, is to charge Southern California electricity consumers directly and explicitly for pollution emitted by their practices.
Tangle of air pollution regulations affecting energy
Federal court decisions from 2005 through 2008, unlike some from earlier years, indicate that without persuasive evidence attempts to weaken, subvert or avoid environmental regulations affecting energy production will be overturned and indicate that enforcement of regulations will be upheld.
Four Court of Appeals decisions and two Supreme Court decisions changed the landscape. An Administration seeking to obstruct regulations had resorted to wordsmithing and legalisms. A southern, coal-fired power-plant operator seeking to avoid regulations had persuaded southern courts to do the same.
The power-plant operator's case was sent back for enforcement. The Environmental Protection Agency was instructed to investigate regulating carbon dioxide. The attempts to weaken or subvert air pollution regulations were rejected, striking out seven actions of the U.S. Environmental Protection Agency from 2002 through 2005 and restoring earlier regulations.
(1)
New York, et al., v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 02-1387, June 24, 2005, 413 F.3d 3
"In 1977, Congress amended the Clean Air Act (CAA or 'the Act') to strengthen the safeguards"
"major stationary sources undertaking modifications...process known as “New Source Review” (NSR)"
"petitioners now challenge this 2002 [NSR] rule, which departs sharply from prior rules"
"EPA erred in promulgating the Clean Unit applicability test, which measures emissions increases by looking to whether 'emissions limitations' have changed"
"Congress directed the agency to measure emissions increases in terms of changes in actual emissions"
"EPA also erred in exempting from NSR certain Pollution Control Projects (PCPs) that decrease emissions of some pollutants but cause collateral increases of other"
"we vacate the provisions...regarding the Clean Unit applicability test and Pollution Control Projects"
(2)
New York, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 03-1380, March 17, 2006, 443 F.3d 880
"Equipment Replacement Provision (“ERP”)...amends the Routine Maintenance, Repair, and Replacement Exclusion (“RMRR”) from NSR requirements"
"Under section 111(a)(4) of the Clean Air Act, sources that undergo 'any physical change' that increases emissions are required to undergo the NSR permitting process."
"ERP would allow sources to avoid NSR when replacing equipment notwithstanding a resulting increase in emissions"
"because it violates the Act, we vacate the ERP"
(3)
Massachusetts v. Environmental Protection Agency
Supreme Court of the United States
No. 05–1120, April 2, 2007, 549 U.S. 497
"organizations petitioned the Environmental Protection Agency (EPA) to begin regulating...carbon dioxide"
"EPA ultimately denied the petition, reasoning that (1) the Act does not authorize it"
"Court of Appeals...judges agreed that the EPA Administrator properly exercised his discretion"
"EPA has offered no reasoned explanation...Its action was therefore 'arbitrary, capricious"
"The judgment of the Court of Appeals is reversed"
(4)
Environmental Defense, et al., v. Duke Energy Corp., et al.
Supreme Court of the United States
No. 05-848, April 2, 2007, 549 U.S. 561
"Duke Energy Corporation replaced or redesigned...coal-fired electric generating units"
"the United States filed this enforcement action"
"the District Court entered summary judgment for Duke on all PSD claims...The Fourth Circuit affirmed"
"The Fourth Circuit’s reading of the PSD regulations amounted to the invalidation of the PSD regulations"
"The judgment of the Court of Appeals is vacated"
(5)
New Jersey, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1097, February 8, 2008
"petitions for review of...rules regarding the emission...from electric...generating units (EGUs)"
"first rule [Delisting rule] removes coal- and oil-fired EGUs from the...sources...regulated under section 112 of the Clean Air Act"
"second rule [CAMR] establishes total mercury emissions limits for States and certain tribal areas"
"Clean Air Mercury Rule [CAMR]"
"Petitioners contend that the Delisting Rule is contrary to the plain text and structure of section 112"
"in section 112(c)(9)...Congress limit[ed] EPA’s discretion to remove sources...from the section 112(c)(1)"
"EPA can point to no persuasive evidence suggesting that section 112(c)(9)’s plain text is ambiguous"
"Because coal-fired EGUs are listed sources under section 112, regulation of existing coalfired EGUs’ mercury emissions under section 111 is prohibited"
"the court grants the petitions and vacates both rules"
(6)
North Carolina v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1244, July 11, 2008
"Petitioner North Carolina challenges CAIR’s programs for pollution-trading"
"Clean Air Interstate Rule [CAIR]"
"North Carolina contests the lack of reasonable measures in CAIR to assure that upwind states will abate their unlawful emissions."
"EPA...never measured the 'significant contribution'...to downwind nonattainment areas."
"No amount of tinkering...will transform CAIR, as written, into an acceptable rule"
"we vacate CAIR and its associated FIP [federal implementation plan]"
(7) [added Aug. 23, 2008]
Sierra Club v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 04-1243, August 19, 2008
slip: http://pacer.cadc.uscourts.gov/common/opinions/200808/04-1243-1133914.pdf
"Clean Air Act emission limits...are scattered throughout rules promulgated by states or EPA"
"1990 Amendments...created a national permit program"
"Title V gives EPA...the duty to identify its 'minimum elements'"
"in 1997...the agency took the position that...permitting authorities could supplement...requirements"
"In 2002, EPA proposed a regulation codifying this view of §70.6(c)(1)"
"an industry group challenged the...rule...Util. Air Regulatory Group v. EPA, No. 02-1290
"the agency settled the litigation by agreeing to...a...rule that would prohibit...supplementing"
"Several environmental groups challenge the 2006 rule...arguing that they violate the Clean Air Act"
"We hold...that Title V of the Act unambiguously precludes EPA’s interpretation in the 2006 rule"
"Accordingly, we vacate the 2006 rule"
Four Court of Appeals decisions and two Supreme Court decisions changed the landscape. An Administration seeking to obstruct regulations had resorted to wordsmithing and legalisms. A southern, coal-fired power-plant operator seeking to avoid regulations had persuaded southern courts to do the same.
The power-plant operator's case was sent back for enforcement. The Environmental Protection Agency was instructed to investigate regulating carbon dioxide. The attempts to weaken or subvert air pollution regulations were rejected, striking out seven actions of the U.S. Environmental Protection Agency from 2002 through 2005 and restoring earlier regulations.
(1)
New York, et al., v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 02-1387, June 24, 2005, 413 F.3d 3
"In 1977, Congress amended the Clean Air Act (CAA or 'the Act') to strengthen the safeguards"
"major stationary sources undertaking modifications...process known as “New Source Review” (NSR)"
"petitioners now challenge this 2002 [NSR] rule, which departs sharply from prior rules"
"EPA erred in promulgating the Clean Unit applicability test, which measures emissions increases by looking to whether 'emissions limitations' have changed"
"Congress directed the agency to measure emissions increases in terms of changes in actual emissions"
"EPA also erred in exempting from NSR certain Pollution Control Projects (PCPs) that decrease emissions of some pollutants but cause collateral increases of other"
"we vacate the provisions...regarding the Clean Unit applicability test and Pollution Control Projects"
(2)
New York, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 03-1380, March 17, 2006, 443 F.3d 880
"Equipment Replacement Provision (“ERP”)...amends the Routine Maintenance, Repair, and Replacement Exclusion (“RMRR”) from NSR requirements"
"Under section 111(a)(4) of the Clean Air Act, sources that undergo 'any physical change' that increases emissions are required to undergo the NSR permitting process."
"ERP would allow sources to avoid NSR when replacing equipment notwithstanding a resulting increase in emissions"
"because it violates the Act, we vacate the ERP"
(3)
Massachusetts v. Environmental Protection Agency
Supreme Court of the United States
No. 05–1120, April 2, 2007, 549 U.S. 497
"organizations petitioned the Environmental Protection Agency (EPA) to begin regulating...carbon dioxide"
"EPA ultimately denied the petition, reasoning that (1) the Act does not authorize it"
"Court of Appeals...judges agreed that the EPA Administrator properly exercised his discretion"
"EPA has offered no reasoned explanation...Its action was therefore 'arbitrary, capricious"
"The judgment of the Court of Appeals is reversed"
(4)
Environmental Defense, et al., v. Duke Energy Corp., et al.
Supreme Court of the United States
No. 05-848, April 2, 2007, 549 U.S. 561
"Duke Energy Corporation replaced or redesigned...coal-fired electric generating units"
"the United States filed this enforcement action"
"the District Court entered summary judgment for Duke on all PSD claims...The Fourth Circuit affirmed"
"The Fourth Circuit’s reading of the PSD regulations amounted to the invalidation of the PSD regulations"
"The judgment of the Court of Appeals is vacated"
(5)
New Jersey, et al. v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1097, February 8, 2008
"petitions for review of...rules regarding the emission...from electric...generating units (EGUs)"
"first rule [Delisting rule] removes coal- and oil-fired EGUs from the...sources...regulated under section 112 of the Clean Air Act"
"second rule [CAMR] establishes total mercury emissions limits for States and certain tribal areas"
"Clean Air Mercury Rule [CAMR]"
"Petitioners contend that the Delisting Rule is contrary to the plain text and structure of section 112"
"in section 112(c)(9)...Congress limit[ed] EPA’s discretion to remove sources...from the section 112(c)(1)"
"EPA can point to no persuasive evidence suggesting that section 112(c)(9)’s plain text is ambiguous"
"Because coal-fired EGUs are listed sources under section 112, regulation of existing coalfired EGUs’ mercury emissions under section 111 is prohibited"
"the court grants the petitions and vacates both rules"
(6)
North Carolina v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 05-1244, July 11, 2008
"Petitioner North Carolina challenges CAIR’s programs for pollution-trading"
"Clean Air Interstate Rule [CAIR]"
"North Carolina contests the lack of reasonable measures in CAIR to assure that upwind states will abate their unlawful emissions."
"EPA...never measured the 'significant contribution'...to downwind nonattainment areas."
"No amount of tinkering...will transform CAIR, as written, into an acceptable rule"
"we vacate CAIR and its associated FIP [federal implementation plan]"
(7) [added Aug. 23, 2008]
Sierra Club v. Environmental Protection Agency
Court of Appeals for the District of Columbia [3rd] Circuit
No. 04-1243, August 19, 2008
slip: http://pacer.cadc.uscourts.gov/common/opinions/200808/04-1243-1133914.pdf
"Clean Air Act emission limits...are scattered throughout rules promulgated by states or EPA"
"1990 Amendments...created a national permit program"
"Title V gives EPA...the duty to identify its 'minimum elements'"
"in 1997...the agency took the position that...permitting authorities could supplement...requirements"
"In 2002, EPA proposed a regulation codifying this view of §70.6(c)(1)"
"an industry group challenged the...rule...Util. Air Regulatory Group v. EPA, No. 02-1290
"the agency settled the litigation by agreeing to...a...rule that would prohibit...supplementing"
"Several environmental groups challenge the 2006 rule...arguing that they violate the Clean Air Act"
"We hold...that Title V of the Act unambiguously precludes EPA’s interpretation in the 2006 rule"
"Accordingly, we vacate the 2006 rule"
Wednesday, January 2, 2008
When is a hybrid not?
When it's a Chevy. Here are specifications for the 2008 Chevrolet Malibu and its main competition, the 2008 Toyota Camry, both vehicles available in conventional as well as hybrid versions:
The single-mode technology of the Malibu Hybrid provides just a marginal improvement in efficiency. At $3 per gallon for gasoline, driving 15,000 miles per year, payback of the cost difference over the conventional base model takes more than 20 years. Chevrolet is trying to compete with Toyota on car prices, offering inferior technology. The last twenty years of automotive history indicates that the strategy will fail. Toyota shows how to get almost a real 35 mpg vehicle, not by 2020 but this year, at a reasonable price and without giving up comfort and performance.
The single-mode technology of the Malibu Hybrid provides just a marginal improvement in efficiency. At $3 per gallon for gasoline, driving 15,000 miles per year, payback of the cost difference over the conventional base model takes more than 20 years. Chevrolet is trying to compete with Toyota on car prices, offering inferior technology. The last twenty years of automotive history indicates that the strategy will fail. Toyota shows how to get almost a real 35 mpg vehicle, not by 2020 but this year, at a reasonable price and without giving up comfort and performance.
Thursday, December 20, 2007
Hucksters for a solar panel derby
"Solar panels at lower-than-usual cost," trumpets the New York Times headline for an article from a Business staffer rarely known to let nasty details mess up a great story [1]. "Less than $1 a watt," he writes, when "a new coal plant costs about $2.1 a watt." Glory! It must be truly a new age.
Well. Maybe. One of these days. First you have to pay for the space, next mount and wire the panels, then invert the power to AC and adapt it to the electrical grid. That will more than double the price.
Finally you have to discount for capacity factor, the ratio of average AC power to peak DC power, at which "$1 a watt" was quoted. Most places outside Times Sq., the sun doesn't shine high in a cloudless sky all the time.
In the United States, practical capacity factors range from about 20 percent, for costly sun-tracking mounts in Arizona deserts, to about 10 percent, for cheaper stationary mounts in northern New England.
Once nasty details are factored in, costs for an average AC watt available to users are at least ten times costs for a peak DC watt from an unmounted panel.
Oh my. Now a solar power-plant costs at least five-fold what a coal-fired plant does, and maybe more than double that. Houston, we have a problem.
But hurry! Get yours now. Federal tax credits through December 31, 2007. Seems there was a dust-up between Pres. and Congress over an Energy Efficiency bill. So after that, gone with the wind (lost its credits, too).
Of course so-called "news" articles are often more views than news, when they are not just press releases and puff pieces. Staff are expected to follow local party lines. It's partly arrogance, but partly economics. The cookie-cutter views are cheaper than news, while puff pieces cost little and press releases hardly anything. No tedious, expensive research, background reviews, fact checks or rewrites; just type and go.
Party lines for 2007 were mostly that energy alternatives are a Good Thing, so items making them look Hard or Expensive would rarely make the cut. For example, several reporters for big newspapers who wrote about the 2007 energy efficiency bill [2] were well aware that games were played with the bill, that lies were told about its effects, and that many loopholes were left in it. Only one, John Donnelly writing for the Boston Globe December 15, explained some of the story when it mattered [3][4].
Kudos to Donnelly and his editor, but cautions for the rest of us. Arrogance and laziness in reporting means we turn to many sources to search out facts and will never simply trust any report.
[1] John Markoff, Start-up sells solar panels at lower-than-usual cost, New York Times, December 18, 2007, available at www.nytimes.com/2007/12/18/technology/18solar.html.
[2] Energy Independence and Security Act of 2007, Public Law 110-140, introduced as H.R. 6 and other bills, enacted December 19, 2007. See http://thomas.loc.gov/cgi-bin/bdquery/z?d110:HR00006:@@@X for the tangle of legislative history and www.rules.house.gov/110/text/110_houseamnd_hr6.pdf for the final text.
[3] John Donnelly, Energy bill targets fuel consumption climb, Boston Globe, December 15, 2007, available at www.boston.com/cars/news/articles/2007/12/15/energy_bill_targets_fuel_consumption_climb/. See a typical follow-up: Martin LaMonica, New energy act gets green light, CNET News, December 19, 2007, available at www.news.com/FAQ-New-Energy-Act-gets-green-light/2100-13836_3-6223567.html -- one of many sure to explain the law once it is a done deal and no longer in play.
[4] Appearing two days after enactment of Public Law 110-140, a Los Angeles Times article explains one of the many games played with the bill: Janet Wilson, EPA chief is said to have ignored staff, Los Angeles Times, December 21, 2007, available at www.latimes.com/news/printedition/asection/la-me-epa21dec21,1,1021228.story.
Well. Maybe. One of these days. First you have to pay for the space, next mount and wire the panels, then invert the power to AC and adapt it to the electrical grid. That will more than double the price.
Finally you have to discount for capacity factor, the ratio of average AC power to peak DC power, at which "$1 a watt" was quoted. Most places outside Times Sq., the sun doesn't shine high in a cloudless sky all the time.
In the United States, practical capacity factors range from about 20 percent, for costly sun-tracking mounts in Arizona deserts, to about 10 percent, for cheaper stationary mounts in northern New England.
Once nasty details are factored in, costs for an average AC watt available to users are at least ten times costs for a peak DC watt from an unmounted panel.
Oh my. Now a solar power-plant costs at least five-fold what a coal-fired plant does, and maybe more than double that. Houston, we have a problem.
But hurry! Get yours now. Federal tax credits through December 31, 2007. Seems there was a dust-up between Pres. and Congress over an Energy Efficiency bill. So after that, gone with the wind (lost its credits, too).
Of course so-called "news" articles are often more views than news, when they are not just press releases and puff pieces. Staff are expected to follow local party lines. It's partly arrogance, but partly economics. The cookie-cutter views are cheaper than news, while puff pieces cost little and press releases hardly anything. No tedious, expensive research, background reviews, fact checks or rewrites; just type and go.
Party lines for 2007 were mostly that energy alternatives are a Good Thing, so items making them look Hard or Expensive would rarely make the cut. For example, several reporters for big newspapers who wrote about the 2007 energy efficiency bill [2] were well aware that games were played with the bill, that lies were told about its effects, and that many loopholes were left in it. Only one, John Donnelly writing for the Boston Globe December 15, explained some of the story when it mattered [3][4].
Kudos to Donnelly and his editor, but cautions for the rest of us. Arrogance and laziness in reporting means we turn to many sources to search out facts and will never simply trust any report.
[1] John Markoff, Start-up sells solar panels at lower-than-usual cost, New York Times, December 18, 2007, available at www.nytimes.com/2007/12/18/technology/18solar.html.
[2] Energy Independence and Security Act of 2007, Public Law 110-140, introduced as H.R. 6 and other bills, enacted December 19, 2007. See http://thomas.loc.gov/cgi-bin/bdquery/z?d110:HR00006:@@@X for the tangle of legislative history and www.rules.house.gov/110/text/110_houseamnd_hr6.pdf for the final text.
[3] John Donnelly, Energy bill targets fuel consumption climb, Boston Globe, December 15, 2007, available at www.boston.com/cars/news/articles/2007/12/15/energy_bill_targets_fuel_consumption_climb/. See a typical follow-up: Martin LaMonica, New energy act gets green light, CNET News, December 19, 2007, available at www.news.com/FAQ-New-Energy-Act-gets-green-light/2100-13836_3-6223567.html -- one of many sure to explain the law once it is a done deal and no longer in play.
[4] Appearing two days after enactment of Public Law 110-140, a Los Angeles Times article explains one of the many games played with the bill: Janet Wilson, EPA chief is said to have ignored staff, Los Angeles Times, December 21, 2007, available at www.latimes.com/news/printedition/asection/la-me-epa21dec21,1,1021228.story.
Subscribe to:
Posts (Atom)