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electric
generators in these states will have to prematurely shutter coal-fired plants and
replace them with plants that produce less carbon dioxide most likely wind and solar power
generating states being assigned reductions that are much larger than the 32 percent. As a result,
plants that need natural gas or coal-fired plants to back them up when the sun is not shining and/or the wind is not
the reductions that the United States makes will quickly be scooped up by
Chinaby far the worlds leader in carbon dioxide emissions or India, who will
surpass the United States as the second largest carbon dioxide emitter, since neither
country expects to make reductions in their carbon dioxide emissions by 2030. China expects
to peak carbon dioxide by 2030 and India will not agree to a firm reduction. Both
countries need to bring electricity to many residents that do not have access to it and
coal is the least expensive way to accomplish that globally. Thus, EPA wants U.S.
consumers of electricity to pay escalating prices as the above graphs indicate just
so countries like China and India can emit more carbon dioxide, in hopes they will
start reducing carbon dioxide sometime down the road . Further, while the regulations on
carbon dioxide emissions would shut down roughly 40 percent of Americas coal-fired power generation, the end
result would be just a 0.01 degree Celsius reduction in global temperatures by
2100[iii]hardly a reason to cause U.S. electric consumers such financial pain , which
impacts the elderly, minorities, and the poor the most. Conclusion Electric rates are increasing nationally
and to a greater extent in certain states, such as Colorado. These increases are caused by onerous
regulations that result in shuttering existing coal and nuclear plants prematurely and
replacing them with new plants that are higher in cost. Electric rates will continue to escalate as
EPA imposes more regulations, such as its regulation of carbon dioxide emissions from power plants.
Consumers need to be aware that their electric rates will increase for very little gain as
other countries will surely increase their carbon dioxide emissions as they provide
electricity to their citizens to improve their quality of life.
blowing. Further,
America, extreme weather is driving the discussion. Terry Boston, president of the PJM bulk electricity
management grid that serves 60 million residents in parts of 13 states, including New Jersey, said
doubts are growing over forecasts based on long-term weather trends, typically 30-year averages. PJM
experts, he said, could soon factor climate change and extreme events into their planning models for
delivering power and for restoring it when big storms turn off the lights. I cannot think of any year
in my career with more challenges, Boston said. U.S. Energy Secretary Steven Chu said theres
to rely on outdated and inflexible infrastructure, Chu recently told a Congressional committee
A2 link turn
CPP will strain the grid and cause blackouts dispersion - also
causes international free-riding
Segal 15 Scott Segal is executive director of the Electric Reliability Coordinating Council and former Emory
debater August 31, 2015 EPA's Clean Power Plan ignores costs, threatens reliability
http://www.mlive.com/opinion/index.ssf/2015/08/epas_clean_power_plan_ignores.html
We can expect significant potential threat to the electric reliability upon which
our modern way of life depends. Experts argued the proposed rule strained essential
services. The final rule is little improved. While it offers welcome delays in the
onset of compliance, it still creates a choke point by requiring draft plans to be filed
in just 12 months. Further, the "safety valve" it creates for reliability is too little , too
late like pulling an emergency brake after the accident is already occurring.
Renewables are an important element of a balanced portfolio as power
companies know, because they are making substantial investments in them but
they cannot come at the expense of maintaining critical base-load power plants. Is
all the pain worth it for the benefits of the Clean Power Plan? No. The rule is not
likely to decrease the harms associated with global warming, given that climate
change is an international phenomenon. While the White House hopes other nations
will follow our lead at December's climate summit in Paris, it is just as likely that
they will simply exploit competitive advantages created by our action.
Commission, Nuclear Regulatory Commission, Department of Energy, state and regional transmission lines has
lasted for almost 80 years, with very positive impacts. More importantly, this state and
federal electrical grid partnership developed the necessary long term planning
expertise, engineering sophistication, vast financing mechanisms and political
mandate to develop the most robust electrical grid in the world . It also had "the machinery
for change," as Leonard Cohen put it. Then, suddenly the EPA announced its "Clean Power Plan" in
2013. Several constitutional scholars saw this plan, using 111(d) of the Clean Air Act, as a significant federal
agency over-reach that some have called "regulatory capture." Experts such as William
Yeatman of the Competitive Enterprise Institute believe that the EPA should avoid this aggressive intervention and
continue a policy of "Cooperative Federalism" by using the "normal tools of government" including the electoral
consistently met or exceeded the federal requirements for energy efficiency, fuel use, renewable energy, and other
high-performance sustainable building metrics. In 2013, for example, EPA oversaw the 24 percent energy intensity
reduction from its FY 2003 baseline, a reduction from the FY 2013 energy intensity by 25.6 percent from FY 2003. In
FY 2013, EPA also measured a reduced fleet petroleum use by 38.9 percent compared to the FY 2005 baseline,
exceeding the goal of 16 percent." In addition, the EPA reports that greenhouse gases in the US have been reduced
by 10 percent 2005-2012. In the states, the 50 separate Public Utility Commissions (and their National Association
of Regulatory Utility Commissioners) have been exercising their authority and responsibility for working with state
governments, power plant operators, business community, state environmental groups, consumer groups and
47 states
have demand-side energy efficiency projects, all with measurable results, 38 states
have Renewable Portfolio Standards (RPS), 10 states have voluntary market-based Green
House Gas (GHG) emission trading programs and numerous large private companies and publicly traded
transmission companies to provide electricity to power the largest economy in the world. Currently,
utility companies have been pursuing voluntary emission reduction strategies. In a recent presentation at
conference of the American Meteorological Society in Phoenix, EPA Administrator Gina McCarthy said that "Science
is under attack like it has never been before," which seems like hyperbole, at the least or a highly political
rationalization, at the most. In a recent editorial in Science Magazine, the executive publisher Alan I. Leshner, said:
"If the general public is to share more opinions with members of the scientific community, scientists themselves
cannot ignore concerns that people may have about the research process or findings. There needs to be a
conversation, not a lecture." Adding to the overall scientific confusion are recent stories about "global warming" by
many news outlets like the BBC, Forbes, the New York Times, The Economist and CBS, they have reported that there
has been no measurable increase in temperature over the last 15 years, also known as "global warming pause." On
the other hand, other media sources like the World Meteorological Organization, The Guardian and Climate Central
are reporting that the 10 warmest years have been since 1998. Surely, these disparities represent a major
disagreement between respected sources of weather science information. For the record, the United Nations
International Panel on Climate Change's (IPCC) latest study shows a temperature increase of 0.09 degrees
Fahrenheit since 1998. Unsurprisingly, a recent Ohio State University 2015 study suggests that "both liberals,
conservatives have science bias," when they are presented with facts that challenge some of their political beliefs.
Finally, there are several EPA's Climate Change assertions which can be vigorously debated. For example, in the EPA
News Release of October 31, 2014, it talks about the impacts of climate change across the country, "ranging from
more severe droughts and wildfires to record heat waves and damaging storms." One could easily argue that none
of the events need necessarily have been caused by global warming. In fact, there is no detailed scientific evidence
Why
has the EPA given up on cooperative federalism and replaced it with the Clean Power
Plan?" This complex plan simply does not take into consideration many of the costs
related to its comprehensive plan, like new transmission infrastructure, new
power plant construction and the stranded costs created by shuttering many coalburning power plants and current transmission lines. The EPA looks woefully
unprepared for the planning, oversight and execution necessary for its own Clean
Power Plan. Without an immediate global warming crisis, the rationale and political will for such precipitous action
as proposed in the Clean Power Plan seems more political than practical, especially given the fact that the EPA
has almost none of the technical, financial and engineering expertise
developed over 80 years by the group of US electric grid stakeholders. Most
surely, the current state of Cooperative Federalism has proven to be capable of
providing inexpensive and abundant energy, which is environmentally progressive
and economically sound. Ultimately, the EPA should be part of the total solution, not a
part of the problem and the creator of state and federal uncertainty many
years into the future.
to ascribe "climate change" to any of these natural events. All of this leads me back to my original point:
A2 k2 reliability
NERC agrees the CPP harms reliabilitymultiple argsno
link turn
NERC, 16North American Electric Reliability Corporation (Potential Reliability
Impacts of EPAs Clean Power Plan, http://www.nerc.com/pa/RAPA/ra/Reliability
%20Assessments%20DL/CPP%20Phase%20II%20Final.pdf,
significant changes occurring on the BPS both as a matter
of the course of business as well as a direct effect of CPP implementation. The results of the IPM and
The results of the CPP analysis underscore
AURORAxmp models have been delineated in the preceding chapters along with an overview of the key
assumptions that went into deriving the aforementioned results. A deviation from the relevant input assumptions
conventional generation resources such as coal, nuclear, etc., to more asynchronous, distributed and storageenabled resources such as wind, solar, and storage. In addition, the modern grid system will change in future to
(ERSs) include three important building blocks of reliability, namely; frequency support, ramping, and voltage. In
order to maintain the reliability of electric grid, resources need to be able to provide frequency support, voltage
control, and ramping capability. The ERSTF evaluated the capabilities of newer resources in terms of providing ERSs
to see if they are able to provide them. ERSs will be needed for future as we transition from conventional generation
mix to newer resource mix. Based on the analysis of geographic areas that are experiencing the greatest level of
change in their types of resources,
Adequate ramping capability (the ability to match load and generation at all times) is
necessary to maintain system frequency. Changes to the generation mix or the
system operators ability to adjust resource output can impact the ability of the
operator to keep the system in balance. Voltage22 Voltage must be controlled to protect system
Ramping21
reliability and move power where it is needed in both normal operations and following a disturbance. Voltage issues
tend to be local in nature, such as in sub-areas of the transmission and distribution systems. Reactive power is
needed to keep electricity flowing and maintain necessary voltage levels. Each reliability building block has an
associated video animation to explain the concept of that particular ERS. Please click on each title above to access
the corresponding video. Additionally, they are all available here: The Basics of Essential Reliability Services23
This report discusses the level of retirements for coal resources as well as the need to
replace that capacity with new resource s, primarily natural gas and renewables in order to meet
electricity demand. Replacement capacity may take years to plan, permit, finance, and
build. The assessment produces the results indicating the level of resources that need to be built in order to meet
demand; however, system planners must adequately plan for new resources to ensure that they can be built in a
for public comment as well as receipt of EPA approval and the necessary time to implement appropriate compliance
The 2022 implementation date could be a challenge for states that need to
pass authorizing state legislation to develop the needed program framework and
enforcement policies required to gain approval of their state implementation
programs. In addition, the states need to develop state implementation plans, gain EPA
approval, and provide sufficient time for the affected sources to plan, permit,
finance, and build replacement capacity, transmission, and any needed upstream
infrastructure (e.g., natural gas pipelines). With the CPP being litigated, it is uncertain what
the final rule deadlines will be and when all states can complete this process .
strategies.
electrical grid operator will compensate for that failure by pulling power from other
sources. 10 5 Electrical engineers rely on "spinning reserves" when this occurs. 10 6 Spinning reserves are "the
extra generating capacity that is available by increasing the power output of generators that are already connected
to the power system."' 0 7 This extra generating capacity is "ready to instantaneously respond to control signals
when grid
operators pull too much energy from compensating sources, they can cause the
generators providing the extra generating capacity to fail , which in turn causes the grid
operator to over-tax different power generators, which may also fail, creating what is known as a
"cascading failure."' 10 9 Cascading failures can eventually lead to blackouts.'10
from the system operator in order to maintain transmission system integrity."' 1 0 8 However,
One of the largest cascading failures resulting in a blackout in North America occurred on August 14, 2003.' That
blackout affected an estimated fifty million people in eight U.S. states and Ontario, Canada for up to a week.'1 2
The blackout cost the United States between $4 billion and $10 billion, 113 and in Canada, "gross domestic product
was down 0.7% in August, there was a net loss of 18.9 million work hours, and manufacturing shipments in Ontario
were down $2.3 billion (Canadian dollars)."' "14 To avoid blackouts, the electrical grid requires the balancing of
supply and demand to a near-perfect degree. In the United States, operators maintain the electrical grid at 60 hertz
("Hz")." 5 Ideally, this means that "the transmission grid would always operate precisely at 60 Hz ...even as its
millions of consumers impose varying loads at tens of thousands of substations.' ' I 1 A demonstrative case of
electrical grid balancing occurs in England, in what is known as the "TV pick-up."' " 7 After a popular television show
or sporting event ends, "[m]illions of lights and kettles are simultaneously switched on" while "[t]he National Grid . .
. must keep the frequency at 50hz.""' 8 This often requires turning additional peak load generators online
specifically to combat the power surge. 19 To combat the threat of blackouts, electrical operators 'have to forecast
[energy demand] second by second, minute by minute."' 1 0 They base predictions on what customers required on
others-some generators can come online at the flip of a switch (i.e. natural gas), while others take some time to
warm up. 123 Because an electrical operator cannot predict demand with perfect accuracy, operators set limits that
define a range of frequencies within which they must maintain operations. " Operators
of the grid
maintain its reliability by ensuring that deviations [from the ideal 60 Hz] never grow
to catastrophic size."' 124 These limits give operators a minimal amount of
wiggle room to balance the grid, but if the electrical grid operator allows the
frequency to go outside of the outer bounds, the grid can fail and cause
blackouts. Time-intermittent wind and photovoltaic power create even more
challenges for grid operators. As the demand for renewable energy sources
increases, the shortcomings of the electrical grid will become more problematic.
"The changes will lead to grids that are more stochastic and exhibit dynamics requiring new stability criteria that
address emerging problems and can be evaluated faster, closer to real time.' 125 In Germany, where renewable
energy sources have priority over traditional power plants, transmission companies send excess renewable energy
to other counties because of the grid's inability to store electricity efficiently.1 26 In the United States, the
Bonneville Power Administration, based in the Pacific Northwest, has taken another approach, which includes
booting wind energy supplies off line in favor of hydroelectric power when too much supply exists, allowing clean
energy to go unused. 127 While grid operators make these decisions based on the necessity to balance the grid,
decisions like Bonneville's can make investments in clean energy superfluous.
Squirrels
Grids vulnerable and threats are growing---insiders vote
neg
Merica 12 Dan, CNN, "DoD official: Vulnerability of U.S. electrical grid is a dire
concern", July 27, security.blogs.cnn.com/2012/07/27/dod-official-vulnerability-of-us-electrical-grid-is-a-dire-concern/
A2 Timeframe/ adapt
Ev is about CPP shift to smart grids
utility-security professionals say that they have experienced at least one security breach. For their part, federal and
state governments genuflect to the goal of reliable, resilient, and affordable electric service. Yet comparatively
trivial sums are directed at ensuring that grids are more secure, compared with the vast funding to promote,
subsidize, and deploy green energy on grids. The central challenge for U.S. utilities in the twenty-first century is to
accommodate the conflict between political demands for more green energy and societys demand for more reliable
there are assurances that security technologies have caught up. While the government needs to improve its vital
role in helping with cyber situational awareness, the private sector must lead the way in defending against
cyberphysical threats that evolve and move at tech-sectornot bureaucraticvelocities.
Smart grids easier to hack the plan makes grids less secure.
Mills, 16
[Mark, Senior Fellow at the Manhattan Institute and author of Exposed: How
Americas Electric Grids Are Becoming Greener, Smarterand More Vulnerable,
Smart Grids: Greener & Easier to Hack, Real Clear Policy, July 14, 2016,
http://www.realclearpolicy.com/blog/2016/07/14/smart_grids_greener__easier_to_hac
k.html]
the power electronics on solar panels. Cybersecurity has simply not been the priority in green policy domains
even though technical and engineering message boards and publications are filled with examples of cybervulnerabilities or weak or non-existent cybersecurity features .
followed by an
email from the hacker stating that the power at all the hospitals will be
shut down within an hour. The ransom is, say, $10 million in Bitcoins. Now imagine a different
scenario, this time a hot Manhattan evening when several blocks go dark. Its not a ransom this time but a
threat: more is coming. The mayor gets an image on his smartphone of the July 25th 1977 cover of Time
larger hospital in the network goes black, too, as the back-up generator fails to start. This is
Magazine with its headline Night of Terror. That 1977 New York City blackout lasted 25 hours, involved thousands
of ransacked stores and fires, 4,000 arrests and $300 million in damages. This time, the mayor also worries that the
attacker could be coordinating an array of Orlando-type physical assaults to fuel the chaos. In the first case, the
ransom gets paid and power comes back. In the second scenario, no physical attacks happen, but it takes two days
and heroic efforts from ConEds crews to restore power by reverting to older manual systems that bypass the
smart stuff. But the terrorists made their point. And in both cases forensic teams from the Department of
Homeland Security, the FBI, and DODs Cyber Command descend. They learn that a sophisticated phishing scam
inserted a computer worm, combined with malware loaded earlier in a backdoor hack into a power monitoring
device, enabling the remote seizure of local power network controls. The NSA traces the cyber breadcrumbs to
anonymous servers in Georgia (the country not the state) or Iran, or China, and a dead end. Sound far-fetched?
Consider where we are today: ransomware attacks are already a scourge. The American Hospital Association
reported that several health care companies and hospitals were hit earlier this year with ransomware (most paid).
But, so far, hackers can only shut down a target organizations access to its own computer system or e-commerce
Web site. As for the future, consider that for hackers, todays Internet-connected cars look just like tomorrows
connected grids. Researchers have hacked the Ford Escape, Toyota Prius, Nissan Leaf, and to great fanfare a
Jeep Grand Cherokee. Last years cyber-jacking of a Jeep took full control from ten miles away by exploiting
vulnerabilities in the Internet-connected infotainment system to backdoor into the cars microcomputers that
operate the steering and brakes. In the wake of that stunt, Chrysler recalled over a million cars and corrected those
particular vulnerabilities. Earlier this year, the FBI and NHTSA issued a general alert regarding vehicle cyber
vulnerabilities. Everyone on both sides knows its only the tip of the cyber-berg. In fact,
there have
already been cases of grid-like cyber-jacking. In 2008, a Polish teenager hacked a citys
light-rail controls and caused a derailment. In 2010 the world learned of a clandestine hack ostensibly U.S.-Israeli
that inserted the Stuxnet computer virus to damage the electrical infrastructure of Irans nuclear facilities. In
2015, hackers breached the operating system of a German steel mill, causing enormous physical damage. And this
already know what adding more Internet connectivity enables. The Department of Homeland Security asserts that
Americas manufacturing and energy sectors are the top two targets for attacks on cyber-physical systems. And
Cisco reports that 70 percent of utility IT security professionals discovered a breach last year, compared with 55
percent in other industries. Heres the rub:
will create more Internet-exposure precisely when bad actors and hostile
nation states are rapidly escalating their hacking skills.
Sq CP
Renewables now solves the aff, but the plan rushes the
transition and causes our impacts
Porter, et al, 15Bishop William Lawrence University Professor, Harvard
Business School (Michael, with David Gee, Senior Partner and Managing Director at
The Boston Consulting Group, and Gregory Pope, Principal at The Boston Consulting
Group, AMERICAS UNCONVENTIONAL ENERGY OPPORTUNITY,
http://www.hbs.edu/competitiveness/Documents/america-unconventional-energyopportunity.pdf,
Policies at both the state and federal level will continue to encourage lowercarbon energy solutions. State Renewable Portfolio Standards will cumulatively
require a minimum of 60 GW of new renewable generation by 2030, 40% higher
than is mandated today.158 In addition, 13 states have introduced greenhouse gas emissions limits
that will require further shifts to lowercarbon power.159 Federal standards will also
ensure that vehicles and appliances continue to improve their energy efficiency.
There are also a growing number of other proposals that would encourage carbon
reductions over the next 1015 years and longer. The Obama Administration, for example, has
recently introduced the proposed Clean Power Plan (CPP)160 that covers carbon reductions in the power sector,
signed a greenhouse gas emissions accord with China,161 and made U.S. greenhouse gas reduction pledges to the
Paris round of international climate negotiations.162 Each proposal targets a 2530% reduction in carbon emissions
by 2030 compared with 2005 levels. These proposals face stiff political and legal challenges, but the reality is that
and at a competitive cost across a range of carbon reduction scenarios, at least through 2030. Natural gas can replace up to 50% of the existing coal capacity by 2022 at lower cost,168
providing significant economic and carbon benefits, regardless of other climate policies. EPA Administrator Gina McCarthy put it well in April 2015 when she said, [Fracking] has changed
the game for me in terms of how the energy system is working. The inexpensive gas thats being produced has allowed us to make leaps and bounds in progress on the air pollution side
and, frankly, to make the Clean Power Plan.169 Natural gas essential for near-term carbon reductions Natural gas is the only fuel that can cost-effectively deliver large-scale carbon
emissions reductions in the near term, including the 30% carbon emissions reduction targeted by the proposed Clean Power Plan. A 2014 CSIS/Rhodium Group study170 shows that
increasing natural gass share of power generation from 28% today171 to 43% by 2030 allows the U.S. to meet the 30% reduction target of the Clean Power Plan without significantly
increasing the cost of electricity in the U.S.172 The study estimates that power rates would rise by around 4%, while overall energy expenditures would remain nearly flat, assuming that
states coordinate their implementation.173 (See Figure 23 on page 39.) Unconventional natural gas also gives the U.S. a competitive advantage in moving to a low-carbon energy
system over other countries that lack abundant natural gas resources. Without a supply of low-cost gas, Germany, for example, set aggressive renewables goals and then spent $400
billion in direct government subsidies to support renewable growth.174 The price of electricity for residential customers increased by 70% between 2004 and 2014.175 The share of
renewables has increased to about 25%,176 but the share of coalfired power has actually increased as well.177 Greenhouse gas emissions have only fallen approximately 10% since
distribution of intermittent renewables, as well as the ability of the grid to utilize demand response and storage, but