The move to
competition in the provision of electricity service will change the way
consumers buy power. Early pilot
programs, in which consumers were offered their choice of suppliers, revealed
that they are very interested in the environmental quality of the electricity
products offered and are often willing to pay a premium for green electricity. Electricity
generation leaves a significant environmental footprint, emitting 66% of the
nation’s sulfur dioxide (SO2), 29% of its nitrogen oxides (NOx),
36% of its carbon dioxide (CO2) and 21% of its mercury. Appropriate and accurate marketing and good
evaluation tools are necessary to make the offer of environmentally superior
electricity products a credible venture.
The Power Scorecard provides
consumers the means to distinguish objectively the relative environmental
quality of the electricity services they must choose among in these new
competitive markets.
More than 40
state legislatures and utility regulatory agencies have begun to review the
risks and benefits of deregulating electricity suppliers in their state --
allowing certified or licensed suppliers (not just regulated monopoly
utilities) to sell electricity to customers at market prices (rather than
regulated rates).
In several states, notably California, Massachusetts, Pennsylvania, Rhode
Island, New Hampshire, New Jersey and New York, customers have already been
offered the opportunity to choose a new electricity supplier.
Some power products
are distinguished by the environmental quality of the power derived from renewable
and other “clean” power resources. The sale of these supplies in states that
have deregulated their power markets is commonly referred to as green
marketing. Monopoly utilities offering
“green” alternatives to traditional generation resources in states which have
not yet adopted deregulation, are engaged in what is commonly known as green
pricing.
The Power Scorecard,
asks a set of questions about the resources used to generate the electricity
being sold, and scores those answers generally on a scale from one to ten. The scoring scale was established by a group
of environmental and energy experts and represents their best judgment about
how to rank the answers provided by the energy suppliers. Default scores are
provided for those situations where only fuel-type or technology is known.
Overall Power Scorecard ratings are
developed for products based on the proportion of the product’s energy mix
provided by each generating resource and the individual scores for each of
those resources. Supplies or products with lower scores cause fewer adverse
environmental consequences than those which rank higher on the scale. In an effort to make Power Scorecard understandable and manageable, the scoring process
has been simplified as much as possible.
Objective measures of
environmental impacts are key elements of the scoring, but Power Scorecard necessarily incorporates some judgment. Objective
criteria are not available for measuring all impacts. Power Scorecard reveals the judgments it uses and discusses the
basis on which those judgments were reached.
Power Scorecard augments the Center for
Resource Solutions’ Green-e and other
certification efforts developed around the country by allowing consumers to
distinguish among each of the supply options carrying a Green-e label as well as supply options that have not yet been
certified. Any electricity product, whether marketed as an environmentally
superior product or not, can be ranked.
Power Scorecard provides consumers with
the means to compare the environmental characteristics of various power
products. The promise of retail choice
is the power of consumers to choose services they want. This tool allows consumers to evaluate the
environmental quality of a supply, and balance that with other attributes of the
offer -- such as price. Only if customers have the tools necessary to
distinguish easily between the relative environmental quality of different
products will consumer choice have the potential to reduce the environmental
impact caused by the generation of electricity.
A. Two Measures of
Environmental Quality
Power Scorecard provides two measures of
the environmental quality for each electricity product: one to assess the
environmental impacts of the electricity generating sources that serve
consumers, and one to assess the contribution to displacing existing high
impact electricity supplies with new low impact renewable and environmentally
preferred supplies. For each of the two measures, products are assigned one of
six ratings: unacceptable, poor, fair, good, very good, or excellent.
The Environmental Impact
Rating
The Power Scorecard evaluation tool ranks
the relative environmental quality of an electricity product. Supplies with
lower scores have better environmental quality than those that rank higher. Power Scorecard allows consumers to
compare products based on their environmental quality. Power
Scorecard also allows suppliers to assess the relative environmental quality of
alternative product designs and to assess the quality of offers made by their
competitors. Its flexible structure enables Power
Scorecard’s use across the wide range of product designs providers may wish to
offer.
The
Environmentally Preferred New Renewable Content Rating
The Power Scorecard evaluation tool also
rates products on the amount of new renewable or environmentally preferred
energy included in their mix. Not only
do new, clean sources of electricity provide significant environmental
improvement over most current generating resources, but purchases from new low impact sources create the
financial market necessary for even more new renewable resources to be
constructed. Buying electricity from new renewable generation yields immediate
and long-term environmental gains.
B. Outreach
The Pace Energy
Project expects to make the Power
Scorecard assessment of products available on the web in each of the states
where consumer choice is provided. In
addition, the environmental organizations that have guided the creation of this
tool will be using it to advise their members of the environmental quality of
available electricity products. Power Scorecard and related
informational materials will be offered to other organizations to increase
consumer awareness of the links between environmental quality and retail
choice. A major education campaign on
the value of buying environmentally superior electricity products is also
planned.
C. Ingredients
An effective green
rating program will have three major components:
1. transparent
and objective environmental quality criteria and associated measures of
performance;
2. a transparent and objective methodology
for rating (i.e., scoring) service options against the
environmental quality
criteria;
3. an education program that communicates
rating scores in easy-to-understand terms that will help consumers make smart
retail choices.
Power Scorecard addresses the first two components and builds the foundation
for the third -- consumer education programs that must be delivered in each
electricity market to encourage consumers to analyze the choices available and
to make responsible decisions.
The environmental
qualities assessed by Power Scorecard
are in those areas most seriously impacted by electric generation
technology. They include:
Air quality global climate change
acid
rain, smog, and fine particulate pollutants
toxic
mercury emissions
Water quality consumption of water
resources
pollution
of water bodies
impacts on fish populations and
other aquatic ecosystems
Land quality impacts on land
fuel cycle/solid waste disposal
D.
Measures of
Performance
Power Scorecard identifies eight criteria on which to measure a generating
resource’s air, water and land impacts and scores using a scale where zero represents no (deminimus) impact
and a score of ten represents the high end of the range of impacts from current
fossil fueled generation. Scores extend beyond the two ends of this scale when
the magnitude of the impacts justify such scores.
As a general matter,
scoring is calibrated using common references.
A score of zero represents no (deminimus) impact. A score of four is assigned for those
impacts that remain after pollution control or mitigation practices are
incorporated to produce practically a very low emission rate from any fossil
fuel technology. A score of ten is
assigned to the high range of impacts associated with typical U.S. production
of electricity. On the scale for NOx, for
instance, a score of four is assigned to that level of emissions produced by a
new, high efficiency combined cycle gas-fired facility and a ten for emissions
expected from a coal plant lacking any NOx controls. Measurement criteria that have two reference
scores are linear from zero to four and from five to ten; all others are linear
from zero to ten. This common scoring system allows environmental impacts to be
compared across issue areas and technologies.
Power Scorecard provides scores for each of eight environmental impact
criteria and, by combining these scores, offers an overall environmental impact
score for each resource. The method for deriving total generation resource
scores is discussed under “Scoring Environmental Impacts” below and the method
for deriving total product scores is discussed in the "Product
Scoring" section.
Currently our power
comes from a number of different types of sources. Power Scorecard
specifically assesses the following types of supply: thermal resources
including geothermal, fossil-fuel and nuclear, and other resources including
solar, wind, and hydro (see list of technologies addressed specifically in
Attachment A). If other specific
sources enter the market, Power Scorecard can be adapted to assess them as well.
Thermal, solar, wind and
hydro facilities are scored on the same air quality criteria. All dual fuel and
multi-fuel thermal supplies receive a composite score based on production,
historic or projected, from each fuel type.
Thermal, solar and wind
facilities are ranked on the same water criteria.
Thermal and solar
resources are ranked on the same land criteria.
Hydro is ranked on
site-specific water and land criteria, while recognizing that hydro plants
produce no air emissions.
Wind is ranked on
site-specific land criteria, while recognizing that wind plants also produce no
air emissions.
E.
Scoring Environmental Impacts
The manner in which the
air, water and land scores for a facility are combined to derive a single
generating resource score reflects a choice of environmental priorities on
which to evaluate electric generating facilities. While objective measures of
environmental impacts are key elements of most of the scoring, Power Scorecard necessarily incorporates
judgment. Objective criteria are not
available for measuring all impacts precisely.
Nevertheless, these impacts exist.
Power Scorecard reveals the
judgments it uses in these cases and discusses the basis on which those
judgments were reached.
An overall environmental
impact score for each electricity product is calculated as the weighted average
of eight measured indices, where the index of global climate change impacts is
counted twice, reflecting the greater importance Power Scorecard assigns to this global environmental impact issue
relative to the other seven.
F.
Significantly Greater Adverse Environmental Impacts
Facilities evidencing
impacts greater than those typically receiving a score of ten can be given
higher scores by using the increments evident in the zero to ten scale. For example, certain coal facilities emit SO2
at rates that are approaching 40% more than emissions of facilities that scored
a ten for the SO2 index. Nuclear power plants have significantly
greater land impacts, and pose significantly greater long-term environmental
risks than do plants receiving a ten score and are scored appropriately in land
categories.
G.
Demonstrable Environmental Mitigation
Marketers wishing to
improve the score of their power products may take steps to mitigate the
environmental impact of the power they are selling. The scoring credits a
number of such enhancements, including commitments to: 1) invest in new,
low-impact renewable energy technologies 2) retire emission offsets or 3)
mitigate the effects of water withdrawal on aquatic ecosystems, as for example,
flow reduction, (re)location and (re)design of intake structures, fish
deterrent devices (e.g., ultrasonics), fish return systems, or native fish
restocking programs. Other enhancements
may be reported by suppliers but are not now addressed by the scoring: a
commitment to provide energy efficiency services is an important example. These
enhancements may contribute significantly to the environmental value of
services to consumers, in effect mitigating the environmental impacts captured
in the scoring. Such unscored environmental enhancements may be addressed in
qualitative observations provided when the scores are reported.
Suppliers of products
with enhancements such as these are invited to list them in the product scoring
process.
Power Scorecard will be revised to address important enhancements.
Recognizing products that make a significant commitment to helping consumers
take full advantage of energy efficiency opportunities will be among the first
such changes in Power Scorecard.
II.
Air Quality Impacts
Air quality is assessed
by measuring four types of emissions:
Carbon Dioxide -- CO2
-- to assess Global Climate Change impacts;
Sulfur
Oxides -- SOx -- to assess acid rain, smog and fine particulates
impacts;
Nitrogen
Oxides -- NOx -- to assess acid rain and smog impacts;
Mercury to
assess the impact of air toxics.
Power Scorecard allows users to consider the effects of emission offsets on
The Score (explained below).
A. CO2
Emission Rate and Score
The scoring for CO2
emissions is calibrated to award a score of four for emissions typical of a
high-efficiency combined-cycle natural gas fueled power plant, currently the
most effective application of fossil fuel technologies. Plants that burn other fuels may have
implemented pollution controls required by regulations but still not meet this
level of emissions, which is estimated to be 770 lbs. CO2/MWH. A score of ten is given for a coal plant
with high emissions since this signifies relatively low combustion efficiency.
The diverse group of
fuel types and fuel processing technologies that make up the category of
“biomass” complicates scoring CO2 for biomass-fueled plants. It is also complicated by the interaction
between a facility’s emissions, the avoided releases of greenhouse gases if the
fuel is instead left to decompose, and CO2 sequestering inherent in
repeated regeneration of biomass fuels.
The global climate
change impact score of biomass is based upon the net impact of the fuel source
on global climate change agents (CO2 and methane emissions). The measurement criteria used here represent
our first, best efforts at correctly accounting for the multiple greenhouse gas
implications of biomass as a fuel. As
we learn more, this scoring will be refined. Initially we will employ the
following scoring guidelines:
1. Projects using a biomass fuel supply that is certified as
coming from “sustainable sources” will qualify for zero net emissions and
receive a score of zero. This anticipates the creation of a “sustainable fuel
source certification” akin to the recently developed Low Impact Hydropower
certification managed by the Low Impact Hydropower Institute.
2. Projects using a biomass fuel supply that is not certified as
sustainable, but for which there is a reasonable basis for believing they are
being replaced (e.g., energy crops), or projects that use clean waste that
would otherwise be landfilled or burned in the open and which come from working
forest or agricultural operations where biomass is being replanted (although
not necessarily being replanted for use as a fuel), would receive a global
climate change score of 2.
3.
Projects in which there is no evidence that the biomass is being
replaced, but which are avoiding methane release, would obtain a global climate
change score of 4 (examples: wood from clearing land for commercial or urban development).
Although the climate change effect of avoiding methane emissions may be zero or
positive, such projects are only given partial credit because the fuel source
is removing previously sequestered carbon.
4.
Projects with no evident carbon equivalent benefits would score 10 (for
example, biomass being removed for commercial development without being
replanted).
Construction and
demolition waste (clean C&D wastes) will be placed in category #3 above
(avoided landfill) or in category #4 depending on the circumstances.
In the case of
landfill gas to electricity projects, a further adjustment is made to account
for the valuable displacement of unflared methane for facilities that utilize
previously (within the previous twelve months) unflared landfill gas
(methane). These resources score a
negative four on this criterion. Landfill gas to electricity projects
utilizing previously captured or flared methane score zero.
The scale is
proportional from zero to four and from five to ten,
but not over the full zero to ten range. The effect is to make the scoring
sensitive to smaller performance increments at the low end (below four) than at
the high end (above four).
SCORE
LBS./MWH
0
= no
or trace CO2 emissions
1
<= 192
2
<= 385
3
<= 578
4 <= 770 -- reference score
5
<= 1096
6
<= 1422
7
<= 1748
8
<= 2074
9
<= 2400
10 >
2400 -- reference score
This scoring produces
the following representative CO2 emission rates for common thermal
electricity generating technologies:
PLANT TYPE CO2
EMISSIONS LBS./MWH SCORE
Solar
(PV) 0
0
Hydro 0
0
Wind
0
0
Nuclear 0
0
Natural gas fueled combined cycle
plant 770 4
Oil
fueled steam electric plant 1,770 8
Oil fueled combustion turbine 2,190 9
Coal fueled steam-electric plant
1,960-2,310 8-10
Solid waste generic facility 2,900 10
B. SOx
Emission Rate and Score
The SOx
emission score is calibrated to the
emissions expected from a high efficiency combined cycle natural gas fueled power
plant (none or negligible emissions) and the ten score is set at the level of
emissions expected from a coal plant using high sulfur coal without any flue
gas desulfurization equipment (46.5 lbs. SOx per MWH of output). A six increment scale is created using the
maximum output of 46.5 lbs.; scores five through nine are assigned five of
those increments and scores one through four divide the remaining sixth into
four equal increments. This allows
differentiation in scores between zero and four as SOx emissions approach zero.
SOx at
high concentrations can cause temporary breathing impairments for
asthmatics. It is also a precursor to
fine particulate matter (emissions particles less than 10 micrometers in size),
which can penetrate deep into the lungs.
Fine particulates are strongly associated with chronic lung disease and
cause regional haze, reducing visibility.
Sulfur Dioxide also causes acid rain, which can kill lake-resident plant
and fish life, affect forests and cause outdoor corrosion.
SCORE LBS./MWH
0 = no
or trace SOx emissions
1
<= 1.9
2
<= 3.7
3
<= 5.6
4 <= 7.4 --
reference score
5
<= 9.3
6
<= 18.6
7
<= 27.9
8 <= 37.2
9 <= 46.5
10 > 46.5 --
reference score
The scoring produces
the following representative SOx emission rates for common thermal
electricity generating technologies:
PLANT TYPE SOx EMISSIONS LBS./MWH SCORE
Solar
(PV) 0 0
Hydro 0
0
Wind
0
0
Nuclear 0 0
Natural gas fueled combined cycle
plant 0
0
Biomass 0.1 1
Oil (2.2 % sulfur) fueled steam
electric plant 25.4 6
Oil (0.3 % sulfur) fueled combustion
turbine 4.4 3
Coal fueled steam-electric plants
1. steam-electric 46.6
10
2. integrated gasification combined
cycle 1.3 1
3. atmospheric fluidized bed
combustion 4.6 3
C. NOx
Emission Rate and Score
Nitrogen Oxides (NOx)
scoring is calibrated to award a score of four to the emission rate for a high
efficiency combined cycle natural gas fueled power plant (0.09 lbs. NOx/MWH)
and a score of ten is assigned to emissions at the level of a coal plant
lacking emissions controls (9.3 lbs. NOx/MWH).
NOx play a
major role in the formation of ozone, which is of particular concern to
asthmatics. Ozone is a strong irritant associated with decreases in lung
function, lung tissue damage, and chronic lung and heart disease. It also
damages crops and forests.
The scoring system is
proportional from zero to four and from five to ten and produces the following
scoring for NOx :
SCORE NOX EMISSIONS -
LBS./MWH 0 = no
NOx emissions
1 <=
0.02
2 <= 0.04
3 <=
0.07
4 <=
0.09 --
reference score
5 <= 1.93
6 <= 3.77
7 <=
5.62
8 <= 7.46
9 <=
9.3
10 >
9.3 -- reference score
This scoring produces
the following representative NOx emission rates for common fossil
fuel based electricity generating technologies:
PLANT TYPE NOx EMISSIONS-LBS./MWH SCORE
Solar
(PV) 0 0
Hydro 0 0
Wind
0 0
Nuclear 0 0
High efficiency natural gas
combined cycle plant 0.09 4
Generic natural gas fueled
combined cycle plants 2.5-3.8
6-7
Biomass (varies with level of
control) 1.7-3.9
5-7
Oil fueled steam electric plant 3.0-3.7 6
Oil fueled combustion turbine 3.7-6.8 6-8
Coal fueled steam-electric plants
C steam-electric 6.1-9.4 7-10
C integrated gasification
combined
cycle 0.45-0.60 5
C atmospheric fluidized
bed
combustion 3.0-3.8 6-7
D. Mercury Emission Rate and
Score
Mercury emissions are not routinely monitored
but the tendency for a plant to emit mercury can be reasonably predicted based
on fuel type and pollution control technology.
The scoring for mercury is calibrated by setting the mercury emission
rate for oil-fired plants at four and the mercury emissions from lignite-fired
plants with dry particulate control but lacking flue gas desulfurization
(”FGD”) equipment at ten. Although the mercury content of coal is extremely variable, even
within the same coal source, the large difference between the mercury content
of coal and other fossil fuels provides the basis for the following scoring:
SCORE LBS./GWH
0 = zero
1
<= .001
2
<= .002
3
<= .003
4 <= .005 --
reference score
5
<= .033
6
<= .062
7
<= .090
8
<= .119
9
<= .147
10 > .147 --
reference score
This scoring produces the following
representative mercury emission rates for common fossil fuel based electricity
generating technologies:
TECHNOLOGY SCORE solar (PV) 0
wind 0
hydro 0
nuclear 0
gas-fired
steam-electric plants 1
oil-fired
steam electric plants 4
bitumen
coal w/ FGD and particulate controls 6
bitumen
coal with dry particulate controls 7
lignite
coal with FGD and particulate controls 8
lignite
coal with dry particulate controls 10
Mercury emitted from solid waste facilities
has often been several times greater then mercury emissions from coal plants
scoring a ten on this scale. . New Federal emissions standards for waste to
energy plants, “Maximum Achievable Control Technology” standards, require substantial
reductions in mercury emissions from waste to energy plants by 2001. The impact
of these new standards is under review and will be reflected in the table of
default scores provided in Attachment A as soon as possible. As is the case generally, any electricity
supply source will be scored on the basis of actual performance characteristics
when that information is made available for scoring.
E. Emission Offsets
Power Scorecard has been designed to
allow inclusion of emission reduction credits in the form of an adjusted score,
though it will not change the ranking associated with actual plant emissions. Emission reduction credits are
created under emissions trading programs. Power
Scorecard will show the effects on air emission scores of the retirement of
valid emission reduction credits that are not otherwise required by any
regulation. To demonstrate validity, the credit must be fully fungible and
registered in either a state or federal or federally-approved registry. Credits
can be in the form stipulated by the program - for instance, SO2
allowances in the case of the acid rain program.
Though at least three formal processes are at
work to develop a standard for early CO2 reduction credits, no
standard program yet exists. When such a standard is established, a specific methodology will
be adopted to allow scoring for CO2 offsets which will require that
the offsets be readily verifiable, measurable, not be double counted by another
source, and be permanently retired.
There is an emissions trading program for SO2
which is referred to as the acid rain program. The program established an
emission cap and allocated that cap to affected utility sources. Each allowance
has a unique serial number and can be freely used for the duration of the
program once it has been activated (a certain number of allowances are
activated each year). At the end of each year, affected sources have to
surrender an amount of allowances that equals their actual SO2
emissions. If they have any allowances remaining, sources can bank them for
future use. If a source decides to retire certain allowances expressly for the
purpose of mitigating the air impact of the power it is generating, the retired
emissions will be credited against their actual emissions for the parenthetical
scoring purposes. For example, if a source held 200 allowances but only emitted
150 tons it would have to surrender 150 allowances and would then bank the
remaining 50 or trade them to another source. If those 50 tons, instead, were
retired for the purpose of mitigating the impact of power generation, then the
source could adjust its score to show and additional 50 tons of reduction in
emissions.
There is one NOx emission cap and
trade program being implemented in the Northeast and another proposed for 23
jurisdictions in the East. There are several other state initiatives to allow
NOx trading for RACT and New Source Review compliance. Because of
the nature of smog formation and the role of NOx, Power Scorecard would only adjust scores
for the retirement of NOx allowances associated with the cap and trade
programs. Adjustments would be done in similar fashion as in the case of SO2.
The adjustments to the air quality scores
that result from considering such credits will be reported with the scores in
parentheses, but will not change the score or ranking associated with actual
plant emissions. This information will allow users to see the score based on
actual emissions but also to consider results of additional retirement of tons.
III. Water Quality Impacts
Water quality impacts of thermal, wind and
solar electricity generation are scored using the same criteria; scoring for
geothermal plants and hydro plants is done separately as discussed below. Water
quality impacts of thermal, wind and solar electricity generation are of three
principle types:
1) Thermal Impacts - the discharge of
heat to the adjacent water body
2) Usage
Impacts - chiefly impacts on aquatic species caused when large
quantities of water are withdrawn from the lakes, rivers and other water bodies
(e.g., entrainment and impingement of organisms in plant cooling systems)
3) Chemical Impacts - the discharge of
chemicals used in, or created by plant operations.
A. Thermal, Wind and Solar
Generation Rating
Methodology
Power Scorecard assigns usage impact scores to generation
resources based on the amount of water used per/MWH and chemical impact scores on the stringency of a plant’s effluent
limits and its compliance record with those limits. Impacts related to thermal
discharge are not separately assessed as they are, by and large, site specific,
and dependent to a great degree on the characteristics of the water body into
which the effluent is discharged. In
addition, significantly adverse impacts due to thermal discharge often result from
isolated incidents. Longer-term impacts
are correlated with cooling system technology, and captured, for the purposes
of Power Scorecard, in the measure of
water use.
1. Usage Impacts
Impacts on aquatic
species caused when water is withdrawn from lakes, rivers and other water
bodies (i.e.,
impingement and entrainment) are correlated strongly with the amount of water
utilized. This in turn depends on a
power plant’s capacity, fuel source and cooling technology. Nuclear plants use the most water for
cooling, coal plants use somewhat less, and oil- and gas-fired generation
plants use even less.
A score of zero is awarded to plants that use
no water and a ten for water use equivalent to a 1000-MW nuclear boiling water
reactor. Scores between zero and ten
reflect the amounts of water utilized by the prototypical generating plants,
expressed as “cubic feet/second/MW” to allow for individual plant differences.
A one point adjustment to the score is
available if the plant operator has built in or retrofitted the facility with
“qualified mitigation measures” such as flow reduction, (re)location and
(re)design of intake structures, fish deterrent devices (e.g., ultrasonics),
fish return systems, or native fish restocking programs to ameliorate impingement
and entrainment impacts. The flat one point adjustment is offered because no
method has been developed to assess the relative value of different
combinations of these mitigation measures.
A linear scoring system using these end
points produces the following scale:
SCORE cubic feet
per second per MW
0
= no surface water
consumption
1
<= 0.22
2 <= 0.44
3 <= 0.67
4
<= 0.89
5 <= 1.11
6 <= 1.33
7 <= 1.55
8 <= 1.77
9 <= 2.00
10 > 2.00 -- reference score
This scoring produces the following
representative intake scores for common fossil-fuel electricity generating
technologies:
PLANT
TYPE SCORE
Solar
(PV) 0
Wind
0
gas-fired
steam electric with cooling towers 1
Biomass
facilities 1
oil
fired steam electric with once-through cooling 6
coal
fired steam electric with once-through cooling 8
nuclear 10
2. Chemical or Water Quality Impacts
Power plants release a number of compounds that threaten
water ecology and human health. As
described below, the Power Scorecard
rating of water quality is based on the level of pollution control the facility
operator is required to meet: 1) in relation to the industry norm; and 2) the
environmental requirements of the adjacent water body. Our scoring system further differentiates
power plants on the basis of their track record of compliance with applicable
standards.
Benchmark score: Under the Clean Water Act, the U.S.
Environmental Protection Agency sets effluent limits for various
"categories or classes" of point source polluters. Categorical standards have been established
for steam electric power plants (40 CFR 423.12) These effluent limits, based on
the best practicable control technology, are written into the power plant
operators' NPDES permit. Power plants
subject to, and in compliance with, all applicable effluent standards receive
the benchmark score of "4".
If they are out of compliance with their effluent limits, they receive
an "8".
Variance score: Power plant operators can obtain a variance
from one or more of the categorical effluent limits if they can demonstrate to
EPA's satisfaction that the power plant in question is fundamentally different
from the prototypical plant upon which EPA's standards are based. Among the recognized bases for receiving a
variance is age and size of the plant, raw materials, plant processes, energy
requirements and costs. Because
variances are granted on the basis of technological and not ecological
differences, Power Scorecard treats
plants receiving a variance less favorably. Thus, these facilities are scored a
"6" if in compliance, and are scored a "8" where out of
compliance.
Water Quality score: In addition to the technology-based
standards, environmental regulation may impose, on a case-by-case basis, more
stringent standards where necessary to protect the designated use of the water
body (e.g., cold water fishery, public water supply, recreation, etc.). Thus, plants failing to meet these water
quality based standards receive a less favorable score (Score = 10) on the
theory that they impose extraordinary impacts on the environment.
SCORE EFFLUENT
STANDARD COMPLIANCE
0
no discharge
4 subject to standards
at
least as strict as categorical
standards
for steam-electric
generation
point sources and in
compliance
6 subject to
effluent standards that are
(in
any respect) less stringent than
categorical
standards and in
compliance
8 Subject
to effluent standard no more
stringent
than categorical standard and out of compliance with any one effluent limit;
10 subject to water
quality standards that
are
more stringent than categorical
standards
(reflecting need to protect local
ecosystems) and out
of compliance;
B. Geothermal Scoring Adjustments
An effectively designed and operated
geothermal generating plant is extremely benign, producing negligible adverse
environmental impacts. Nevertheless there
are may be significant environmental impacts, especially water quality impacts,
that must be addressed in their design and operation.
The risks of impacts on water resources are
associated with processing the geothermal resource itself, i.e., the geothermal
fluids or steam. Binary cycle
technologies are closed loop systems and, therefore, when operating properly,
do not impact water resources or related ecosystems. Flash system technologies may result in the releases of
significant quantities of geothermal fluids, depending on the effectiveness of
the plant design at capturing and re-injecting geothermal fluids back into
geothermal zones of the Earth’s crust.
The long-term impact of geothermal plant operations on the quality and
quantity of local ground water supplies is a significant water quality issue in
some regions.
Until a better method is developed, Power Scorecard will assign four penalty
points to both water use and water quality scores for any geothermal generating
facility that is contributing significantly to the deterioration of the quality
and quantity of local ground water supplies. This will be assessed on a case by
case basis, an approach that may be practical because there are only a limited
number of geothermal projects in each market area.
IV. Land Quality Impacts
Land quality is assessed for both on- and
off-site impacts. On-site impacts
result from ecological consequences of the facility itself, on-site fuel
storage and waste handling. Off-site
impacts include waste disposal, and the mining, processing and transportation
of fuel.
Wind and hydro facilities are scored using
site-specific criteria, as discussed infra.
A. On-Site Land Impacts:
Thermal and Solar Generation
On- site land impacts are inherently specific
to each plant. In light of our
inability to measure such specific impacts at the outset, we use a proxy and
measure the amount of land used per megawatt-hour (of annual plant output) for
the facility and its on-site fuel storage and waste disposal. A permanency factor is assigned to
differentiate generating technologies with easy to reverse land impacts from
those that pose comparatively difficult to reverse on-site land impacts
1. Land-use/megawatt-hour
Base scores are assigned from zero to ten
depending on acreage required for the facility and for its on-site storage and
disposal systems (“inside the fence”) per megawatt/hour of output. The ten
score reflects the land needed for a facility imposing one of the largest
footprints, a biomass facility running at a 60% capacity factor. The 4 score represents the mid-point between
acres required for a new combined cycle natural gas plant and an older natural
gas steam plant. Scores are spread
between 0 and 4 and 4 and 9 in equal increments.
SCORE ACRES/MWH
(OF ANNUAL OUTPUT)
0 0
1 < .5 x 10!5
2 < 1.0 x 10!5
3 < 1.5 x 10!5
4 < 2.0 x 10!5
5 < 9.6 x 10!5
6 < 17.2 x 10!5
7 < 24.8 x 10!5
8 < 32.4 x 10!5
9 < 40.0 x 10!5
10 => 40.0 x 10!5
2.
Permanency of impact
A
permanency factor is applied as a multiplier to the base land score. The
multiplier is based on qualitative judgments about the reversibility of
impacts, and differentiates among
i)
fossil fuel technologies which are assumed to have similar impacts
associated with power plant and fuel handling facilities,
ii)
wind and solar technologies which can be easily and quickly removed,
iii)
biomass plants whose operation requires large amounts of land for fuel
storage and processing, but impose very few long-lasting environmental risks to the site, and
iv)
nuclear facilities which produce significant,
difficult-to-reverse impacts and whose environmental and public health
risks are qualitatively different from
other generation sources.
Fossil
fuel plants are assigned a permanency multiplier of one (1.0). Solar and wind facilities, which can be
removed easily and quickly, are assigned a permanency multiplier of 0.25.
Biomass fueled facilities will have a default permanency weight of 0.5.
For plants whose biomass fuel is source is certified as sustainable, a
permanency weight of 0.25 will be assigned. Power
Scorecard is developing appropriate biomass scoring. As a first effort we differentiate between fuel sources that are
sustainable and/or replaced and those that are not. No certification for “sustainable
biomass” is available now, but several organizations are planning the
development of such a certification. Power Scorecard recognizes the value of
creating such a certification by offering a better rating for plants that may
qualify.
A permanency factor of 1.0 can be assigned where there is evidence of
significant risk of environmental impact from fuel storage and processing
related to operations.
Nuclear plants leave long-lived and risky on-site impacts
that are much more significant and risky than the land-use impacts of fossil
facilities. The Nuclear Regulatory Commission permits
owners of nuclear plants to defer the dismantling of the facilities for up to
60 years. In addition, it is possible
that spent nuclear fuel could be stored on-site for as long as 100 years. And there is disagreement between the NRC
and the Environmental Protection Agency as to the level of residual radiation
that can remain on-site following decommissioning. Furthermore, the operation of nuclear power plants entails a
small but potentially catastrophic risk to surrounding communities from the
release of radioactive materials.
For these reasons, we assign a multiplier of 5 to nuclear
generation. This measure of nuclear
power’s on-site land impacts may understate the impact and risk to surrounding
communities. It is a preliminary approach.
To summarize, technologies are assigned the
following permanency multipliers:
very
low impact renewable technologies 0.25
biomass plants 0.50
certified
sustainable biomass 0.25
fossil
fuel combustion technologies 1.0
nuclear technologies 5.0
Applying the multiplier to the on-site land
scores produces the following land use scores:
FINAL SCORE
(BASE
SCORE) X
TECHNOLOGY SCORE (PERMANENCY)
Rooftop Solar PV 0
0.0
Gas combustion turbine 6 6.0
Natural gas combined cycle 3
3.0
Oil, steam electric
4
4.0
Coal, generic
5
5.0
Biomass (default) 10
5.0
PV, dedicated site 56 14.0
Geothermal 5 2.5
B. Off-Site Land Impacts:
Thermal and Solar Generation
Power Scorecard addresses the
off-site land impacts by adding the scores for i) solid waste and ii) fuel
acquisition (i.e., mining, processing and transportation) impacts. Solid waste
impacts are scored on the basis of net pounds of solid waste generated
per MWH. Scores for fuel acquisition
impacts are fuel-based and simply differentiate between renewable technologies,
various types of biomass facilities and fossil fuel/nuclear resources.
1. Solid Waste Impacts
Solid waste disposal can adversely impact
groundwater and land (for on-site or off-site landfill purposes). Land used for, and groundwater impacts from,
solid waste impacts are measured by pounds of waste produced (and disposed of)
per megawatt/hour.
The nine score for solid waste impacts is
based on the tons of waste produced by a coal facility using flue gas
desulfurization (FGD). Coal and biomass
facilities create the most significant amount of solid waste but differ among
themselves by size (MW), capacity factor, plant efficiency, fuel type and use
of flue gas desulfurization (FGD).
Solid waste impacts are scored on the basis
of net pounds of solid waste generated per MWH per year to account for
reuse of ash and FGD by-products.
SCORE LBS
OF SOLID WASTE GENERATED/MWH (NET)
0
none
1 <= 23.4
2 <=
46.8
3 <=
70.2
4 <=
93.6
5 <= 117.0
6 <= 140.5
7
<= 163.9
8
<= 187.3
9 <= 210.8
10
> 210.8
The mitigation of groundwater impacts is
captured by reducing by half the solid waste score for sites equipped with a
double liner conforming to state/federal guidelines.
Nuclear plants produce comparatively small
volumes of high-level and low-level radioactive wastes. When measured only on a volume/megawatt
hour, nuclear power would score relatively well on solid waste impacts. However, there are a succession of risks
inherent in nuclear waste, each of which could rate a severe (i.e., 10) impact
score. These risks include;
i. High-level radioactive waste
ii. Low-level radioactive waste
iii. Proliferation risks
iv. Transportation risks
Both high-level and low-level radioactive
wastes cannot be easily managed or disposed.
There is currently no location to permanently dispose of the high-level
radioactive waste contained in spent nuclear fuel pools and it is unlikely that
this issue will be resolved in the next decade. Any site would have to demonstrate that radioactive waste could
be isolated from the biosphere for at least 10,000 years. There is only one
location that is accepting low-level radioactive waste from nuclear power
plants throughout the country (Barnwell, South Carolina) and the future
availability of this site is in question. Given the high level of uncertainty
about how these wastes will be managed, there is the need to assign a
multiplier to the solid waste impact for nuclear power. We will assign a
multiplier of 3 to nuclear solid waste, leading to a total score of 30. This represents a very conservative
estimate of the relative impact of radioactive waste compared to other forms of
solid waste.
This scoring produces the following
representative solid waste scores for common generating facilities. No credit for double lined disposal
facilities or waste reuse has been incorporated in these scores.
SCORE TECHNOLOGY
0 solar
(distributed and central station PV)
1 natural
gas combined cycle
1 geothermal
2 oil
fired steam electric
4 coal
plant without flue gas desulfurization
10 coal
plant with FGD
30 nuclear
2. Fuel Acquisition Adjustment
Power Scorecard adds a fuel acquisition
score to the solid waste score for all thermal and solar technologies to
produce an off-site land score. Fuel
acquisition is scored by assigning either a zero or a four. Fossil fuel and nuclear facilities receive a
score of four to reflect fuel cycle impacts not imposed by renewable resource
based technologies -- i.e., the environmental impacts associated with fuel
mining, processing and transportation.
Coal acquisition impacts include the land use impacts of both strip
mining and underground mining, the impacts of coal cleaning, crushing, and the
impacts of coal transportation from the mine to power plant. Oil acquisition impacts include the impacts
of oil drilling, refining and transportation (including accidental spills).
Natural gas acquisition impacts include the impacts of gas drilling and
pipeline construction and operation. Nuclear fuel acquisition impacts include
those associated with fuel mining, processing, and transportation.
Power Scorecard also distinguishes
between biomass facilities that generate solid waste and those that reduce the
need for solid waste disposal. For those biomass plants that produce
electricity from biomass fuels that would otherwise be landfilled, we will use
a fuel cycle adjustment multiplier of 0.5 applied to the total solid waste
score.
This factor reduces the solid waste score for qualifying biomass facilities by
half, in recognition of the environmental benefit obtained by producing
valuable electricity from biomass wastes that would otherwise be destined for
landfill disposal.
We acknowledge that assigning a single
score for the acquisition impacts of most fossil fuel technologies and nuclear
generation does not recognize the variations that exist among these
technologies. Refinements to
distinguish the range of fuel cycle impacts among various fuels, unfortunately,
are unavailable. Cross-fuel data sets
that measure impacts consistently are also not currently available.
Determinations of fuel cycle impacts require complicated, difficult analysis.
The US Department of Energy and the European Community, with the technical
assistance of Oak Ridge National Laboratory and Resources for the Future, used
seven volumes to report their detailed assessment of the environmental costs of
total energy fuel cycle costs. Published
fuel cycle information is not readily transferable for use in this rating
system.
In addition,
impacts on air and human health are necessarily very sensitive to the
geographic location and the technology at the site. Yet generic information
offers only very gross assessments.
Probabilistic analysis of accidents, public health and biological risks
that are associated with the total coal and natural gas cycles are unavailable.
It is clear,
however, that fossil and nuclear generation impose fuel acquisition impacts
that renewable resources do not, and therefore it is necessary to incorporate
this differentiation into the scoring system.
C. Land Impacts: Wind and Hydro Generation
To create land scores that differentiate
among wind and hydro facilities, these two technologies are scored with
site-specific criteria. Scoring the
land impacts of these technologies with the same scales used for thermal plants
would distinguish them from the thermal technologies. Using these same criteria, however, would not create meaningful
distinctions among hydro facilities or among wind facilities and would not
account for the multiple uses that these sites (as opposed to thermal plant
sites) are capable of hosting.
1. Land Impacts of Wind Generation
Power Scorecard rates the land
impacts of wind plants by measuring the extent to which the facilities have
been sited pursuant to criteria for suitable siting. The criteria for scoring wind generation are summarized here.
LAND IMPACT SCORE CRITERIA
FOR
WIND TECHNOLOGIES
1 Wind
facility mostly suitable on seven siting criteria OR wind facility developed
and fully compliant with applicable state- or region-wide wind power
development guidelines developed through collaborative, multi-stakeholder
process and acknowledged as suitable by state environmental siting officials
3 Wind
facility mostly or moderately suitable on seven siting criteria OR site
developed pursuant to and fully compliant with a collaborative,
multi-stakeholder settlement process
5 Wind
facility mostly suitable in five or more categories, not least suitable in any
7 Wind
facility mostly suitable or moderately suitable in three or more categories;
not least suitable in any
10 Wind
not scored above.
Attachment D explains these criteria.
2. Land and Water Impacts from Hydro Generation
The land and water scores for hydro are
either tied to metrics that embody the diverse range of hydro plant impacts, or
scores are tied to the characteristics of ownership and last license that
reasonably represent these diverse impacts. Among hydro’s more significant
impacts are:
i) fish impacts - dams
may interrupt upstream and downstream movement of fish and other aquatic life
ii) river flows - dams
may interrupt traditional river flows necessary to maintain aquatic habitat
iii) water quality - dams may impose
thermal and nutrient stratification
iv) land use - dams may destroy habitat
Hydro facilities qualifying as “Low Impact Hydropower” score a four. Low Impact Hydropower facilities successfully meet the low impact
certification criteria established by the Low Impact Hydropower Institute. Low Impact Hydropower facilities impose fewer adverse aquatic and
terrestrial impacts by using environmental protections for fish, river flows,
water quality, habitat mitigation and recreational opportunities. The Low Impact Hydropower Institute’s
criteria and certification process are described in Attachment C.
Most other hydro facilities’ scores are based
on ownership and the date of their most recent Federal Energy Regulatory
Commission operating license. Because
facilities owned by non-federal entities that do not qualify as low impact
hydro but have been relicensed by FERC since 1986 generally have better
environmental conditions than older FERC-regulated facilities, they score
eight. Federally-owned facilities, not
subject to FERC licensing, that have been subject to an environmental
operations review since 1986 also score an eight because they tend to have
better environmental conditions than other facilities. Others score “10” for
water impacts in recognition of the potential for significant aquatic harm and
“15” for land impacts to account for the adverse and permanent impacts caused by reservoir creation.
SCORE OWNERSHIP
OR CERTIFICATION
0
4 Project
meets criteria required for certification as Low Impact Hydropower (Using
criteria in Attachment B)
8 Project
is non-federally owned with FERC Relicense since 1986 but does not qualify as
low impact hydro OR is federally-owned and has had an environmental operations
review since 1986
10
(water); 15 (land) others
Where federal or state government resource
management agencies have recommended that a hydro facility be removed because
of its severe ecological or dam safety impacts, the plant will be scored “20”.
The score derived from this set of questions
produces both water quality and land quality scores for all hydro
facilities. (The air quality score is
derived in the same manner as for other technologies -- generally a zero for
each of the four air criteria.) The
total score for a hydro facility is developed in the same fashion as the total
score for any generating technology -- by averaging the air, water and land scores. (See Scoring Environmental Impacts discussion, above.)
V. Adjustments for Purchases of New Renewable and
Environmentally Preferred Energy Resources
Power Scorecard provides a strong
inducement for service providers to invest in new, low-impact, naturally
reoccurring renewable and environmentally preferred energy facilities by
showing a second rating
for each product based on the size of such commitments. (See
Product Scoring section, below.)
Qualifying
new capacity (as determined per the definition adopted by the Center for
Resource Solutions' Green-e standard in a particular state/region)
will be counted from the time it is officially contracted, as long as the
capacity is scheduled for operation within 12 months of the contract. In the case of repowered capacity, only the
net increase in kilowatt-hours will be awarded this bonus. Verification that the resource has come
on-line in accordance with the schedule is required.
To qualify,
the resource must be scored at the facility rather than by default, and will
not qualify if it scores greater than 5 for any two of the eight rating
criteria or receives penalty points (e.g., geothermal plants adversely
affecting ground or surface water quality). Examples of renewable energy
sources include solar, wind, geothermal, and biomass. Landfill gas fueled
facilities may qualify as a low-impact environmentally preferred resource. New
hydropower facilities do not qualify as preferred new capacity.
VI. Data Collection
Rating the environmental quality of
electricity services depends on obtaining accurate information on the
environmental characteristics of the electricity supplies that service
providers generate or purchase to serve their customers. It invites service
provider cooperation and an opportunity to provide sufficient detail to support
claims of environmental quality. Electricity supplier responses to Power Scorecard data collection
questions are designed to be verifiable, usually by reference to statewide
databases, to ensure accuracy. Data collected will be subject to annual audit for
verification purposes.
VII. Product Scoring
There are two ways to score electricity
sources: 1) by assessing the actual performance qualities of the plants
providing electricity, or 2) by assigning default scores associated with known
technology characteristics of plants providing power. For any technology, the best scores may be obtained only by
providing evidence of the low impact qualities of the specific electricity
sources. The default scores assume that
the technologies perform poorly. Attachment
A provides the example default scores.
Calculating a weighted average of the eight
impact scores produces the final facility specific score. The weighted average
assigns a double weight to the Global Climate Change measure and single weights
to the other seven, for reasons explained above.
The overall Product Score is the weighted
average of the scores for the electricity supply resources that comprise the
product, weighted for the share each source contributes to the total
product. Products which have been on
the market for one year or more and which will continue to be offered without
significant change will be rated on the mix of resources delivered to a
customer’s “market area bulk power grid” over the past year (i.e., most recent
twelve months for which data is available). All other products will be rated
based on the mix of resources expected to be delivered to a customer’s “market
area bulk power grid” over the appropriate month period. Products delivered either as actual supply (trackable
deliveries) or as deliveries on a customer’s behalf are scored in the same
manner.
System power purchases from wholesalers with
unspecified supply arrangements and pool net interchange or other
undifferentiated market purchases are assigned power scores based on pool-wide
system averages, unless the wholesale supplier’s mix has been rated. When the
past year’s pool residual average is available, it can be used.
It is important, in states that may require
some form of environmental disclosure, to distinguish Power Scorecard product scores from
environmental product labels. A
product’s Power Scorecard score and
its disclosure label may not be based on the same combination of facilities or
the same time frame (i.e., the settlement period).
Six scoring categories have been identified
to assist customers in understanding Power
Scorecard scores: excellent, very good,
good, fair, poor and unacceptable.
The category designation for any product depends on the Power Scorecard score of the resources.
The scores required for placement in the
categories are:
Rating Required score
Excellent
1.5 or less
Very
Good >1.5 to 2.5
Good >2.5 to 3.9
Fair >3.9. to 5.5
Poor >5.5 to 7.0
Unacceptable
>7.0 ‑ 10+
Power Scorecard treats existing and
new facilities the same in the quantitative scoring of impacts, but it provides
a separate and distinct set of category ratings to highlight those products
that include a significant commitment to new renewable/environmentally
preferred energy facilities. The categories are determined by the percentage of
new renewables that comprise the product. For example, a product that contains
60% new renewables in the product mix would be assigned a category designation
of “VERY GOOD”.
The percentage of new renewables required for
placement in the categories are:
Rating Required Score
Excellent
=>75 % or more new renewables
Very
Good =>50% to <75% new renewables
Good => 35% to <50% new renewables
Fair => 15% to <35% new renewables
Poor >5% to <15% new renewables
Unacceptable
none to <5%
ATTACHMENT A
Technology Based Default Scores
You may obtain a score for an electricity
source by identifying the technology used at the plant to produce the
electricity you are purchasing to serve your customers.
Generally a better score may be obtained by
providing information on the actual characteristics of the plant using the
Facility Scoring Sheet. These default scores for technology types are provided
to allow scoring of products when relatively little environmental impact
information is available, or (on a prospective basis) resources have not yet
been procured.
These default scores represent
high impact applications allowed by regulation or law. Many facilities may earn scores reflecting
lower impact applications if they provide information demonstrating lower
impacts. The default scores are used
when other information is not available from the supplier or facility
owner/managers. The Power Scorecard searches for representative information on
plant design and operating characteristics, using default scores set forth
below when other verifiable information is not available.
When little is known about the technology, the highest score
among the options for that type will be awarded. For example, if the capacity is known to be oil fueled but
nothing more is known, a score of 6.2, for oil fueled steam electric
technology, will be selected.
Following the table are brief definitions of
the technologies for which default scores are provided:
Go to next page
Technology Types:
Coal-Fired
Steam Electric:
Make this selection for coal-fired electric
power. If evidence is available that the facility uses a low sulfur coal,
please provide the supporting information and select the appropriate entry for
low sulfur coal. If information is
available that the facility utilizes a flue gas desulfurization system, make
the appropriate selection below. The assumed heat rate is 10,500. The expected
lifetime is 30 years.
Coal-Fired
Steam Electric, with Flue Gas Desulfurization (high mercury content):
If information is available that the facility
utilizes a flue gas desulfurization system, please select this category. If
additional information exists regarding the mercury or sulfur content of the
coal, please provide the supporting documents and select the appropriate
category below. The assumed heat rate
is 10,500. The expected lifetime is 30 years.
Coal-Fired
Steam Electric, with Flue Gas Desulfurization (low mercury content):
Make this selection for coal, when
information is available regarding the existence of a flue gas desulfurization
system at the facility and supporting information about the mercury content and
emissions rate of mercury. The assumed
heat rate is 10,500. The expected lifetime is 30 years.
Biomass:
Wood Fueled Stoker (Default):
Make this selection for Biomass-fired
electric power supply. The default assumes no NOx control. It assumes a heat
rate of 13,900 and a lifetime of 30 years.
Biomass:
Wood Fueled Stoker (NOX controls):
If supporting information is available
regarding the utilization of NOX controls at the biomass facility,
please make this selection accompanied with data on the existence of NOX
controls. The assumed heat rate is 13,900. The expected lifetime is 30
years.
Biomass:
Wood Fueled, Low Impact:
Make this selection for Biomass that utilizes
a clean wood fuel supply and wood harvesting sources that subscribe to
sustainable harvesting practices. Supporting information is required
demonstrating the quality of the input fuel source and the protocol for wood
harvesting. The low impact assumes use of cooling tower technology.
Mass
Burn Municipal Waste:
Make this selection for any electric power
purchases from a waste-to-energy facility or refuse derived fuel facility. The
assumed heat rate is 16,373. The expected lifetime is 30 years.
Oil-Fired
Steam Electric (default):
Make this selection for electric power
purchases from an oil-fired, or gas/oil fired steam electric facility. If
information is available on the utilization of a low sulfur content oil please
choose the appropriate category below. The assumed heat rate is 10,500. The
expected lifetime is 30 years.
Oil-Fired
Steam Electric (1.0% sulfur content) or
Oil-Fired Steam Electric (0.5% sulfur content):
Make this selection for an oil-fired steam
electric facility, or, oil/gas fired steam electric facility that is
demonstrably burning a low-sulfur oil. The assumed heat rate is 10,500. The
expected lifetime is 30 years. A facility not providing documentation on the
use of a lower sulfur content oil will be given the Oil Fired Steam Electric
default of 2.2% sulfur content.
Gas-Fired
Steam Electric (default):
Make this selection for a gas-fired steam
electric facility. If information is available regarding the existence of NOX
controls at the facility supplying power, refer below to the lower NOX
gas-fired steam electric alternative. The assumed heat rate is 10,500. The
expected lifetime is 30 years.
Gas-Fired
Steam Electric with NOX Controls:
Make this selection for a gas-fired steam
electric facility with NOX controls. If information can be provided
regarding the employment of selective catalytic reduction technology, select
the appropriate alternative below. The assumed heat rate is 10,500. The
expected lifetime is 30 years.
Gas-Fired
Steam Electric (w/SCR and SWI):
Make this selection for a gas-fired steam
electric facility with selective catalytic reduction and steam water injection
control technology. The assumed heat rate is 10,500. The expected lifetime is
30 years.
Gas-Fired
Combined Cycle Power Plant:
Make this selection as the default for a
gas-fired combined cycle power plant. If information is available to establish
the admissibility of a low NOX (or higher heat rate) facility,
please submit the supporting materials and select the alternatives Gas-Fired Combined Cycle Power Plant (low NOX
facility). The assumed heat rate is 9,224. The expected lifetime is 30
years.
Oil-Fired
Combustion Turbine:
Use this option as the default for
electricity supplied from an oil-fired combustion turbine
The assumed heat rate is 13,600. The assumed
capacity factor is 10%.
Gas-Fired
Combustion Turbine:
Use this option as the default for
electricity supplied from a gas-fired combustion turbine. The assumed heat rate
is 14,520. The assumed capacity factor is 10%.
Landfill
Gas (default):
Select this alternative for electric power
supplies from a landfill gas to energy project. This option assumes the
utilization of an internal combustion engine (IC Engine, high NOx rate) with a
relatively high NOX rate. If
evidence is available that the technology employed is a simple-cycle gas
combustion turbine, or a boiler/steam turbine configuration, please select the
appropriate alternative below. The assumed heat rate is 12,000 Btu’s/kWh.
Landfill
Gas: Low Impact:
Select this alternative for electric power
supplies from a landfill gas to energy project that has a demonstrably low NOX
emissions.. Supply information on the NOX emissions rate of the
facility.
Hydro-Electric
Facility (default):
Use this alternative for hydro-electric power
supplies, If information is available regarding the projects ownership (federal
or private), its date of relicense, or more detail on the extensive mitigation
efforts, please provide the supporting information and select the appropriate
alternative below.
Hydro-Electric
Facility ( federally owned):
Use this alternative for hydro-electric power
supplies that are owned by the federal government (not subject to regulation by
the Federal Energy Regulatory Agency –FERC) and have been subject to a formal
review of the environmental impact of its operations sometime after 1986.
Hydro-Electric
Facility (FERC regulated, relicensed after 1986):
Make this selection for hydro-electric power
supplies that are regulated by FERC and have been relicensed after 1986.
Hydro-Electric
Facility (certified low-impact by the Low Impact Hydropower Institute program):
Use this alternative for hydro-electric power
supplies that have obtained certification as a low-impact hydro facility by the Low Impact Hydropower
Institute. See Attachment B for
information about this certification program.
Geothermal;
Flash Technology (default):
Select this alternative for all electric
power supply from geothermal power. If documentation is available that the
geothermal supply is from an alternative technology type (Binary technology or
low-impact geothermal flash technologies) please provide the documentation and
select the appropriate technology alternative.
Geothermal;
Binary Technology:
Make this selection for geothermal facilities
using Binary technology
Geothermal;
Low Impact:
Make this selection only if providing
documentation regarding the land use, water use and water quality
characteristics of the facility and mitigation measures in place to reduce land
and water use impacts.
Wind
Turbine Plant (default):
For electric power supply from a wind turbine
facility select this option. The default characterization is a poorly sited
wind turbine plant. If data is available to establish the admissibility of a
low land impact facility, please submit the supporting materials and select the
alternative Wind Turbine Plant (low land
impact)
Wind
Turbine Plant (low land impact):
If data is available to establish the
admissibility of a low land impact facility, please submit the supporting
materials and select the low land impact score.
Solar
Central Station PV (default):
Use this selection as the default for central
station PV. If detailed information is
available that justifies the admissibility of mitigated land impacts, please
submit the documentation and select the Solar Central Station PV (low land
impact) alternative below.
Solar
Distributed PV:
Select this option for distributed PV
utilizing such existing structures as rooftop PV, parking garage integrated PV
and other dual-use structures demonstrably eliminating the need for
dedicated land use.
Nuclear
Fuel Steam Electric:
Make this selection
for nuclear fueled steam-electric power. If the facility uses a closed cycle
cooling system, provide supporting information. If information is available on
the total site land use (acres per MW), report that with supporting
documentation. The expected lifetime of the default facility is 30 years.
ATTACHMENT C
CRITERIA FOR LOW IMPACT HYDRO FACILITIES
The following
summarizes the Low Impact Hydro Certification Program administered by the Low
Impact Hydropower Institute (“LIHI”).
For more information on this program contact the LIHI at telephone: (415) 561-2100
LOW IMPACT
HYDROPOWER CERTIFICATION PROGRAM
INTRODUCTION
< November 8, 1999 >
The Low Impact Hydropower Institute (“Institute”) has
established a Low Impact Hydropower Certification Program (“Certification
Program”) to certify hydropower facilities with impacts that are low compared
to other hydropower facilities based on objective environmental criteria. The Certification Program’s goals are to
reduce the environmental impacts of hydropower generation, and to create a
credible and accepted standard for consumers to use in evaluating
hydropower. For a hydropower facility
to be certified as low impact, objective certification criteria must be met in
the following eight areas: (1) river
flows, (2) water quality, (3) fish passage and protection, (4) watershed
protection, (5) threatened and endangered species protection, (6) cultural
resource protection, (7) recreation, and (8) facilities recommended for
removal. A hydropower facility meeting
the eight certification criteria will be certified as a Low Impact Hydropower
facility, and will be able to use this certification when marketing power to
consumers.
I. WHY CREATE A LOW IMPACT HYDROPOWER
CERTIFICATION PROGRAM?
In the new world of consumer choice being created through
electric power industry restructuring, environmentally preferable electric
power is one of the markets developing first.
From early evidence in California and Pennsylvania, energy from wind,
solar, geothermal, biomass and hydropower are attractive to many
consumers. But consumers often have
questions about the specifics of various generation sources, including
hydropower. What generation is
environmentally preferable and what is not?
For many knowledgeable consumers, hydropower raises
issues. They understand that hydropower
dams have both positive and negative environmental impacts. Hydropower dams provide public benefits such
as flood control, recreation, water supply, irrigation and the offset of fossil
fuel and other power sources that generate air pollution. But hydropower dams also have environmental
impacts, such as flooding river habitat, blocking fish passage, altering
natural flow cycles, and degrading water quality. If a dam is well sited and well operated, these environmental
impacts can be reduced, though not eliminated.
Consumers are seeking a credible means to determine which hydropower
facilities are well sited and well operated and thus provide the benefits of
the hydropower while minimizing the dam’s environmental impacts.
In states where the issue of distinguishing hydropower’s
benefits and impacts has been addressed legislatively, an interim solution used
(based on PURPA’s Qualifying Facility definition) is size. Small hydropower (less than an arbitrary
cutoff, usually 30 megawatts) is defined as renewable. But this size criterion is a poor indicator
of the environmental impacts of a hydropower facility. For example, small facilities that de-water
river reaches and block fish passage may be more environmentally destructive
than larger facilities designed and operated to reduce environmental
impacts. Under this size criterion, a
dam is either renewable or not – a small dam can be operated in a way that is
harmful to the environment and still be environmentally preferable, and a large
dam can undergo major changes to reduce the environmental impacts of its
operation and still not be considered environmentally acceptable.
In addition, a small hydro criterion automatically certifies
the majority of hydropower dams in
the country, but eliminates from consideration the majority of the country’s
hydropower capacity. Of the over 2,000 hydropower dams in the US
owned by entities other than the federal government, approximately 89% of the dams are “small” (less than 30 megawatts
capacity), but together they only provide only 8% of the hydropower capacity. The remaining 11% of the dams produce 92% of the hydropower
capacity. Thus, under the small hydro
approach, we are classifying as environmentally preferable a large number of
dams but not a large amount of power, and we are granting that preferred status
without any examination of the operation of those dams.
To respond to the need for an impact-based evaluation of
hydropower dams, the Low Impact Hydropower Institute has been established to
create a voluntary program to certify hydropower facilities with environmental
impacts that are low compared to other hydropower facilities based on objective
environmental criteria. This
distinction allows well sited and well operated hydropower dams to gain a
market advantage for the benefits that hydropower dams provide.
The Institute’s Certification Program evaluates the siting
and operation of hydropower dams based on objective environmental criteria. The Institute has identified eight key areas
that provide a reasonable approximation of the environmental impacts of a
facility. The Certification Program
establishes basic objective criteria for each of these eight areas. Because every dam and every river is
different, it is not possible for objective standards to delineate with 100%
accuracy all low impact hydropower facilities.
However, the Low Impact Hydropower criteria are a good means of
identifying those facilities whose siting and operation minimize the dam’s
environmental impacts.
II. PROGRAM GOALS AND OBJECTIVES
A.
Program Goals:
The Low Impact Hydropower Institute’s Certification Program
has two equally important fundamental goals: (1) Reducing the environmental
impacts of hydropower generation; by (2) Creating a credible and accepted
standard for consumers to use in evaluating hydropower.
1. Reduce the environmental
impacts of hydropower generation: A
goal of the Low Impact Hydropower Certification Program is to improve existing
conditions of natural resources affected by dams. The Low Impact Hydropower Certification Program will recognize
facilities that are sited and operated in a manner that reduces environmental
impacts, and will provide an incentive to other dam owners to change their
operations to reduce environmental impacts.
Certified facilities will at a minimum comply with applicable laws for
protection of fish, wildlife, water quality, endangered species and cultural
and recreational resources. In
addition, because these are environmental criteria, the level of environmental
protection will generally exceed current legal requirements, which often take
more than environmental concerns into account.
2. Create a credible and
accepted standard for consumers to use in evaluating hydropower: A goal of the Low Impact Hydropower
Certification Program is to create a credible and accepted standard for
consumers to use in evaluating hydropower.
The Certification Program will provide an independent and credible
evaluation of hydropower to create a product that is effectively differentiated
in the consumer marketplace for power.
The Certification Program must be credible with consumers, the
environmental community and the hydropower industry. To accomplish this, the Certification Program will be: (1) Based
on objective certification criteria with a scientific basis; (2) Administered
in a fair and efficient manner; and (3) Judged on applications that are open to
public review and comment.
B. Program Objectives:
To meet the two Program goals described
above, the Institute’s objective is to require hydropower certified facilities
to meet eight criteria related to: (1) River flows, (2) Water quality, (3) Fish
passage and protection, (4) Watershed protection, (5) Threatened and endangered
species protection, (6) Cultural resource protection, (7) Recreation, and (8)
Facilities recommended for removal. The
certification criteria have been designed with the recognition that if the
level of environmental protection is set too high, an insufficient amount of
power would be eligible for certification and thus the value of the program in
the emerging power market would be undermined.
If an effective market for low impact hydropower develops, the level of
environmental protection in the criteria is intended to increase over time,
consistent with the Institute’s recognition of the need for a robust
environmentally preferable power market.
III. CERTIFICATION CRITERIA:
The eight Low Impact Hydropower certification
criteria are described below. The
approach taken for setting the criteria is designed to establish objective
criteria while recognizing that conditions at every dam and on every river are
different. The criteria rely on formal
recommendations of expert government agencies whose mandates are to protect the
resources the criteria are designed to evaluate. Thus, for most criteria the hydropower facility must meet the
latest and most stringent recommendation of the relevant state or federal
resource agencies. To accommodate situations
where appropriate resource agency recommendations do not exist, the criteria
establish other objective criteria to meet the same goals. If a facility meets the requirements under
all eight of the criteria, the facility will be certified as Low Impact
Hydropower. A facility failing on one
or more of the criteria will not be certified.
The criteria do not apply to new hydropower facilities, hydropower
facilities outside of the United States, and pumped storage facilities. For the specific criteria requirements, see
the Low Impact Hydropower criteria in Part VI below.
1. Flows: The Flows
Criterion is designed to ensure that the river has healthy flows for fish,
wildlife and water quality, including seasonal flow fluctuations where
appropriate. For instream flows, a
certified facility must comply with recent resource agency recommendations for
flows, or meet one of two alternative standards to demonstrate that flows are
appropriately protective of water quality, fish and wildlife.
2. Water Quality: The
Water Quality Criterion is designed to ensure that water quality in the river
is protected. The Water Quality
Criterion has two parts. First, an
Applicant must demonstrate that the facility is in compliance with state water
quality standards, either through producing a recent Clean Water Act Section
401 certification or providing other demonstration of compliance. Second, an applicant must demonstrate that
the facility has not contributed to a state finding that the river has impaired
water quality under Clean Water Act Section 303(d). Subject to approval by the Governing Board, beginning in 2002, an
Applicant will also have to demonstrate that the facility has a program for
monitoring water quality.
3. Fish Passage and Protection:
The Fish Passage and Protection Criterion is designed to ensure that,
where necessary, the facility provides effective fish passage for riverine,
anadromous and catadromous fish, and protects fish from entrainment. For riverine, anadromous and catadromous
fish, a certified facility must be in compliance with both recent mandatory
prescriptions regarding fish passage and recent resource agency recommendations
regarding fish protection. If
anadromous or catadromous fish historically passed through the facility area but
are no longer present, the facility will pass this criterion if the Applicant
can show both that the fish are not extirpated or extinct in the area due in
part to the facility and that the facility has made a legally binding
commitment to provide any future fish passage recommended by a resource
agency. When no recent fish passage
prescription exists for anadromous and catadromous fish, the Applicant must
demonstrate either that there was a recent decision that fish passage is not
necessary for a valid environmental reason, or that existing fish passage
survival rates at the facility are greater than 95% over 80% of the run.
4. Watershed Protection:
The Watershed Protection criterion is designed to ensure that sufficient
action has been taken to protect, mitigate and enhance environmental conditions
in the watershed. A certified facility
must be in compliance with resource agency and Federal Energy Regulatory
Commission (“FERC”) recommendations regarding watershed protection, mitigation
or enhancement. Subject to approval by
the Governing Board, beginning in 2002, an Applicant must demonstrate that the
facility has sufficiently protected, mitigated or enhanced environmental
conditions in the watershed through meeting one of four requirements for watershed
protection, all of which involve either protecting, mitigating or enhancing
watershed land or spending or dedicating funds for conservation purposes.
5. Threatened and Endangered Species Protection: The Threatened and Endangered Species
Protection Criterion is designed to ensure that the facility does not
negatively impact state or federal threatened or endangered species. For threatened and endangered species
present in the facility area, the Applicant must either demonstrate that the
facility does not negatively affect the species, or demonstrate compliance with
the species recovery plan and receive long term authority for a “take” (damage)
of the species under federal or state laws.
6. Cultural Resource Protection: The Cultural Resource Protection Criterion is designed to ensure
that the facility does not inappropriately impact cultural resources. Cultural resources must be protected either
through compliance with FERC license provisions, or through development of a
plan approved by the relevant state or federal agency.
7. Recreation: The
Recreation Criterion is designed to ensure that the facility provides access to
the water and accommodates recreational activities on the public’s river. A certified facility must be in compliance
with terms of its FERC license or exemption related to recreational access,
accommodation and facilities. If not
FERC-regulated, a certified facility must be in compliance with similar
requirements as recommended by resource agencies. A certified facility must also provide access to water without
fee or charge.
8. Facilities
Recommended for Removal: The
Facilities Recommended for Removal Criterion is designed to ensure that a
facility is not certified if a natural resource agency concludes it should be
removed. If a resource agency has
recommended removal of a dam associated with the facility, certification is not
allowed.
IV. CERTIFICATION PROCESS
Certification under the low Impact Hydropower Program is
designed to be a fair and efficient process for determining whether a
hydropower facility has low environmental impacts. An Applicant fills out a certification questionnaire, attaches
supporting information and forwards the completed application to the Low Impact
Hydropower Institute. Early emphasis of
the Certification Program will be on facilities in New England and the Pacific
Northwest, although applications will be accepted for certification of
facilities in other regions. The
Certification Administrator posts the complete application on the Institute’s
Web page for a 60-day public comment period, and forwards the full application
package (with any public comments) to the Application Reviewer. The Application Reviewer reviews the
package, conducts any factual investigation needed to resolve factual disputes
and evaluate the veracity of claims, and returns the application to the
Certification Administrator with a certification recommendation. The Institute’s Governing Board makes a
preliminary certification decision, which is posted on the Institute’s Web page
for 30 days. If no appeal is requested
by either the Applicant, or by any member of the public who commented on the
application package, the decision becomes final. Any appeals are referred to the Institute’s Appeals Panel for
review. Certification decisions from
the Appeals Panel are referred to the Governing Board, which approves the
Appeals Panel’s certification decision.
A summary of the structure of the Low Impact Hydropower Institute is
found in Part II, and the certification procedures are in Part III.
V. MARKETING
In order to protect the consumer and provide the greatest
degree of credibility for the Low Impact Hydropower Certification Program, all
marketing claims associated with Low Impact Hydropower certification must meet
the requirements established for the Certification Program. These requirements can be found in Part V.
VI. LIMITATIONS OF THE LOW IMPACT
HYDROPOWER CERTIFICATION PROGRAM
The Low Impact Hydropower criteria have been established as
relatively simple objective criteria for distinguishing hydropower in the
marketplace. These criteria should not,
however, be considered a benchmark for exemplary environmental operations at
hydropower facilities. While the
criteria are intended to be a national base for evaluating impacts of
hydropower, not all environmental impacts associated with hydropower facilities
are addressed by the criteria. In
addition, while the reliance on resource agency recommendations is designed to
create an objective system based on scientific evidence that takes into account
site-specific conditions, any specific facility may have unique conditions that
require more or less stringent conditions for environmental protection. Thus, supporters of the Low Impact
Hydropower criteria, officers and staff of the Low Impact Hydropower Institute
and recipients of Low Impact Hydropower certification reserve the right to seek
conditions other than those outlined in the Low Impact Hydropower criteria in
any legal or administrative proceeding.
Support of the Low Impact Hydropower Certification Program
or of the Low Impact Hydropower criteria also does not imply endorsement of any
facility certified pursuant to the Certification Program or any resulting power
product. Supporters of the Low Impact
Hydropower criteria, and officers and staff of the Low Impact Hydropower
Institute, reserve the right to individually endorse or otherwise comment upon
facilities receiving Low Impact Hydropower certification and resulting power
products. In addition, support of the
Low Impact Hydropower Certification Program or of the Low Impact Hydropower
criteria does not imply endorsement of any level of power consumption. Supporters of the Low Impact Hydropower
criteria, and officers and staff of the Low Impact Hydropower Institute,
reserve the right to promote energy conservation as an alternative to power
generation.
The term Low Impact Hydropower should not imply that a
certified facility has no environmental impacts. Not all environmental impacts associated with hydropower
facilities are addressed by the criteria.
In addition, the certification of some facilities as Low Impact
Hydropower does not mean and should not imply that the Low Impact Hydropower
Institute or its supporters, officers or staff are labeling other hydropower
facilities as high impact.
The Low Impact Hydropower Certification Program is also
intended only to aid in differentiating the environmental performance among
hydropower facilities. The Institute
certifies facilities whose impacts are low compared to other hydropower
facilities based on objective scientific environmental criteria. As discussed above, this certification is
being provided in order to allow well cited and well operated hydropower
facilities to gain market advantage because of the benefits that hydropower
provides compared to some other power sources.
However, the certification does not compare hydropower generation
impacts to the impacts of other forms of power production because the impacts
of hydropower are not strictly comparable, in the Institute’s view, to the
impacts of other generation sources.
The Low Impact Hydropower criteria and other Certification
Program requirements are subject to change by the Institute’s Governing
Board. While no significant changes to
the Certification Program requirements are anticipated before the scheduled
phase-in of water quality monitoring and watershed protection requirements in
2002, the Governing Board reserves the right to modify the criteria and other
Certification Program requirements as needed.
