NIPSCO settles with EPA

Clean Power Plan Rollback signals EPA's shift to inside-the-fence efficiency at coal plants, emphasizing heat-rate improvements over sector-wide decarbonization, renewables, natural gas switching, demand-side efficiency, and carbon capture under Clean Air Act constraints.

Key Points

A policy shift by the EPA to replace broad emissions rules with plant-level efficiency standards, limiting CO2 cuts.

✅ Inside-the-fence heat-rate improvements at coal units

✅ Potential CO2 cuts limited to about 6% per plant

✅ Alternatives: fuel switching, renewables, carbon capture

President Barack Obama’s signature plan to reduce carbon dioxide emissions from electrical generation took years to develop and touched every aspect of power production and use, from smokestacks to home insulation.

The Trump administration is moving to scrap that plan and has signaled that any alternative it might adopt would take a much less expansive approach, possibly just telling utilities to operate their plants more efficiently.

That’s a strategy environmentalists say is almost certain to fall short of what’s needed.

The Trump administration is making "a wholesale retreat from EPA’s legal, scientific and moral obligation to address the threats of climate change," said former Environmental Protection Agency head Gina McCarthy, the architect of Obama’s Clean Power Plan.

President Donald Trump promised to rip up the initiative, echoing an end to the 'war on coal' message from his campaign, which mandated that states change their overall power mix, displacing coal-fired electricity with that from wind, solar and natural gas. The EPA is about to make it official, arguing the prior administration violated the Clean Air Act by requiring those broad changes to the electricity sector, according to a draft obtained by Bloomberg.

Possible Replacements

Later, the agency will also ask the public to weigh in on possible replacements. The administration will ask whether the EPA can or should develop a replacement rule -- and, if so, what actions can be mandated at individual power plants, though some policymakers favor a clean electricity standard to drive broader decarbonization.

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Such changes -- such as adding automation or replacing worn turbine seals -- would yield at most a 6 percent gain in efficiency, along with a corresponding fall in greenhouse gas emissions, according to earlier modeling by the Environmental Protection Agency and other analysts. That compares to the 32 percent drop in emissions by 2030 under Obama’s Clean Power Plan.

"In these existing plants, there’s only so many places to look for savings," said John Larsen, a director of the Rhodium Group, a research firm. "There’s only so many opportunities within a big spinning machine like that."

EPA Administrator Scott Pruitt outlined such an "inside-the-fence-line" approach in 2014, later embodied in the Affordable Clean Energy rule that industry groups backed, when he served as Oklahoma’s attorney general. Under his blueprint, states would set emissions standards after a detailed unit-by-unit analysis, looking at what reductions are possible given "the engineering limits of each facility."

The EPA has not decided whether it will promulgate a new rule at all, though it has also proposed new pollution limits for coal and gas plants in separate actions. In a forthcoming advanced notice of proposed rulemaking, the EPA will ask "what inside-the-fence-line options are legal, feasible and appropriate," according to a document obtained by Bloomberg.

Increased efficiency at a coal plant -- known as heat-rate improvement -- translates into fewer carbon-dioxide emissions per unit of electric power generated.

Under Obama, the EPA envisioned utilities would make some straightforward efficiency improvements at coal-fired power plants as the first step to comply with the Clean Power Plan. But that was expected to coincide with bigger, broader changes -- such as using more cleaner-burning natural gas, adding more renewable power projects and simply encouraging customers to do a better job turning down their thermostats and turning off their lights.

Obama’s EPA didn’t ask utilities to wring every ounce of efficiency they could out of coal-fired power plants because they saw the other options as cheaper. A plant-specific approach "would be grossly insufficient to address the public health and environmental impacts from CO2 emissions," Obama’s EPA said.

That approach might yield modest emissions reductions and, in a perverse twist, might event have the opposite effect. If utilities make coal plants more efficient -- thereby driving down operating costs -- they also make them more competitive with natural gas and renewables, "so they might run more and pollute more," said Conrad Schneider, advocacy director for the Clean Air Task Force.  

In a competitive market, any improvement in emissions produced for each unit of energy could be overwhelmed by an increase in electrical output, and debates over changes to electricity pricing under Trump and Perry added further uncertainty.

"A very minor heat rate improvement program would very likely result in increased emissions," Schneider said. "It might be worse than nothing."

Power companies want to get as much electricity as possible from every pound of coal, so they already have an incentive to keep efficiency high, said Jeff Holmstead, a former assistant EPA administrator now at Bracewell LLP. But an EPA regulation known as “new source review” has discouraged some from making those changes, for fear of triggering other pollution-control requirements, he said.

"If EPA’s replacement rule allows companies to improve efficiency without triggering new source review, it would make a real difference in terms of reducing carbon-dioxide emissions," Holmstead said.

Modest Impact

A plant-specific approach doesn’t have to mean modest impact.

"If you’re thinking about what can be done at the power plants by themselves, you don’t stop at efficiency tune-ups," said David Doniger, director of the Natural Resources Defense Council’s climate and clean air program. "You look at things like switching to natural gas or installing carbon capture and storage."

Requirements that facilities use carbon capture technology or swap in natural gas for coal could actually come close to hitting the same goals as in Obama’s Clean Power Plan -- if not go even further, Schneider said. They just would cost more.

The benefit of the Clean Power Plan "is that it enabled states to create programs and enabled companies to find a reduction strategy that was the most efficient and made the most sense for their own content," said Kathryn Zyla, deputy director of the Georgetown Climate Center. "And that flexibility was really important for the states and companies."

Some utilities, including Houston-based Calpine Corp., PG&E Corp. and Dominion Resources Inc., backed the Obama-era approach. And they are still pushing the Trump administration to be creative now.

"The Clean Power Plan achieved a thoughtful, balanced approach that gave companies and states considerable flexibility on how best to pursue that goal," said Melissa Lavinson, vice president of federal affairs and policy for PG&E’s Pacific Gas and Electric utility. “We look forward to working with the administration to devise an alternative plan for decarbonizing the U.S. economy."

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Iran Renewable Energy Strategy targets productivity first, then wind power expansion, investment, and exports, overcoming US sanctions, banking and forex limits, via private sector partnerships, precise wind maps, and regional grid interconnections.

Key Points

A policy prioritizing efficiency, wind deployment, and investor access while navigating US sanctions and currency limits.

✅ Prioritize efficiency, then scale wind generation capacity

✅ Leverage private sector, rial contracts, attract foreign capital

✅ Map high-wind corridors: Zabol, Khaf, Doroud; target exports

Deputy Energy Minister on Renewable Energies Affairs says the U.S. sanctions have currently affected the economic, banking and forex sectors of the country as the country‘s medicine is under sanctions and it means renewable energies are also under sanctions, and, globally, pandemic disruptions have compounded pressures on supply chains.

Speaking in a press conference yesterday, Mohammad Satkin said leading countries first focus on productivity then they turn to electricity production and the ministry in the first step has focused on productivity then on renewables, noting that renewables are now the cheapest new power in many regions, reiterating that the ministry will use all existing potentials in this regard especially in utilizing wind.

He added that the ministry is doing its best that the country would become the hub in the region for rush of investors and those who want take advantage of Iran’s experience in renewables, as markets like the U.S. scale renewables to a quarter of generation in coming years.

Satkin added that in the eastern part, the country has the biggest windy fields with capacity over 40mw. So the ministry is doing its best with full support of the private sector in equipping and investing in this field to carry out new policies.

He noted that in the past 12 years, wind potentials of the country have been under study, noting that country has three special channels in the east as one of them is north of Zabol which is very valuable in terms of energy and it has capability for construction of 2 to 3mw power station.

Satkin further said Khaf channel is the other one which has one of the most unique winds in the world, while Saudi wind expansion underscores regional momentum, and it can be developed for over 1000mw station. The windy region of Doroud is the third channel where the 50mw project has been kicked off there and it has capability for construction of some thousand-megawatt wind power station.

He added that Iran has prepared one of the most precise maps and it has even identified the border regions like with Afghanistan and perhaps in the future, Iran and Afghanistan may launch a joint project as Iran has enough expertise to offer its neighboring countries and as IRENA's decarbonisation roadmap highlights wider socio-economic benefits.

On signing agreement with foreign companies, Satkin said the ministry pays the sum of all contracts with domestic companies is paid in national currency rial as it is unable to pay in dollar or other currencies but Iranian companies may enjoy having foreign backings, including initiatives like ADFD-IRENA funding that support developing markets, and the ministry tries to attract foreign capital.

He also pointed to exports of renewables, adding that the government has authorized export of renewable energy but it needs proper planning to be assured of electricity production in order to export it to the neighboring states whenever they need, especially as Ireland targets over one-third green power within a few years.

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Municipal Renewable Energy Procurement surged as cities contracted 3.7 GW of solar and wind, leveraging green tariffs, community solar, and utility partnerships across the Southeast, led by Houston, RMI, and WRI data.

Key Points

The process by which cities contract solar and wind via utilities or green tariffs to meet climate goals.

✅ 3.7 GW procured in 2020, nearly 25% year-over-year growth

✅ Houston runs city ops on 500 MW solar, a record purchase

✅ Southeast cities use green tariffs and community solar

Cities around the country bought more renewable energy last year than ever before, reflecting how renewables may soon provide one-fourth of U.S. electricity across the grid, with some of the most remarkable projects in the Southeast, according to new data unveiled Thursday.

Even amid the pandemic, about eight dozen municipalities contracted to buy nearly 3.7 gigawatts of mostly solar and wind energy — enough to power more than 800,000 homes. The figure is almost a quarter higher than the year before.

Half of the cites listed as “most noteworthy” in Thursday’s release —  from research groups Rocky Mountain Institute and World Resources Institute — are in the region that stretches from Texas to Washington, D.C. 

Houston stands out for the sheer enormity of its purchase: In July, it began powering city operations entirely from nearly 500 megawatts of solar power — the largest municipal purchase of renewable energy ever in the United States, as renewable electricity surpassed coal nationwide.

The groups also feature smaller deals in North Carolina and Tennessee, achieved through a utility partnership called a green tariff.

“We wanted to recognize that Nashville and Charlotte were really blazing a new trail,” said Stephen Abbott, principal at the Rocky Mountain Institute.

And the nation’s capital shows how renewable energy can be a source of revenue: It’s leasing out its public transit station rooftops for 10 megawatts of community solar.

All of these strategies will be necessary for scores of U.S. cities to meet their ambitious climate goals, researchers believe. An interactive clean energy targets tracker shows all 95 clean energy procurements from the year in detail.

Tracker 
Even before former President Donald Trump promised to remove the United States from the Paris Climate Accord, a lack of federal action on climate left a void that some cities and counties were beginning to fill, as renewables hit a record 28% in a recent month. In 2015, the first year tracked by researchers at the Rocky Mountain Institute and the World Resources Institute, municipalities contracted to buy more than 1 gigawatt of wind, solar and other forms of clean energy. 

But when Trump officially set in motion the withdrawal from the climate agreement, the ranks of municipalities dedicated to 100% clean energy multiplied. Today there are nearly 200 of them. The growth in activity last year reflects, in part, that surge of new pledges.

“It takes a while to get city staff up to speed and understand the options, and create the roadmap and then start executing,” Abbott said. “There is a bit of a lag, but we’re starting to see the impact.”

Even in Houston — one of the earliest to begin procuring renewable energy — there has been a steep learning curve as market forces change and prices drop, including cheaper solar batteries shaping procurement strategies, said Lara Cottingham, Houston’s chief of staff and chief sustainability officer.

No matter how well resourced and educated their staff, cities have to clear a thicket of structural, political and economic challenges to procure renewable energy. Most don’t own their own sources of power. Nearly all face budget constraints. Few have enough land or government rooftops to meet their goals within city limits.

“Cities face a situation where it’s a square peg in a round hole,” Cottingham said.

The hurdles are especially steep in much of the Southeast, where only publicly regulated utilities can sell electricity to retail customers, even large ones such as major cities. That’s where a green tariff regime comes in: Cities can purchase clean energy from a third party, such as a solar company, using the utility as a go-between.

Early last year, Charlotte became the largest city to use such a program, partnering with Duke Energy and two North Carolina solar developers to build a solar farm 50 miles north in Iredell County. At first, the city will pay a premium for the energy, but in the latter half of the 20-year contract, as gas prices rise, it will save money compared to business as usual.

“Over the course of 20 years, it’s projected we would save about $2 million,” Katie Riddle, sustainability analyst with Charlotte, told the Energy News Network last year.

The growing size of projects, innovative partnerships like green tariff programs, and the improving economics all give Abbott hope that renewable energy investments from cities will only grow — even with the Trump presidency over and the country back in the Paris agreement.

And when cities meet their goals for procuring renewable energy for their own operations, they must then turn to an even bigger task: reducing the carbon footprint of every person in their jurisdiction with broader decarbonization strategies and community engagement.

“The city needs to do its part for sure,” said Houston’s Cottingham. “Then we have this challenge of how do we get everyone else to.”

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New England Grid Reform Initiative aligns governors with ISO New England to reshape market design, boost grid reliability, accelerate renewable energy and offshore wind, explore carbon pricing and forward clean energy markets, and bolster accountability.

Key Points

Five states aim to reform ISO New England markets, prioritize renewables and reliability, and test carbon pricing.

✅ Governors seek market design aligned with clean energy mandates

✅ ISO-NE accountability and stakeholder engagement prioritized

✅ Explore carbon pricing and forward clean energy market options

Weeks after initiating a broad overhaul of utility regulation within its borders, Connecticut has recruited four New England states, as Maine debates a 145-mile transmission line project to rework the regional grid that is overseen by ISO New England, the independent system operator charged with ensuring a reliable supply of electricity from power plants.

In a written statement Thursday morning, Gov. Ned Lamont said the current structure “has actively hindered” states’ efforts to phase out polluting power plants in favor of renewable sources like wind turbines and solar panels, while increasing costs “to fix market design failures” in his words. Lamont’s energy policy chief Katie Dykes has emerged as a vocal critic of ISO New England’s structure and priorities, in her role as commissioner of the Connecticut Department of Energy and Environmental Protection.

“When Connecticut opted to deregulate our electricity market, we wanted the benefits of competition — to achieve lower-cost energy, compatible with meeting our clean-energy goals,” Dykes said in a telephone interview Thursday afternoon. “We have a partner [in] ISO New England, to manage this grid and design a market that is not thwarting our clean-energy goals, but achieving them; and not ignoring consumers’ concerns. ... That’s really what we are looking to do — reclaim the benefits of competition and regional cooperation.”

Lamont and his counterparts in Massachusetts, Rhode Island, Vermont and Maine plan to release a “vision document” in their words on Friday through the New England States Committee on Electricity, after New Hampshire rejected a Quebec-Massachusetts transmission proposal that sought to import Canadian hydropower.

The initial documents made no mention of New Hampshire, which likewise obtains electricity through the wholesale markets managed by ISO New England and has seen clashes over the Northern Pass hydropower project in recent years; and whose Seabrook Station is one two nuclear power plants in New England alongside Dominion Energy’s Millstone Power Station in Waterford. Gov. Chris Sununu’s office did not respond immediately to a query on why New Hampshire is not participating.

Connecticut and the four other states outlined a few broad goals that they will hone over the coming months. Those include creating a better market structure and planning process supporting the conversion to renewables; improving grid reliability, with measures such as an emergency fuel stock program considered; and increasing the accountability of ISO New England to the states and by extension their ratepayer households and businesses.

ISO New England spokesperson Matt Kakley indicated the Holyoke, Mass.-based nonprofit will “engage with the states and our stakeholders” on the governors’ proposal, in an email response to a query. He did not elaborate on any immediate opportunities or challenges inherent in the governors’ proposal.

“Maintaining reliable, competitively-priced electricity through the clean energy transition will require broad collaboration,” Kakley stated. “The common vision of the New England governors will play an important role in the discussions currently underway on the future of the grid.”

Renewable revolution
ISO New England launched operations in 1999, running auctions through which power plant operators bid to supply electricity, including against long-term projections for future needs that can only be met through the construction or installation of new generation capacity.

ISO New England falls under the jurisdiction of the Federal Energy Regulatory Commission rather than the states whose electricity supplies it is tasked with ensuring. That has led to pointed criticism from Dykes and Connecticut legislators that ISO New England is out of touch with the state’s push to switch to renewable sources of electricity.

Entering October, ISO New England published an updated outlook that revealed 60 percent of proposed power generators in the region’s future “queue” are wind farms, primarily offshore installations like the proposed Park City Wind project of Avangrid and Revolution Wind from Eversource. But Dykes recently criticized as unnecessary an NTE Energy plant approved already by ISO New England for eastern Connecticut, which will be fueled by natural gas if all other regulatory approvals are granted.

The six New England states participate in the Regional Greenhouse Gas Initiative that caps carbon emissions by individual power plants, while allowing them to purchase unused allowances from each other with that revenue funneled to the states to support renewable energy and conservation programs. FERC is now considering the concept of carbon pricing, which would levy a tax on power plants based on their emissions, and it also faces pressure to act on aggregated DERs from lawmakers.

ISO New England is investigating the concepts of net carbon pricing and a “forward clean energy market” that would borrow elements of the existing forward capacity market, but designed to meet individual state objectives for the percentage of renewable power they want generated while ensuring adequate electricity is in place when weather does not cooperate.

The Connecticut Public Utilities Regulatory Authority is collecting on its own initiative industry input on modernization proposals, as New York regulators open a formal review of retail energy markets for comparison, that would add up to hundreds of millions of dollars, including utility-scale batteries to store power generated by offshore wind farms and solar arrays; and “smart” meters in homes and businesses to help electricity customers better manage their power use.

The New England Power Pool serves as a central forum for plant operators, commercial users and others like the Connecticut Office of Consumer Counsel, amid Massachusetts solar demand charge debates that affect distributed generation policy, with NEPOOL’s chair stating Thursday morning the group was still reviewing the governors’ announcement.

“NEPOOL has been engaged this year in meetings ... exploring the transition to a future grid in New England and potential pathways forward to support that transition,” stated Nancy Chafetz, chair of NEPOOL, in an email.

Connecticut’s issues with ISO New England boiled over this summer on the heels of a power-purchase agreement between Millstone owner Dominion and transmission grid operators Eversource and United Illuminating, which contributed to a sharp increase in customer bills.

A few weeks ago, Lamont signed into law a “Take Back the Grid” act that allows the Connecticut Public Utilities Regulatory Authority to factor in Eversource’s and Avangrid subsidiary United Illuminating’s past performance in maintaining electric reliability, in addition to any future needs for revenue based on needed upgrades. The law included an element for Connecticut to initiate a study of ISO New England’s role.

Eversource and Avangrid have voiced support for the switch to “performance-based” regulation in Connecticut. Eversource spokesperson Mitch Gross on Thursday cited the company’s view that any changes to the operation of New England’s wholesale power markets should occur within the existing ISO New England structure.

“We also recommend any examination of potential alternatives includes a thorough evaluation that ensures unfair costs would not be imposed on customers,” Gross stated in an email.

In a statement forwarded by Avangrid spokesperson Ed Crowder, the United Illuminating parent indicated it intends to have “a voice in this process” with the goal of continued grid reliability amid increased adoption of clean energy sources.

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Ontario Pumped Storage advances as Ontario's largest energy storage project, delivering clean electricity, long-duration capacity, and grid reliability for peak demand, led by TC Energy and Saugeen Ojibway Nation, with IESO review underway.

Key Points

A long-duration storage project in Meaford storing clean power for peak demand, supporting Ontario's emission-free grid.

✅ Stores clean electricity to power 1M homes for 11 hours

✅ Partnership: TC Energy and Saugeen Ojibway Nation

✅ Pending IESO review and OEB regulation decisions

In a bid to accelerate the province's ambitions for clean economic growth, TC Energy Corporation has announced significant progress in the development of the Ontario Pumped Storage Project. The Government of Ontario in Canada has unveiled a plan to address growing energy needs as a sustainable road map aimed at achieving an emission-free electricity sector, and as part of this plan, the Ministry of Energy is set to undertake a final evaluation of the proposed Ontario Pumped Storage Project. A decision is expected to be reached by the end of the year.

Ontario Pumped Storage is a collaborative effort between TC Energy and the Saugeen Ojibway Nation. The project is designed to be Ontario's largest energy storage initiative, capable of storing clean electricity to power one million homes for 11 hours. As the province strives to transition to a cleaner electricity grid by embracing clean power across sectors, long duration storage solutions like Ontario Pumped Storage will play a pivotal role in providing reliable, emission-free power during peak demand periods.

The success of the Project hinges on the approval of TC Energy's board of directors and a fruitful partnership agreement with the Saugeen Ojibway Nation. TC Energy is aiming for a final investment decision in 2024, as Ontario confronts an electricity shortfall in the coming years, with the anticipated in-service date being in the early 2030s, pending regulatory and corporate approvals.

“Ontario Pumped Storage will be a critical component of Ontario’s growing clean economy and will deliver significant benefits and savings to consumers,” said Corey Hessen, Executive Vice-President and President, TC Energy, Power and Energy Solutions. “Ontario continues to attract major investments that will have large power needs — many of which are seeking zero-emission energy before they invest. We are pleased the government is advancing efforts to recognize the significant role that long duration storage plays — firming resources, including new gas plants under provincial consideration, will become increasingly valuable in supporting a future emission-free electricity system.” 

The Municipality of Meaford also expressed its support for the project, recognizing the positive impact it could have on the local economy and the overall electricity system of Ontario. Additionally, various stakeholders, including LiUNA OPDC, LiUNA Local 183, and the Ontario Chamber of Commerce, lauded the potential for job creation, training opportunities, and resilient energy infrastructure as Ontario seeks new wind and solar power to ease a coming electricity supply crunch.

The timeline for Ontario Pumped Storage's progress includes a final analysis by the Independent Electricity System Operator (IESO) to confirm its role in Ontario's electricity system and in balancing demand and emissions during the transition, to be completed by 30 September 2023. Concurrently, the Ministry of Energy will engage in consultations on the potential regulation of the Project via the Ontario Energy Board, while debates over clean, affordable electricity intensify ahead of the Ontario election, with a final determination scheduled for 30 November 2023.

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New Zealand Renewable Energy Strategy examines decarbonisation, GHG emissions, and net energy as electrification accelerates, expanding hydro, geothermal, wind, and solar PV while weighing intermittency, storage, materials, and energy security for a resilient power system.

Key Points

A plan to expand electricity generation, balancing decarbonisation, net energy limits, and energy security.

✅ Distinguishes decarbonisation targets from renewable capacity growth

✅ Highlights net energy limits, intermittency, and storage needs

✅ Addresses materials, GHG build-out costs, and energy security

The Electricity Authority has released a document outlining a plan to achieve the Government’s goal of more than doubling the amount of electricity generated in New Zealand over the next few decades.

This goal is seen as a way of both reducing our greenhouse gas (GHG) emissions overall, as everything becomes electrified, and ensuring we have a 100 percent renewable energy system at our disposal. Often these two goals are seen as being the same – to decarbonise we must transition to more renewable energy to power our society.

But they are quite different goals and should be clearly differentiated. GHG emissions could be controlled very effectively by rationing the use of a fossil fuel lockdown approach, with declining rations being available over a few years. Such a direct method of controlling emissions would ensure we do our bit to remain within a safe carbon budget.

If we took this dramatic step we could stop fretting about how to reduce emissions (that would be guaranteed by the rationing), and instead focus on how to adapt our lives to the absence of fossil fuels.

Again, these may seem like the same task, but they are not. Decarbonising is generally thought of in terms of replacing fossil fuels with some other energy source, signalling that a green recovery must address more than just wind capacity. Adapting our lives to the absence of fossil fuels pushes us to ask more fundamental questions about how much energy we actually need, what we need energy for, and the impact of that energy on our environment.

MBIE data indicate that between 1990 and 2020, New Zealand almost doubled the total amount of energy it produced from renewable energy sources - hydro, geothermal and some solar PV and wind turbines.

Over this same time period our GHG emissions increased by about 25 percent. The increase in renewables didn’t result in less GHG emissions because we increased our total energy use by almost 50 percent, mostly by using fossil fuels. The largest fossil fuel increases were used in transport, agriculture, forestry and fisheries (approximately 60 percent increases for each).

These data clearly demonstrate that increasing renewable energy sources do not necessarily result in reduced GHG emissions.

The same MBIE data indicate that over this same time period, the amount of Losses and Own Use category for energy use more than doubled. As of 2020 almost 30 percent of all energy consumed in New Zealand fell into this category.

These data indicate that more renewable energy sources are historically associated with less energy actually being available to do work in society.

While the category Losses and Own Use is not a net energy analysis, the large increase in this category makes the call for a system-wide net energy analysis all the more urgent.

Net energy is the amount of energy available after the energy inputs to produce and deliver the energy is subtracted. There is considerable data available indicating that solar PV and wind turbines have a much lower net energy surplus than fossil fuels.

And there is further evidence that when the intermittency and storage requirements are engineered into a total renewable energy system, the net energy of the entire system declines sharply. Could the Losses and Other Uses increase over this 30-year period be an indication of things to come?

Despite the importance of net energy analysis in designing a national energy system which is intended to provide energy security and resilience, there is not a single mention of net energy surplus in the EA reference document.

So over the last 30 years, New Zealand has doubled its renewable energy capacity, and at the same time increased its GHG emissions and reduced the overall efficiency of the national energy system.

And we are now planning to more than double our renewable energy system yet again over the next 30 years, even as zero-emissions electricity by 2035 is being debated elsewhere. We need to ask if this is a good idea.

How can we expand New Zealand’s solar PV and wind turbines without using fossil fuels? We can’t.

How could we expand our solar PV and wind turbines without mining rare minerals and the hidden costs of clean energy they entail, further contributing to ecological destruction and often increasing social injustices? We can't.

Even if we could construct, deliver, install and maintain solar PV and wind turbines without generating more GHG emissions and destroying ecosystems and poor communities, this “renewable” infrastructure would have to be replaced in a few decades. But there are at least two major problems with this assumed scenario.

The rare earth minerals required for this replacement will already be exhausted by the initial build out. Recycling will only provide a limited amount of replacements.

The other challenge is that a mostly “renewable” energy system will likely have a considerably lower net energy surplus. So where, in 2060, will the energy come from to either mine or recycle the raw materials, and to rebuild, reinstall and maintain the next iteration of a renewable energy system?

There is currently no plan for this replacement. It is a serious misnomer to call these energy technologies “renewable”. They are not as they rely on considerable raw material inputs and fossil energy for their production and never ending replacement.

New Zealand is, of course, blessed with an unusually high level of hydro electric and geothermal power. New Zealand currently uses over 170 GJ of total energy per capita, 40 percent of which is “renewable”. This provides approximately 70 GJ of “renewable” energy per capita with our current population.

This is the average global per capita energy level from all sources across all nations, as calls for 100% renewable energy globally emphasize. Several nations operate with roughly this amount of total energy per capita that New Zealand can generate just from “renewables”.

It is worth reflecting on the 170 GJ of total energy use we currently consume. Different studies give very different results regarding what levels are necessary for a good life.

For a complex industrial society such as ours, 100 GJ pc is said to be necessary for a high levels of wellbeing, determined both subjectively (life satisfaction/ happiness measures), and objectively (e.g. infant mortality levels, female morbidity as an index of population health, access to nutritious food and educational and health resources, etc). These studies do not take into account the large amount of energy that is wasted either through inefficient technologies, or frivolous use, which effective decarbonization strategies seek to reduce.

Other studies that consider the minimal energy needed for wellbeing suggest a much lower level of per capita energy consumption is required. These studies take a different approach and focus on ensuring basic wellbeing is maintained, but not necessarily with all the trappings of a complex industrial society. Their results indicate a level of approximately 20 GJ per capita is adequate.

In either case, we in New Zealand are wasting a lot of energy, both in terms of the efficiency of our technologies (see the Losses and Own Use info above), and also in our uses which do not contribute to wellbeing (think of the private vehicle travel that could be done by active or public transport – if we had good infrastructure in place).

We in New Zealand need a national dialogue about our future. And energy availability is only one aspect. We need to discuss what our carrying capacity is, what level of consumption is sustainable for our population, and whether we wish to make adjustments in either our per capita consumption or our population. Both together determine whether we are on the sustainable side of carrying capacity. Currently we are on the unsustainable side, meaning our way of life cannot endure. Not a good look for being a good ancestor.

The current trajectory of the Government and Electricity Authority appears to be grossly unsustainable. At the very least they should be able to answer the questions posed here about the GHG emissions from implementing a totally renewable energy system, the net energy of such a system, and the related environmental and social consequences.

Public dialogue is critical to collectively working out our future. Allowing the current profit-driven trajectory to unfold is a recipe for disasters for our children and grandchildren.

Being silent on these issues amounts to complicity in allowing short-term financial interests and an addiction to convenience jeopardise a genuinely secure and resilient future. Let’s get some answers from the Government and Electricity Authority to critical questions about energy security.

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