Costs of Keeping the Lights On

“We want to develop a plan that makes sense for New Mexico,” Rita Bates, planning section chief for the NMED air quality bureau, tells SFR.

“That is why we’re developing a state implementation plan rather than having a federal implementation plan imposed on the state, which is one of the other alternatives if we don’t comply,” says Michael Vonderheide, Environmental Protection Division director. “That’s not a risk we’re willing to take.”

NMED is hosting a series of public meetings, the first of which was held at the Southside Public Library in Santa Fe on Wednesday afternoon, in which New Mexicans can ask questions and voice their priorities. It’s taken some time to get to the point of seeking public input, as state staff have sifted through the 1,500-page rule, which was accompanied by technical support documents and spreadsheets. They’re specifically seeking opinions on questions of reliability, cost and fairness.

“When you do reliability and cost, that’s exactly what we can’t say, because it’s a spectrum, and we’re learning from the public about where to land on that spectrum. We’re definitely in the input and data-gathering phase of it,” says Allison Scott Majure, the department spokeswoman. “Fairness, of course, we want to land smack dab in the middle. It can be subjective depending on which special interest group you’re a member of, though.”

The EPA gives the state the option to craft its own plan and choose the rate by which to set emissions based on total tons of carbon dioxide emitted each year, known as a mass-based plan, or on pounds emitted per megawatt of electricity generated, a rate-based plan. New Mexico emitted just under 18 million short tons of carbon dioxide in 2012, and was given a goal of 12.4 million tons of CO2 emissions total, or 1,146 pounds per megawatt hour, by 2030.

“I think some options could be higher or lower cost, depending on how you write them into your plan, and I think we need to be cognizant that New Mexico is not a wealthy state,” Bates says. “We’ve got a lot of vulnerable populations. so we need to be aware of that in writing plans and in whatever we do.”

The bulk of the state’s emissions come from the San Juan Generating Plant in the northwestern corner of the state, which emits some 13 million tons of carbon dioxide each year—more than the entire state will be allotted after 2022. There are already plans in place to take two of the four units off-line by 2017.

States are given until September 2016 to draft a plan, with an optional two-year extension as long as progress and outreach efforts can be demonstrated. Then, they have until 2022 to begin implementing interim goals by 2029 and final goals by 2030. Should New Mexico fail to come forward with an acceptable plan to meet these goals by the deadline, the federal government will craft one for the state. That kind of plan would, Majure said, “lose the nuances.”

“The only decision we have already made is that we’re going to develop a plan,” says Bates. “So we will be writing a plan for New Mexico. We haven’t decided yet what’s going to be in that plan.”

NMED has set up a Clean Power Plan team to head the effort. They're charged to craft a plan specific to the state’s wants and needs, and expect to submit information on where the state is headed by the 2016 deadline, but would likely request an extension for the final plan. The New Mexico Environmental Improvement Board and the US EPA also both have to approve that final plan.

The federal guideline allows for “trading” emissions with other states to approach the balance, or even develop a multistate plan, and for the use of energy efficiency measures to help meet the goal. How states will sort out questions like who gets credit for renewable power generated in one state but used in another remains to be seen. So far, Bates says, it seems the EPA is simply suggesting states work it out amongst themselves.

Various stakeholders will have a chance to participate in the process by requesting meetings, submitting their own analyses of the information available and commenting on drafts.

“As you go through this process, do certain parties that are stakeholders in this process have a closer position at the table?” Positive Energy Solar’s Regina Wheeler asked during the Wednesday meeting. She clarified: Specifically, does PNM have a closer seat to the table?

“Obviously, we’re talking to the utilities,” Bates said, adding, “We’re not listening to just one opinion on this, absolutely not. We’re listening to everyone.”

They’ll also be aiming their efforts so compliance happens when it counts—reductions in emissions that could occur well before the plan is even finalized by 2018 or 2019, if the EPA takes the full 12 months allotted to approve the plan, might not even count in meeting the goal.

Of course, there’s murkiness on the horizon just looking as far as state-level planning for energy through the end of Gov. Susana Martinez’ term.

“It’s just hard to understand how the state is approaching this, particularly in the context of the state energy plan, in a way that’s going to really result in meeting the Clean Power Plan,” says Ben Shelton, political and legislative director for Conservation Voters New Mexico, a statewide nonprofit. “It’s going to be very, very difficult if a lot of the things that the governor outlined in the state energy plan get executed.”

“The state energy plan certainly props up coal heavily, which is, frankly, a dying resource,” says Liliana Castillo, communications and outreach manager for Conservation Voters New Mexico and CVNM Education Fund. “So the question becomes, how can we both comply with the Clean Power Plan as well as implement things that are in the state energy plan?”

There’s also work to be done in reaching out to low-income communities that often live much closer to where natural resources are mined and burned.

“Carbon pollution from coal-fired power plants disproportionately impacts New Mexico’s Latino, Native, low-income and rural populations,” Demis Foster, executive director of CVNM, said in a statement. “Communities in western New Mexico continue to experience negative health effects from legacy uranium mining waste.”

Foster points to the CPP’s effort to engage low-income communities and communities of color as they develop plans, adding that there are incentives for those efforts.

There’s also a question of the cooperation businesses will or will not promise the state.

“If, for instance, San Juan decides to do something like re-up, sign a new purchasing agreement because that could potentially knock us out of compliance,” Shelton says. “The onus falls on the PRC to put something in place that will grant some certainty to folks in the Environment Department to know that, OK, we’re not going to put together a compliance plan that’s rate or mass based that’s going to be thrown out of alignment based on PNM’s next business decision.”

The next public-input meeting is at 4 pm Thursday, Nov. 19 in Albuquerque. View more information at www.env.nm.gov/aqb/CPP.htm or email questions to NMENV-NMCPP@state.nm.us or call 476-4300. Subsequent meetings are planned for Las Vegas, Roswell, Las Cruces and Farmington.