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Intervener Testimony

regarding PUC IRP in which they propose a Natural Gas fired generator at Carty, Oregon

We chose to intervene in this process to make sure these points got addressed:


  1. Pollution is a reason a plant built today will be a stranded asset in a few years:
    1. Natural Gas is evil because of upstream emissions
    2. The currently externalized cost of carbon as both CO2 and the CO2e from Methane will not stay externalized.
    3. Oregon industry is encouraged to anticipate internalized costs.
  2. Economics is a reason a Natural Gas plant built today will be shut down before 2030. Certainly before 2050.
    1. Exponential change will make green alternative cheaper
      1. Moore's Law
      2. Cost of Wind and Photo-Voltaic Solar (PV) approximately follow Moore's law
      3. Cost of Battery Storage decreasing at 16% per year from peaker parity.
    2. Natural Gas
      1. Costs more than either Wind or Solar now, and
      2. Will get more expensive over time -
  3. Latest Carbon Budgeting info says need to stop at 1.5 degrees, which means by 20 years, and laws can be expected to enforce that.


Tracy's introduction

Commentary to the Oregon Public Utilities Commission, 16 February 2017

We are thankful to have been accepted as Interveners in this important matter, and for the discussions invited by Commission Chair Hardy. Ed Averill and I are research partners, I am Tracy Farwell, we are both PGE ratepayers and career engineers who have left retirement years ago to investigate just how bad climate issues have become. For many factual reasons we find the end of climate road as we know it is far behind us.

The true carbon footprint of the Carty Units: We regard the CO2 emissions from Carty Units 2 and 3 gas turbine exhaust to be a fraction the total attributable GHG products. The remainder stems from upstream methane emissions that are 80x worse than CO2 in the 20 years after release. A lower methane factor can be used if you believe we have all century to solve climate, but those who understand the nature of the problem are thinking 20 years is all we have.

Using the 20-year methane life cycle, Unit 2 CO2 plus upstream methane exceeds the pollution from the Boardman coal plant. This is because the methane contribution is 150% over the CO2 emissions.

True Life Cycle Carbon Footprint needs to be acknowledged: WA State, an upstream source for OR natural gas fuel, has launched their Clean Air Rule to just now begin comprehensive measurement of methane and CO2 releases to the environment. This proper use of state authority, targeting the top 24 point sources, can actually defend the effectiveness of Unit 2 regarding its WA upstream climate damage, if emissions are then controlled and sharply reduced. But the best they promise is a reduction of 1.7%/year wrt 1990 levels in WA. In CA, the AB 32 cap and trade program reduced emissions 9.4% in 10 years. None of these measures instituted in OR would save Unit 2 or achieve Oregon climate goals. We need 5% reductions for 10 years running. There is no 5% plan.

Our OR PUC Environmental Guidelines, amended and adopted in June 2008 as Order No. 08-339, discuss the eventual prospect of CO2 compliance requirements:

“ … The utility should identify whether the basis of those requirements, or “costs,” would be CO2 taxes, a ban on certain types of resources, or CO2 caps … . The utility should recognize upstream greenhouse gas emissions that would likely have a significant impact on its resource decisions.” [emphasis added]

We find that the OR PUC has properly anticipated the eventual incorporation of climate “externalities” into utility cost models, knowing full well they should impact on the economic viability of resource planning. The energy choices offered to Oregonians should clearly protect rate-payers and investors from the clear possibility of regulatory future “CO2 adders.”

The social cost of CO2 is widely recognized as $40/ton, an average of damage to health, infrastructure, forests, crops, etc. The US EPA carries the social cost of methane at $1000/ton.

We offer our summary of other first-order economic factors bearing on Carty natural gas expansion.

Ed's Testimony

Economics is a reason a plant built today will be shut down before 2030. Certainly before 2050.

Exponential change

Moore's Law

Cost of Wind and Photo-Voltaic Solar (PV) approximately follow Moore's law As technology is developed and put into production there are curves that describe typical changes in cost. One famous curve is Moore's Law, which was suggested as a pattern for price of integrated circuit transistors over time. Integrated Circuits have decreased in price by 1/2 every 2 years. This rule has, indeed, defined the future for many decades, as shown on the illustration from Wikipedia.

The most important thing to note is that Moore's Law is an exponential curve. Every 7 2-year timeframe produces a 100x change in price, which has been and will continue to be astounding. ( 2^7 - 128 ).

Cost of Wind and Photo-Voltaic Solar (PV) approximately follow Moore's law

As this is typically treated as a manufacturing experience curve, it is called Swanson's Law, but the result is similar.
Illustration shows approximate grid parity of residential solar at current time.

Cost of Battery Storage decreasing at 16% per year, nearing peaker parity.

Ben Kallo at equity analyst firm RW Baird believes that Tesla's current battery costs are ~$150 to ~$200 per kilowatt-hour, well below the industry average pack costs of ~$350 per kilowatt-hour (as estimated by Bloomberg New Energy Finance). External Link

Natural Gas

Costs are close to either Wind or Solar now

Will get more expensive over time

By 2020 the EIA thinks natural gas prices will rise more than 50% from current levels, hitting about $5 per MMBtu


Latest Carbon Budgeting info says need to stop at 1.5 degrees, which means by 20 yearsOCI report, and laws can be expected to enforce that: The serious risk of our future is that we fail to prevent catastrophic climate change. We only have about 20 years in which to reach almost shut-off of all fossil fuel. In addition to that, the efforts to make green energy affordable have just hit the amazing point of parity with fossil fuel – because of exponential and continuing rates of decrease in costs. And, for green energy there are NO FUEL COSTS.

It would be foolish to participate in ending the existence of our life support system, or even to put it at serious risk. But we don't need to.


intervener_testimony.txt · Last modified: 2017/02/15 17:42 by admin