Don’t export LNG to Europe, they have their own natural gas

Preface. The congressional record is full of senators, representatives, and witnesses trying to sell U.S. shale “fracked” gas as LNG to Europe so that they aren’t beholden to Russia.  Well uh-oh, with the Russian invasion of Ukraine, the chickens have come home to roost, and there really aren’t good alternatives for Russian oil, which was especially suited for diesel fuel and was 10% of world oil production (though on the cusp of declining due to corruption with profits going into oligarch’s Swiss and offshore bank accounts rather than maintaining and improving the oil and natural gas infrastructure).

Hutzler is wrong by the way about Europe’s shale gas reserves — the infrastructure of pipelines isn’t there as it was in the U.S. for conventional oil and gas, the U.S. doesn’t have enough experts here in the U.S., the fracked sand may be difficult to get in Europe (essential for drilling), there are stricter rules on land use and environmental laws and s on.

Alice Friedemann  www.energyskeptic.com  Author of Life After Fossil Fuels: A Reality Check on Alternative Energy; When Trucks Stop Running: Energy and the Future of Transportation”, Barriers to Making Algal Biofuels, & “Crunch! Whole Grain Artisan Chips and Crackers”.  Women in ecology  Podcasts: WGBH, Planet: Critical, Crazy Town, Collapse Chronicles, Derrick Jensen, Practical Prepping, Kunstler 253 &278, Peak Prosperity,  Index of best energyskeptic posts

HRG. 113-623. 2014-7-22. U.S. Security implications of international energy and climate policies and issues. U.S. Senate 113th congress

MARY HUTZLER, DISTINGUISHED SENIOR FELLOW, INSTITUTE FOR ENERGY RESEARCH, BERLIN, MD

EUROPE ’S NATURAL GAS SUPPLIES

According to the Energy Information Administration, Europe has an estimated 470 trillion cubic feet of technically recoverable shale gas resources, around 80% of the U.S. estimated endowment of 567 trillion cubic feet. (1)

Europe is worried about continually receiving the 30% of its natural gas supplies that it receives from Russia, but instead of embracing hydraulic fracturing and horizontal drilling on domestic soil, it is looking toward the United States to export LNG to them.

According to a leaked document, the European Union is making its desire to import more oil and natural gas from the United States very clear in the discussions over the Transatlantic Trade and Investment Partnership (TTIP) trade deal. The EU is pressuring the United States to lift its ban on crude oil exports and make it easier to export natural gas to Europe. The EU emphasizes the TTIP’s role in ‘‘reinforcing the security of supply’’ of energy for the member countries, pointing to the political situation in the Ukraine as a key reason to relax rules against U.S. exports. ‘‘The current crisis in Ukraine confirms the delicate situation faced by the EU with regard to energy dependence,’’ the document states. ‘‘Of course the EU will continue working on its own energy security and broaden its strategy of diversification. But such an effort begins with its closest allies.’’ (2)

EU could start by developing its shale gas resources throughout its member countries.

Germany has proposed a prohibition against hydraulic fracturing through 2021.

France, which has the second-largest estimated shale gas resources in Europe, has a hydraulic fracturing ban through at least 2017

Bulgaria also forbids hydraulic fracturing. Poland, which has Europe’s largest technically recoverable shale gas resources at 148 trillion cubic feet, is interested in developing those resources, but has geology problems demonstrated by poor results from exploratory drilling. Several other European countries are now interested in developing their shale gas resources, such as the U.K., the Netherlands, Denmark, and Romania, but none of the European shale-gas exploration efforts are close to being ready for commercial development. (3)

(1) Energy Information Administration, Technically Recoverable Shale Oil and Shale Gas Resources: An Assessment of 137 Shale Formations in 41 Countries Outside the United States, June 2013.   EIA Detailed 145 page report on European Natural Gas

(2) Huffington Post, Secret Trade Doc Calls for More Oil and Gas Exports to Europe, July 8, 2014.

(3) Europe wants the energy, but not the fracking, July 15, 2014.

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Why we need a diverse electricity generation portfolio: House hearing 2013

House 113-12. March 5, 2013. American Energy security and innovation. The role of a diverse electricity generation portfolio. House of Representatives. 135 pages.

  • June 5, 2015. Proposed Clean Power Plan would accelerate renewable additions and coal plant retirements. U.S. Energy Information Administration
  • Even without the Clean Power Plan rule (CPP), 40 GW of coal capacity is expected to retire by 2040. If the CPP is passed, between 90 to 101 GW of coal plants may retire (EIA June 5 2015).
  • The EIA expects 46 to 62 GW of natural gas plant retirements replaced by 166 GW.
  • Coal plant retirement 40.1 GW by 2025 EIA DOE 2015 Annual energy outlook with projections to 2040.

Even in the absence of the proposed Clean Power Plan rule, 40 GW of existing coal-fired capacity and 46 GW of existing natural gas/oil-fired capacity are expected to retire through 2040 in the Reference case. Cases that implement the proposed Clean Power Plan rule accelerate and amplify these retirements, especially for coal. In the Base Policy case, 90 GW of coal-fired capacity and 62 GW of natural gas/oil-fired capacity retire by 2040. In the Policy Extension case, as emission rates continue declining after 2030, 101 GW of coal-fired generating capacity and 74 GW of natural gas/oil-fired generating capacity retire by 2040. The timing of the coal retirements is heavily influenced by implementation of environmental rules that may require power plant operators to either incur costs to retrofit power plants or receive less revenue because of lower levels of operation. As a result, coal retirements occur during the implementation of the Mercury and Air Toxics rule (in both the Reference case and Base Policy case), and in the initial year of the Clean Policy Plan implementation.

If EPA’s clean power plan and mercury and air toxis standards passes, then 60 GW of coal plants may retire early. EIA. March 20, 2014 Planned coal-fired power plant retirements continue to increase

  • Nuclear EIA DOE 2015: 19% of total electricity in 2013: 5.5 GW new by 2020 with 3.2 GW retirements by 2020
  • Natural Gas 2013: 8.4 quadrillion BTU = 8.2 Tcf to 9.6 QUADS = 9.4 Tcf in 2040
  • Only 3% of the nations 80,000 dams have hydropower, though more could be added.

APPA (7 million customers) Diversification is a means of risk management to prevent reliability, and low cost electricity.

40% of new plant construction is NG, 19.1% wind, 12.7% solar, 11.4% nuclear. NG is 43.4% operating capacity with coal 30%. Utilities are spending hundreds of millions to convert coal facilities to NG or new NG plants. They are also using NG to back up wind and solar. NG is subject to price volatility. Prices may be low now, but can easily rise due to increased regulation of fracking, increased utility demand, exports, and increasing use in the transportation sector. It’s not clear if there’s enough infrastrucuture or storage to accommodate greater use of ng by electric utilities.

Rules causing coal and nuclear plants to shut down:

  • the utility MACT rule
  • clean air transport rule (CATR) cross-state air pollution rule
  • Coal ash rule (resource conservation and recovery act)
  • Cooling water intake structures rule (section 316(b) of Clean water act)
  • New Source Performance Standards (NSPS)
  • new National Ambient Air Quality Standards (NAAQS) for criteria pollutants
  • National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and industrial ICI boilers and reciprocating internal combustion engines (RICE) units)

Commercially available technologies can be bought from a vendor, are proven at a commercial scale, and offered with robust guarantees on performance and reliability.

There are no commercially available technologies for the capture of CO2 from coal-based power plants. The DOE has 12 major CCS demonstration projects but not one of them has been completed or even started operating. Most are on paper, canceled, or delayed indefinitely, and AEP canceled its own project due to lack of adequate funding. Nor is CCS available abroad. Even if the technology was ready the high cost precludes commercial deployment. At best CCS technology is at least 10 years away indefinitely until projects are implemented. And since CCS equipment is so large, expensive to install, and highly energy intensive there is a real risk that project economics would discourage widespread deployment unless revolutionary technology innovations come along. On top of that CCS faces significant regulatory and legal barriers to get access to geologic repositories and liability and stewardship of the stored CO2. Lending institutions won’t risk several billion dollars without adequate assurances that CCS technology can be installed given EPA rules. Put another way, a utility operator will never select an electric generating technology that requires a control equipment retrofit of unknown technology to be installed 10 years after initial operation. As a result, EPA’s proposed rule is likely to delay for many years the development of CCS technology because new coal-fueld generation will not be built, and without the development of such new coal-based units in the future, the incentive to invest in and advance CCS technology will be greatly diminished.

Mark C. McCullough, exec VP generation, American Electric Power, 5 million retail customers.

The more fuel diversity the less risk since each fuel type and technology is different in terms of availability, reliability, cost, and performance.

Coal and nuclear plants buffer against natural gas fuel supply disruptions because they have 30-60 days of fuel on site. Baseload power runs around the clock with low fuel costs and provides the bulk of electricity. Intermediate and peaking facilities run primarily during periods of high electricity demand. Policies that prevent new or force early retirement of coal and nuclear reduce capacity diversity, risk availability, reliability, and cost.

Too great a reliance on natural gas with a history of great price volatility increases the risk of price spikes and supply disruptions. In Japan, only 2 of 54 nuclear reactors are back and heavily populated areas of the country have rolling blackouts, reduced output in manufacturing facilities, and some of them are moving abroad. NG prices tripled to make up the deficit.

Coal is solid and can an inventory of 30 to 60 days of supply can be at the plant site, unlike natural gas which is subject to disruptions of supply when pipeline infrastructure is damaged in storms and natural disasters. Nuclear power also has large reserves of fuel capacity.

AEP is concerned that a prolonged “dash” to gas will lead to over reliance on one fuel. Already there can be bottlenecks in delivery when both electric and consumer heating demands occur at the same time, especially on cold, short winter days.

Electric utilities have publicly announced plans to shut down 335 coal-fired generating units totally about 47,000 MW. It is likely that over 20% of the U.S. coal fleet will be shut down in the next few years. ACCCE “Coal Unit Shutdowns” feb 14, 2014

The grid will become increasingly reliant on Natural Gas (NG).

William Mohl, president, Entergy wholesale commodities (6 pages of mostly how safe nukes are)

NG 2013 8.4 quadrillion BTU = 8.2 Tcf to 9.6 QUADS = 9.4 Tcf in 2040

Replacing the approximately 101,000 megawatts of capacity provided by U.S. nuclear plants with gas-fired Combined-Cycle Gas Turbine (CCGT) plants would cost between $100 and $110 billion dollars, not including pipelines.

replacing all U.S. nuclear units with gas-fired generation would require an additional 14.5 billion cubic feet per day of additional gas supply, a 70% increase over the 20.8 billion cubic feet per day of gas that electric generators used in 2011. Natural gas fired generators do not have on-site fuel inventory and must be continuously supplied through a pipeline system, and while some facilities may have access to gas storage facilities to ensure continuous supply, many facilities do not. Supply issues can arise during peak times, when pipeline capacity is needed to satisfy the demands of local gas distribution companies to serve homes and businesses, in addition to the needs of power plants that may not have contracts for firm delivery. By contrast, nuclear plants have up to eighteen months of fuel supply on site and do not compete with residential and business consumers for fuel

Regional electric grids require a mix of baseload, load-following, and peaking facilities. Baseload power sources are those plants that can generate dependable power to consistently meet demand. Baseload generation typically runs at full capacity, 24 hours a day, seven days a week, unless a unit is off-line for a scheduled or unscheduled outage. Load-following power sources are typically called upon to increase or reduce output throughout the course of a day as demand for power from end users changes. Peaking units are usually called into service only when demand for electricity is especially high, such as during periods of extreme heat or cold. While each regional electric system has its own unique characteristics, in general, coal and nuclear plants have long supplied baseload power, while natural gas-fired units have been used as the predominant source of load-following and peaking capacity.

There are 1031 operating nuclear power plants in the United States generating approximately twenty percent (20%)2 of the Nation’s electricity. Those nuclear plants operate as baseload, high capacity factor (approximately 89% in 20111) units that power — and help stabilize — the electric grid in or near many major American cities, including New York, Boston, Philadelphia, Pittsburgh, Baltimore, Washington, D.C., Chicago, Detroit, Cleveland, Charlotte, Miami, New Orleans, and Phoenix, among others. Almost half of U.S. nuclear reactors are located within 50 miles of a metropolitan area that has a population of more than half a million. Throughout the Nation, nuclear generators help keep wholesale electricity prices lower than they otherwise would be.

A misconception about nuclear power plants we sometimes encounter is that they remain as they were when they first began operating. To the contrary, many key components are upgraded or replaced periodically, incorporating technological innovations that have been tested and proven suitable. One example is digital instrumentation, which has replaced other types of instrumentation for multiple systems and sub-systems at Entergy plants. Where digital instrumentation has been installed after rigorous analysis and testing, it generally allows plant operators to exercise finer control of systems and provides more immediate feedback. Another example is replacement components made from innovative new materials, such as working components of feed-water pumps and the turbine blades that are driven by steam to produce power. Components such as these, which often cost much more than the components they replace due to their use of cutting-edge materials, last longer and increase plant reliability

American chemistry council. the US chemical industry is the nation’s largest user of combined heat and power (CHP) with 82 GW of installed capacity at 3,700 sites. CHP is significantly underused. ORNL has estimated there are 130 GW possible in U.S. commercial and industrial applications.

ED WHITFIELD (KENTUCKY). At today’s hearing, we are going to be focusing on the role of a diverse source of fuel for electricity generation. We frequently all hear a vocal chorus about the need for ‘‘all of the above’’ to meet our Nation’s demand for electricity at an affordable cost so that we can be competitive in the global marketplace, create a strong economy, and create jobs.

Robert Mann, the Sierra Club President, was quoted as saying ‘‘Fossil fuels have no part in America’s energy future. Coal, oil, and natural gas are poisoning us. The emergence of natural gas as a significant of our energy mix is particularly frightening, because it dangerously postpones investment in clean energy at a time when we should be doubling down on wind, solar, and energy efficiency.’’

Americans are fortunate to have a variety of electricity sources available to us. Each source brings its own unique mix of assets and liabilities. Some are inexpensive, while others are not. Some are reliably available 24 hours a day and seven days a week and ideal for baseload power, while others are not. Some can be quickly ramped up or down to match quick changes in demand, while others cannot. Some can be located almost anywhere, while others are geographically limited. Some can be easily integrated into the existing electric grid, while others would necessitate costly new infrastructure investments. As a result, there is no one ideal means of generating electricity. The best approach for affordability and reliability is a broad mix of generation sources, be it coal, natural gas, nuclear, or renewables. Each source can serve a purpose in the electricity mix, and each has strengths that can compensate for the other’s weaknesses.

BOBBY L. RUSH (ILLINOIS). If we are going to be able to be a manufacturing country and actually create jobs here, it is going to take energy to do it, and under the current breakdown we have today, roughly 87 percent of the electricity that is generated in this country comes from coal, from nuclear power, and from natural gas, and unfortunately, all three are under attack by this administration. The war on coal has been duly noted, you know, you see so much coal being exported because you can’t even use it in this country today, yet it represents over 37 percent of the electricity that is generated. How you can continue to enjoy the standard of living we have as a country today when the administration is attacking 37 percent of that resource, and then in addition, it is all of the other things that are produced in this country. You can’t just do it on wind and solar. We support the advancement of those technologies, but when 87 percent of your electricity comes from the other sources and you are going after them, that is truly the government picking winners and losers and ultimately, the losers are families who are paying higher electricity costs when this kind of policy goes into effect.

Mr. Shimkus of Illinois. the State of Illinois is a 50 percent nuclear, 50 percent coal, so we have the benefits,

HENRY A. WAXMAN (CALIFORNIA). Cheap natural gas is also helping to transform our electricity sector. This market reality is driving a shift away from the use of polluting coal to generate electricity. Even boosters of coal acknowledge that it is not cost effective to build new coal plants today.

Mr. Mark McCullough, Executive Vice President, Generation, at American Electric Power

Energy diversity plays an important role in reducing the potential exposure of our company and our customers to major fluctuations in markets, costs, regulations, and electric demand. This allows for the use of the lowest cost resources possible while enabling rapid response to demand changes. However, policies that could prevent the construction of new base load generating units or force the retirement of existing capacity could lead to significant shifts to this balanced energy mix and reduce capacity diversity.

For example, the proposed CO2 NSPS for new sources effectively prohibits the construction of any new coal-fired power plant because of a lack of commercially available CO2 control technology. Due to these regulations, as well as numerous other challenges facing nuclear energy, our Nation’s electric grid will become increasingly reliant on a single fuel for new base load generation capacity, likely eliminating both diversity and flexibility in new power plant builds. Federal policy should support fuel diversity, not preclude it.

The importance of fuel diversity cannot be overstated

Too great a reliance upon any one energy source creates a significant risk of exposure to electricity price spikes and supply disruptions. Among other benefits, coal and nuclear plants buffer against fuel supply disruptions because they can inventory months of fuel on site, a fundamental value to any energy security solution with national security benefits.

Over the past 12 years, AEP has added more than 5,000 megawatts of natural gas fuel diversity, enabling our company to switch between fuel sources based on price fluctuations. While we recognize the value that natural gas brings to the diversity equation, AEP is concerned that a prolonged ‘‘dash’’ to gas will lead to over reliance on one fuel and have adverse consequences for the balance and diversity of the power sector and the economy.

With the current low cost of natural gas, coal, and uranium, now is the ideal time to look to the future and adjust the focus of technology development to truly innovative, revolutionary paradigms for energy conversion and use. We support commercialization of Small Modular Reactor, or SMR, technology for the next generation of nuclear power. For fossil fuels, the United States must invest in technologies that show promise of a step change move of the needle regarding cost, fuel efficiency, and environmental performance.

With success, technologies like chemical looping and other new revolutionary technologies will enable our next generation of power plants to use coal with extremely high efficiency and ultra-low emissions, while producing a pure stream of CO2 with no added energy penalty. These technologies can open a vast, yet untapped, oil reserves in this country to enhanced oil recovery production by making enormous quantities of low-cost CO2 available for EOR purposes, bringing an even higher level of energy security. These technology innovations require attention now to enable industry to overcome the high cost of commercialization. Encouragingly, as stated in the CURC–EPRI Technology Roadmap, the necessary funding to develop and commercialize these concepts is not beyond the levels invested in recent years with DOE’s Fossil Energy clean coal programs. This funding just needs to be focused on the proper technologies.

SMR development could address nuclear risk that prevents its broad deployment today.

William Mohl, President of Entergy Wholesale Commodities.

Entergy is one of the largest nuclear operators in the United States. We currently operate 11 nuclear power facilities in New York, Vermont, Michigan, Massachusetts, Arkansas, Louisiana, and Mississippi.

Nuclear plants are an essential part of this Nation’s energy portfolio. Regional electric grids require a mix of base load, load-following, and peaking facilities. While each regional electric system has its own unique characteristics, in general, coal and nuclear plants have long supplied base load power, while natural gas-fired units have been used as the predominant source of load-following and peaking capacity. There are 103 operating nuclear power plants in the United States, generating approximately 20 percent of the Nation’s electricity. Those nuclear plants operate as base load, high capacity factor units that power and help stabilize the electric grid in or near many major American cities. Throughout the Nation, nuclear generators help keep wholesale electricity prices lower than they otherwise would be.

A simple way of looking at the economic value of the existing nuclear generation fleet is to consider the potential cost of replacing it. Using data from the Energy Information Administration, we have calculated that replacing the 100,000 megawatts of nuclear capacity with new combined cycle technology gas plants would cost more than $110 billion. To put that number in perspective, in 2011, American utilities invested slightly more than $30 billion in transmission and distribution facilities, less than 1/3 of the nuclear for combined cycle replacement cost. Moreover, this replacement cost estimate does not include any costs of expanding pipeline capacity to serve new gas-fired plants. The adequacy of pipeline capacity is a key consideration, as was recently demonstrated in New England.

Nuclear power is also a crucial contributor to maintaining America’s air quality.

Mr. BARTON. Let us be honest. You are not going to build a coal plant with those regulations, and you will build, probably, almost all natural gas. I am in the Barnett Shale, so I am not anti-natural gas, but I also have lignite coal plants and I support nuclear power and wind power. So I think it is a little bit disingenuous to say that they are fuel neutral. They are not. The gentleman from Entergy, you are a big proponent of nuclear power. Do you think it is possible in today’s market environment to build a base load nuclear power plant in America?

Mr. MOHL. It is very challenging in this environment to be able to build a new nuclear plant. Currently there is a handful of them being developed down South.

Mr. BARTON. Yes, where they still have the regulated markets and you can roll in the prices. But is the challenge for new nuclear, is it more still regulatory and licensing, or is it just the simple fact that because of the competition from coal and natural gas, and to some extent, wind power possibly, that it is just not cost effective right now? It is not economically possible?

Mr. MOHL. There are three challenges as it relates to merchant nuclear. Low gas prices obviously have depressed the markets. Regulation, we need fact-based scientific approach that is based on cost benefit, and we need fair and competitive wholesale markets. And so you are exactly right, that trying to build a new nuclear plant in a wholesale market is just not feasible. Mr. BARTON. I want the record to show that we had a witness say I was exactly right. If you all will make a note of that.

Mr. Benjamin Fowke, who is President and CEO, Xcel Energy

QUESTOIN: would you comment on the assistance stability impacts of wind and solar energy in your utilities?

Mr. FOWKE. Yes, the reliability issues increase, obviously, the more renewables you have on system. I mentioned in my testimony at one point earlier this year, we had 57 percent of our energy coming from wind. So when that happens, you have to quickly back down your generation, and typically you want that to be a gas-fired generation versus nuclear or coal, because they are designed better for those sorts of things. So you have to ramp up and ramp down, and you have to follow the load accordingly. And that does—as you get higher levels of penetration, increase the cost of having that much renewables on your system.

QUESTION: how does wind energy form a hedge against price spikes?

Mr. FOWKE. Wind, as we all know, is interruptible, so while it has a capacity factor for planning, we put a very small capacity factor on it. So it is fuel. So you can build it and you can determine how long it is going— what it is going to cost over a 20-year period. For us, that is about $40 a megawatt hour. Then you compare that to other fuel sources, natural gas specifically. Sometimes at $40 a megawatt hour it is in the money, as it was when natural gas was at 8 and $10. Sometimes it is a little bit out of the money, as it is today in a very low natural gas environment. But it is still a hedge.

QUESTION: You said in your testimony that only 3 percent of the dams, 80,000 dams across America produce electricity. Could you explain that a little bit? What is holding that up?

Mr. GERKEN. Well, one issue is it is very capital intense projects, and they take such a long time to develop. And a lot of these are not your big—dams or obviously run-of-the-river where we are at, so they have smaller capacity name plate. Our projects are, example, 105 megawatts, 82 megawatts, 72 megawatts, and 48 megawatts. But for the most part, it is that capital intense issue. I am not sure we would build these projects today, you know, in today’s natural gas markets it would have been tough to justify this, because quite frankly, our run-of-the-river hydro are very similar to the nuclear when it comes to cost. But we look at that component from we don’t have a fuel to buy and a waste stream on the other side——

MARK MCCULLOUGH ON BEHALF OF AMERICAN ELECTRIC POWER

Energy diversity plays an important role in reducing the potential exposure of our company and customers to major fluctuations in markets, costs, regulations, and electric demand by allowing for the use of the lowest cost resources possible while enabling rapid response to changes in demand that occur throughout the day. However, policies that could prevent the construction of new baseload generating units or force the retirement of existing coal-fired capacity could cause significant shifts to this balanced energy mix; reduce capacity diversity; and hinder our ability to provide reliable and affordable electricity to our communities and customers. For example, the proposed CO2 NSPS for new sources effectively prohibits the construction of any new coal-fired power plant because of the lack of a commercially available CO2 control technology. Due to these regulations, as well as numerous other challenges facing nuclear energy, our nation’s electric grid will become increasing reliant on natural gas for new generation capacity, likely eliminating both diversity and flexibility in new power plant builds. Federal policy should support fuel diversity, not preclude it.

The importance of fuel diversity cannot be overstated given its implications for assuring economic and energy security. Too great a reliance upon any one energy source (particularly those with a history of price volatility) creates a significant risk of exposure to electricity price spikes and supply disruptions. This can lead to severe impacts on the supply stability and price of electricity for residential, commercial, and industrial customers. Consider the Tsunami catastrophe in Japan, where a natural disaster resulted in all 54 nuclear reactors being abruptly removed from service. Nearly two years later only two units are back in service. Hurricane Katrina in 2005 disabled nine oil refineries and rendered 30 oil platforms damaged or destroyed. Coal and nuclear plants buffer against fuel supply disruptions because they can inventory months of fuel on site, a fundamental value to any energy security solution with national security benefits.

Over the past twelve years AEP has added more than 5,000MW of natural gas fuel diversity, which has enabled our company to switch between fuel sources based on price fluctuations of fuels over time. This diversity has served our customers and communities well and has allowed us to keep our electricity rates low. For example, AEP responded to the spikes in natural gas pricing during the mid2000’s by increasing its use of cheaper coal to serve our customers, while at the same time decreasing emissions. Similarly, recently depressed natural gas pricing have allowed us to keep our electricity prices low by using additional natural gas where more cost effective than coal. However, AEP is concerned that a prolonged“dash” to gas will lead to over reliance on one fuel and have adverse consequences for the balance and diversity of the power sector and the economy.

With the current low cost of natural gas, now is the ideal time to look to the future and adjust the focus of technology development to truly innovative, revolutionary paradigms for energy conversion and use. We support commercialization of Small Modular Reactor (SMR) technology for the next generation of nuclear power. For fossil fuels, the United States must invest in technologies that show promise of meaningfully moving the needle regarding cost, fuel efficiency, and environmental performance. With success, chemical looping and other new revolutionary technologies will enable our next generation of power plants to use coal with extremely high efficiency and ultra-low emissions, while producing a pure stream of CO2 with no added energy penalty. Not only will these new paradigms revolutionize the power generation industry, they can open the vast, yet untapped, oil reserves in this country to Enhanced Oil Recovery (EOR) production by making enormous quantities of low cost CO2 available for EOR purposes. These technology innovations are essential to a diverse energy future, but they require attention now and focused funding to enable industry to overcome the high cost of commercialization. Encouragingly, as stated in the CURC-EPRI Technology Roadmap, the necessary funding to develop and commercialize these concepts is not beyond the levels invested in recent years with DOE’s Fossil Energy clean coal programs; this funding just needs to be focused on the proper technologies.

To ensure our current investments in coal-fired generation can be retained in the future to maintain diversity, we have also invested heavily in the advancement of carbon capture and storage technology. The Mountaineer CCS Project treated a 20-MW portion of flue gas from our 1300-MW Mountaineer Plant, removed the carbon dioxide (CO2), and compressed and injected the CO2 into two deep underground formations more than 7,000 feet below the surface of the plant property. The project successfully operated from 2009 to 2011, and permanently stored nearly 40,000 tons of CO2 in deep saline reservoirs, with continuing post-closure monitoring. A second phase of that project, which would have advanced the technology to a 235-MW commercial scale, was deferred due to the failure to raise funding.

THE ROLE OF DIVERSITY

Diversity plays an important role in reducing the potential exposure of our company and customers to fluctuations in markets, costs, regulations, and electric demand. Diversity within the electric power sector can refer to a variety of practices that reduce these exposures. Perhaps the most important measure of diversity for the electric power sector is the practice of fuel diversity. The U.S. has an abundance of energy resources that can be used to generate electricity, including coal, natural gas, uranium, wind, solar, water, biomass and geothermal. These fuel sources each have a unique cost profile based on both supply and demand of the fuel as well as the unique generating technology required to turn chemical, solar or kinetic energy into useful electrical energy. However, each fuel type and technology present different risk characteristics in terms of availability, reliability, cost, and performance. As such, fuel diversity among these energy resources will lower the overall risk of the generation portfolio and provide for a more reliable and cost effective electric supply. Generating technologies are specific to the fuel or energy resource used to produce electricity to our electric grid. Developing capacity diversity within our generating system is important because it allows for the use of the lowest cost resources when possible while enabling rapid response to changes in demand that occur throughout the day. Capacity diversity is achieved by constructing baseload, intermediate and peaking facilities in addition to intermittent facilities (e.g. wind and solar), which may or may not be available to generate electricity at any given time. When properly deployed, each type of resource can synergistically operate during the various fluctuations in supply and demand to reliably support customer needs and requirements. Generally speaking, baseload facilities (coal, nuclear, hydro, and more recently gas) are designed to run around the clock with low fuel costs and provide the bulk of electricity to the grid. Intermediate and peaking facilities are designed to run primarily during periods of higher electric demand. However, policies that could prevent the construction of new baseload facilities or force their retirement could cause significant shifts to this mix; reduce capacity diversity; and increase risk of availability, reliability, and cost of electricity.

IMPORTANCE OF FUEL DIVERSITY

The importance of fuel diversity cannot be overstated given its implications for assuring economic and energy security. Too great a reliance upon any one energy source (particularly those with a history of price volatility [NATURAL GAS]) creates a significant risk exposure to electricity price escalation and supply disruptions. As has been proven repeatedly across the globe, such exposure can lead to severe impacts on the supply and price of electricity for residential, commercial, and industrial customers. For example, the recent catastrophe in Japan serves as a sobering reminder of what can happen if a single energy source is abruptly removed from use. In 2011, an earthquake and tsunami devastated shoreline communities and seriously damaged the Fukushima Daiichi nuclear power plant. Resultant radiation leaks and a greatly eroded public faith in safety of nuclear power lead to the shutting down of all of Japan’s 54 nuclear reactors for mandatory maintenance and safety checks. To date, only two units are back in service. Heavily populated areas of the country have faced the realities of rolling blackouts, while manufacturing facilities are reducing output, with some making moves to relocate abroad. Meanwhile, natural gas prices in Japan nearly tripled as power producers scrambled to fill the massive void left in their energy infrastructure. Domestic energy disruptions and their consequences are clearly evident by such disasters as Hurricane Katrina in 2005, where nine oil refineries were shut down for an extended period of time and 30 oil platforms were either damaged or completely destroyed, dramatically hampering oil and gas production. United States natural gas prices spiked following the disaster and for months afterward remained more than double the price over the previous year.

There is another unique feature to coal that must be considered from an energy security perspective. Coal is a solid and physically stable energy resource that can be safely stockpiled at the power plant site. A typical power plant takes advantage of this feature by keeping an inventory of 30 to 60 days of supply of coal at the plant site. This is an incredibly valuable characteristic when considering the risks associated with supply interruptions of other fuels, such as natural gas. If storms, natural disasters, or other forces interrupt major gas pipeline infrastructure, gas-fired power plants immediately cease to produce electricity and cannot resume production until infrastructure repairs are made. Coal plants, on the other hand, can continue to operate if the major fuel supply is compromised.

Similarly, nuclear power enjoys the benefit of large reserves of fuel capacity on the plant site. This is a factor of fundamental value to any energy security solution and has national security benefits as well– particularly given the abundant reserves of coal in the United States.

While we value natural gas as a critical component of our generation energy mix, AEP is concerned that the United States has reached an important crossroads in terms of fuel diversity planning. EPA’s regulations have led to the premature shut down of some of our existing coal fired facilities, while not allowing the construction of new coal-fired facilities, as discussed later. This effectively precludes further use of a low-cost, abundant and domestic resource, coal, within the U.S. generating mix and will force AEP and others to increasingly rely on natural gas for generating electricity– which has a long history of price volatility. AEP is concerned that a prolonged “dash” to gas will lead to over reliance on one fuel and have adverse consequences for the balance and diversity of the power sector and the economy.

For example, the increased use of natural gas to generate electricity puts stress on a natural gas supply system designed to meeting peak winter heating needs by requiring increasingly larger supply and flow rate to power plants, which currently represent a minority share of U.S. natural gas demand. As an example, ISO New England just told the Federal Energy Regulatory Commission on February 7 that it was concerned about “increasing reliance on natural gas-fueled generators at times when there is an increasingly tight availability of pipeline capacity to deliver natural gas from the south and west to New England.” This increased reliance has contributed to rapid price spikes in the cost of natural gas in that area, which translates into much higher wholesale electric prices. There are additional concerns surrounding the synchronization of electricity and natural gas markets as supplies of power and natural gas are secured on a different time basis. This disconnect may prevent facilities committed to provide electric power from securing the gas supplies they need to operate. This picture is further complicated by the interdependent nature of the natural gas supply and electric generation industries. As more of the power generation comes from gas, the impact of simultaneous peak electricity demand and peak consumer heating demands converge, creating a scenario where gas deliverability capability can become a bottleneck.

This is particularly true in the winter when shorter days and colder temperatures increase demands for heating and lighting. While adequate supply of gas may exist, delivering at the rate needed during peaks could be constrained.

The dash to gas and the potential problems created in its wake has come at the same time that other countries around the world are increasingly turning to coal to fuel their economies. China is currently far and away the largest consumer of coal, and in fact is consuming almost as much coal as the rest of the world combined. Additionally, Europe is increasingly returning to coal to fuel its electric sector, with much of the imported coal coming from the United States. Consequently, any policy, direct or indirect, to restrict coal use within the U.S. is unlikely to have a significant impact on reducing global coal consumption. The more significant impacts will be felt however by the U.S. economy, particularly in regions of the country which rely on coal production for economic stability and low-cost electric generation.

REGULATORY BARRIERS TO FUEL DIVERSITY

There are numerous barriers to fuel diversity within the electric generation fleet; however our most pressing concerns are the new federal environmental regulations and the lack of an energy policy promoting diversity and therefore energy security.

As an example, the proposed CO2 NSPS for new sources effectively prohibits the construction of new coal-fired facilities for the reasons discussed in the next section. These proposed CO2 performance standards come in the wake of other new environmental regulations, most notably the Mercury and Air Toxics Standards. Due to these new EPA rules and other factors, electric utilities have already publicly announced their plans to shut down 335 coal-fired generating units, totaling about 47,000 MW. Additional coal plant shutdowns are expected as companies finalize their air toxics compliance plans. Once these additional plant retirements are combined with already announced retirements, it is likely that over 20 percent of the U.S. coal fleet will be shut down within the next few years. 1 See http://www.eia.gov/todayinenergy/detail.cfm?id=9751 .2 See http://www.economist.com/news/briefing/21569039-europes-energy-policy-delivers-worst-all-possible-worldsunwelcome-renaissance. 3 See

Due to these regulations, our nation’s electric grid will become increasing reliant on natural gas for new generation capacity, likely eliminating both diversity and flexibility in new power plant builds.

CCS is not currently commercially available or economically viable at this time. EPA supports its fuel discriminatory standard by stating that the rule would not impose any additional costs on the economy because under current economic conditions, no new coal-fueled units will be built. While AEP agrees that current market conditions generally do not support development of new coal-fueled units, this result is driven primarily by current low prices of a very volatile commodity, natural gas. Natural gas prices have fluctuated over the past decade between $2 and $13 per MMBtu on a monthly average basis. Average prices over most of the last decade have been above $6 per MMBtu. Most 10-year projections show gas prices in the range of $4 to $6 per MMBtu. By contrast, most coal prices in the US are less than $3 per MMBtu. In light of the significant historical fluctuation of natural gas prices, it is reasonable to plan for some continued variation in natural gas prices over the long-term even though shale gas reserves appear to be plentiful at this time. If, for example, natural gas prices were to increase modestly to levels seen only a few years ago, electric generating companies could opt to build new coal units based on economics, absent the proposed CO2 NSPS requirements. However, with EPA’s proposal to adopt a CO2 emissions standard based on the performance of natural gas combined cycle units, electric generating companies are unable to build coal-fueled units without assuming unreasonable risks, and therefore generally have no choice but to build gas units instead.

Nuclear energy also faces daunting challenges. According to an MIT study “The Future of Nuclear Power”, nuclear energy faces four unresolved problems: high relative cost; perceived adverse safety, environmental, and health effects; potential security risks stemming from proliferation; and unresolved challenges in long-term management of nuclear wastes. From a new plant construction perspective, risks associated with cost escalation, scheduling, and sheer project size suggest that very few new nuclear plants will be built. Compounding this with the fact that existing nuclear power plants are facing expiration of their operating licenses over the coming years or decades, there is a real threat that nuclear energy will not be a viable participant in a long term diverse energy portfolio.

AEP believes that technological solutions are critical to reducing emissions as well as improving the reliability, efficiency, and availability of electricity production. More than a century of technology innovation qualifies AEP as an industry leader and expert in these topics. Nonetheless, as a consequence of our first-hand experience and intimate understanding of CCS technologies, AEP is convinced that CCS is many years from providing a commercially viable solution to capturing and permanently storing CO2 emissions due to the numerous technical, financial, legal, and regulatory challenges that must first be addressed. However, these solutions will need to be developed to ensure fuel diversity can be maintained with the possibility of a carbon-constrained world. Additionally, there are a number of other new and innovative technologies that convert coal to electric power and other products while producing a pure stream of CO2, not requiring the added processes to capture and purify CO2 emissions. While still in the developmental phase, these emerging technologies are showing tremendous promise at the laboratory and pilot-plant level. In many cases, these new technologies, such as chemical looping applications, are revolutionary as opposed to evolutionary in nature and could usher in a new generation of technology solutions that are lower in cost, perform at higher energy efficiencies, and provide more flexibility in fuel selection.

“Commercially available” technologies are those that can be purchased from a vendor, have been proven at commercial scale on a representative application, and are offered with robust guarantees on performance and reliability. Vendors cannot provide meaningful guarantees without extensive testing at representative scale. Based on this point of reference, no commercially available technologies for the capture of CO2 from coal-based power plants exist today.

The Department of Energy’s Major CCS Demonstration program currently includes twelve projects that propose to demonstrate CO2 capture along with some form of storage and/or utilization of the captured CO2. If this were a list of 12 successfully completed projects, then it could certainly be argued that the technologies are ready for commercial deployment. However, not one of the projects has been completed, and in fact, none have even commenced operation. Most are no more developed than the work on paper required for conception of the project. Some that had previously been included on DOE’s list have been cancelled or delayed indefinitely.

The technologies to capture and sequester CO2 are not commercially available, domestically or otherwise. While several promising CO2 capture technologies are under development, none are ready for commercial deployment. They must be advanced in a systematic and step-wise manner to ensure their technological and economic feasibility.

AEP had begun the process of moving the CCS technology to commercial scale with the Mountaineer CCS Demonstration Project, but the lack of an adequate funding mechanism resulted in the company placing the project on hold. Even if AEP’s project had remained on schedule, the CCS technology, like other first-of-a-kind projects, would have been installed without any commercial guarantees from vendors and would have run the risk of not continuously or reliably achieving high CO2capture levels. AEP’s expectation was that a commercial-scale CCS demonstration project was essential now, so that in 2020 or later, a reliable commercial-scale CO2 capture system might be commercially available and ready for deployment.

With the suspension of the AEP project and as similar DOE projects are delayed or discontinued, the date for commercial readiness of CCS technology continues to move further out on the horizon. A reasonable estimate for commercial availability, based on the current state of technology development, is at least ten years away, and this is assuming that current financial and regulatory barriers to demonstration projects are expeditiously removed. Without a clear path forward, we will remain, perhaps indefinitely, ten years or more from commercialization of CO2 capture technology. Numerous studies and projects by public and private organizations also have concluded that the availability of commercially available CCS is at least a decade away, even if a much more ambitious research, development, and demonstration program were implemented. Even then, CCS equipment is large, expensive to install, and highly energy intensive. There is a real risk that project economics could discourage wide deployment of CCS.

Furthermore, the path to CCS commercialization is filled with significant regulatory and legal barriers. These include issues related to the ownership of, acquisition of, and/or access to geologic pore space, as well as issues surrounding long-term liability and stewardship of geologically stored CO2. The removal of these barriers in many cases will most likely be through the development of state legislation and regulatory programs. Efforts at the state and federal level are underway and in various stages of development, but significant challenges remain before these and other legal and regulatory issues will be sufficiently resolved to support the commercialization of CCS on coal-based generation.

Finally, EPA has proposed an alternative compliance option that will not help coal-fueled EGUs achieve the CO2 performance standard. EPA’s averaging approach will not work without much greater certainty pertaining to CCS cost and technology. In fact, this alternative compliance option does nothing to ensure the demonstration and deployment of CCS technologies. As just discussed, CCS is not yet commercially demonstrated for large-scale commercial applications and the high cost of the CCS technology effectively precludes its commercial deployment, even if the technology was ready. As a result, there are many technical, economic, and legal risks with CCS technology that must be addressed before an EGU developer would consider investing in a new multi-billion dollar plant. These risks will not be taken if the new plant might have to cease operation after ten years if CCS cannot achieve a regulatory standard developed without any real-world data. Without much greater certainty on the timing and success of CCS commercialization efforts, such risk simply will not be acceptable and will effectively preclude the development of any new generation technology that must rely on CCS to operate. It is unlikely that the developer could ever obtain the necessary funding for building the plant until these matters are satisfactorily addressed. Lending institutions and state regulatory commissions will not risk several billion dollars unless they obtain adequate assurances that a CCS technology is capable of achieving the CO2 performance standard and can be installed at the new coal-fueled plant within the initial ten-year period of operation. Simply put, a utility operator will never select an electric generating technology or unit design that requires a control equipment retrofit of unknown technology to be installed ten years after initial operation.

Work done to date on CCS technology has yielded incremental improvements in cost and process efficiency. Substantial “game changing” innovations for CCS cost and performance will require the integration of new CCS technologies with advanced next generation coal-based systems, such as advanced IGCC, oxycombustion, and chemical looping combustion or gasification. As a result, EPA’s proposed rule is likely to delay for many years the development of CCS technology because new coal-fueled generation will not be built and, without the development of such new coal-based units in the future, the incentive to invest in and advance CCS technology will be greatly diminished.

As stated above, the current regulatory climate and market are such that no new coal-fired power plants are likely to be built so long as gas prices remain low.

Currently, most power generation-related technology development is focused on modifications and retrofit applications to the existing power plant fleet. Yet, most of the existing fleet in the US is over 30 years of age and already carrying expensive and complex retrofit systems, many of which were installed at costs rivaling the original power plant. Any further modification or retrofit will add complexity and most likely reduce the energy efficiency of the power plant.

QUESTION: let us talk about this shift in natural gas. I am all for it, but I think you alluded to—just like an electricity grid and a transmission grid, we may have some pipeline constraints. Can you talk about that?

Mr. MCCLURE. Well, there is a recent example, a very real example in New England that I think many of you have become familiar with where high demand for electricity and a very cold snap, high demand for gas for heating created a real spike in prices for both natural gas and electricity. There are other parts of the country where we simply don’t have the gas pipeline infrastructure. We could not convert our two coal plants to gas because there is no— not an adequate gas line infrastructure there.

Mr. SHIMKUS. And Mr. Gramlich, that is some of the challenges on wind power on the reverse side, just with the transmission grid, is it not?

Mr. GRAMLICH. Transmission is very helpful——

Mr. SHIMKUS. Just trying to wield that power to places that it might be used. So those are—I think those are especially issues in a bipartisan manner that we can talk about is expanding our natural gas pipeline, expanding the transmission grid.

Mr. MCCULLOUGH. We will be converting just a few plants to natural gas, but that will be for capacity reserve reasons, not for, you know, overall energy economics. You lose some efficiency, as these units are designed to burn coal and gas can’t get steam temperatures to the same efficiency levels that it was designed for, so it is not going to be a very efficient use of natural gas, as you try to meet the energy needs of your jurisdiction.

Mrs. CHRISTENSEN.  We are looking at wind energy. We  are doing some solar, but haven’t really moved towards wind yet. For a place that doesn’t have a grid that supplies energy from diverse areas, like the Virgin Islands, do you think that we could reach that same reliability from wind or would we need additional reserve capacity? I am thinking that we couldn’t rely on it.

Mr. FOWKE. You know without specifics, the smaller the grid and the larger the one single source of wind would be, I think the more problems you would have making sure that it is integrated efficiently and reliably.

 

Mr. OLSON. We all know more people means more homes, more commerce, more industry, more need for electricity generation. ERCOT is the agency in our State of Texas that regulates most of the electricity in the State, about 90 percent of it, and they did a recent study that says we may have a power crisis by 2014 unless we have new power generation brought up online. We will be short 2,500 megawatts is their estimate. If we have a heat wave like the August before last, we were over 100 degrees in every part of the State for over a month. If that happens again, we will have brownouts or blackouts. We need more capacity.

 

 

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Nature: All women in the world should have the right to birth control

Source: Masri L (2019) “Two is enough” Egypt tells poor families as population booms. The Star.

Preface. Nature is one of the top science journals, so it is a big deal that Nature finally acknowledged a growing population will wreak enormous havoc on the world, and that the best way to slow the human juggernaut of destruction is for women to be able to control their own bodies and lives.

Fewer people is the only way to slow down climate change, pollution, poverty,  depletion of  (rain)forests, topsoil, aquifers, housing shortages, low-paying jobs and unemployment, and so on. Can you even think of a single problem that would not be helped by fewer people?

Continue reading

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67% of USA counties still in recession — lower incomes than 2009

[ Time magazine points out that most of the green counties are oil drilling locations, which in 2016 are quickly losing jobs ]

Wilson, C. December 15, 2015. See How Well Your Neighbors Have Recovered From the Recession. Time Magazine.

The recession may have officially ended in mid-2009, but millions of working Americans have seen their income remain stagnant. New figures from the U.S. Census Bureau confirm that the median household income in the U.S. was $53,482 between 2010 and 2014, down from $56,568 between 2005 and 2009 when adjusted for inflation—a drop of 5%. Only 1,038 of 3,142 counties have a higher median income than they did five years ago. The following map shades every county by its growth or decline in median income since 2009.

Time mag most of USA still not recovered since 2009

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Nearly a third of cacti threatened with extinction

Illegal trade contributes to placing cacti among world’s most threatened species – IUCN Red List

05 October 2015 | International news release

Gland, Switzerland, 5 October 2015 (IUCN) – Thirty-one percent of cactus species are threatened with extinction, according to the first comprehensive, global assessment of the species group by IUCN and partners, published today in the journal Nature Plants. This places cacti among the most threatened taxonomic groups assessed on The IUCN Red List of Threatened Species™ – more threatened than mammals and birds.

According to the report, cacti are under increasing pressure from human activity, with more than half of the world’s 1,480 cactus species used by people. The illegal trade of live plants and seeds for the horticultural industry and private collections, as well as their unsustainable harvesting are the main threats to cacti, affecting 47% of threatened species.

“These findings are disturbing,” says Inger Andersen, IUCN Director General. “They confirm that the scale of the illegal wildlife trade – including trade in plants – is much greater than we had previously thought, and that wildlife trafficking concerns many more species than the charismatic rhinos and elephants which tend to receive global attention. We must urgently step up international efforts to tackle the illegal wildlife trade and strengthen the implementation of the CITES Convention on International Trade in Endangered Species, if we want to prevent the further decline of these species.”

Other threats to cacti include smallholder livestock ranching affecting 31% of threatened species, and smallholder annual agriculture affecting 24% of threatened species. Residential and commercial development, quarrying and aquaculture – particularly shrimp farming, which expands into cacti’s habitats – are also among major threats faced by these species.

Cacti are key components of New World arid ecosystems and are critical to the survival of many animal species. They provide a source of food and water for many species including deer, woodrats, rabbits, coyotes, turkeys, quails, lizards and tortoises, all of which help with cactus seed dispersal in return. Cactus flowers provide nectar to hummingbirds and bats, as well as bees, moths and other insects, which, in turn, pollinate the plants.

Cactus species are widely used by people in the horticultural trade, as well as for food and for medicine. Their fruit and highly nutritious stems are an important food source for rural communities. The nutritional value of one cactus stem of Opuntia ficus-indica – a ‘prickly pear’ cactus popular in Mexico, where it is known as ‘nopal’ – is often compared to that of a beef steak, and the roots of species such as Ariocarpus kotschoubeyanus which is listed as Near Threatened, are used as anti-inflammatories.

Trade in cactus species occurs at national and international levels and is often illegal, with 86% of threatened cacti used in horticulture taken from wild populations. European and Asian collectors are the biggest contributors to the illegal cactus trade. Specimens taken from the wild are particularly sought after due to their rarity.

“The results of this assessment come as a shock to us,” says Barbara Goettsch, lead author of the study and Co-Chair of IUCN’s Cactus and Succulent Plant Specialist Group. “We did not expect cacti to be so highly threatened and for illegal trade to be such an important driver of their decline. Their loss could have far-reaching consequences for the diversity and ecology of arid lands and for local communities dependent on wild-harvested fruit and stems.”

“This study highlights the need for better and more sustainable management of cactus populations within range countries. With the current human population growth, these plants cannot sustain such high levels of collection and habitat loss.”

Cacti are renowned for their diverse forms and beautiful flowers. They are endemic to New World arid lands except for one species, Mistletoe Cactus (Rhipsalis baccifera), which is also found in southern Africa, Madagascar and Sri Lanka. Hotspots for threatened cactus species include arid areas of Brazil, Chile, Mexico and Uruguay. These areas are perceived as uncharismatic and unimportant, even though they are rich in biodiversity, hence arid-land species like cacti are often overlooked in conservation planning. The report’s authors highlight the need to broaden arid land protected area coverage and raise awareness about the importance of sustainable collection of cacti from the wild in order to better conserve the species.

Additional notes:

“Cacti are extraordinary plants that concentrate water and nutrients used by natural and human communities, in some of the world’s most challenging environments,” says Mary Klein, President of NatureServe, an IUCN partner in facilitating assessments of North American and Caribbean cacti. “This study confirms that cacti are especially vulnerable, but that with focused attention on reducing the threats such as illegal harvest, we can conserve these miracles of nature for the future.”

• The seven most threatened taxonomic groups assessed on The IUCN Red List of Threatened Species™ are cycads (63%), amphibians (41%), conifers (34%), warm-water reef building corals (33%), cacti (31%), mammals (25%) and birds (13%).

• Cacti are native to the New World but species have been introduced to Africa, Australia, and Europe. For example, prickly pears (Opuntia spp.) were introduced to Australia in the 19th century and have since then become invasive species, spreading throughout the Outback and outcompeting native flora.

• Agriculture is the most widespread threat to cacti, affecting species in large parts of northern Mexico, Mesoamerica and the southern part of South America. Cacti in coastal areas, such as the Caribbean and the Baja California peninsula in Mexico, are mainly affected by residential and commercial development. In southern Brazil, conversion of land for eucalyptus plantations is affecting at least 27 species, including the Endangered Parodia muricata.

• More than 30 species, such as the Critically Endangered Coleocephalocereus purpureus in eastern Brazil are affected by quarrying. Arrojadoa marylaniae, also listed as Critically Endangered, may go extinct in the near future, as the single white quartz rock on which it is exclusively found is threatened by mining.

• In the north-western part of Mexico, species such as the Critically Endangered Corynopuntia reflexispina are unexpectedly becoming threatened by aquaculture, as shrimp farming expands into the desert.

 

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Chemicals banned in cosmetics

The environmental working group has this to say about cosmetics:

“American families assume personal care products on the market today have been tested by the federal government. Unfortunately, the personal care products industry remains largely unregulated. The FDA does not even require safety testing of ingredients in personal care products before they are used.  While the Food and Drug Administration (FDA) has limited authority to regulate cosmetics, our current laws leave them powerless to screen for chemicals that have been linked to cancer, harm to the reproductive system in both men and women, and severe allergies, among other health effects. The federal law designed to ensure that personal care products are safe has remained largely unchanged since 1938.

Americans have waited far too long for cosmetic safety reform. The Personal Care Products Safety Act would reform regulation of personal care products, requiring companies to ensure that their products are safe before marketing them and giving FDA the tools it needs to protect the public.”

These lists of toxic chemicals are constantly updated (see if your shampoo, soap, and so on use any of these chemicals):

Ingredients Banned in EU: http://ec.europa.eu/growth/tools-databases/cosing/index.cfm?fuseaction=search.results&annex_v2=II&search

FDA Banned/Restricted List: http://www.fda.gov/Cosmetics/GuidanceRegulation/LawsRegulations/ucm127406.htm#prohibited

Canadian Banned List: http://www.hc-sc.gc.ca/cps-spc/cosmet-person/hot-list-critique/hotlist-liste-eng.php

Beautycounter Never List: http://www.beautycounter.com/the-never-list/

 

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Why the Grid is getting less reliable. House Hearing 2013.

House 113-40. May 9, 2013. Grid reliability challenges in a shifting energy resource landscape. U.S. House of Representatives. 176 pages.

Mr. Jonathan A. Lesser, President Continental Economics, Inc.

[This is a really good introduction to how the grid works and the problems caused by intermittent wind (and solar)]

I appreciate the invitation from the Committee to testify today regarding the costs and the reliability implications of integrating “intermittent generating resources. By way of background, I began my professional career almost 30 years ago, as a load forecaster for Idaho Power. In my work for government, industry, and as a consultant, I have been involved with, and researched, many facets of the electric industry, as well as corresponding policy issues, at both the national and individual state levels. These issues have covered: (1) the “nuts and bolts” issues involved in regulating and designing electric rates; (2) electric industry restructuring, and the introduction of wholesale and retail competition; (3) environmental regulations affecting energy resource development and use; (4) the costs and benefits of renewable generation; (5) the economic impacts of electric competition; and (6) the economic consequences of energy subsidies. I have testified numerous times before state regulatory commissions, before the Federal Energy Regulatory Commission, before legislative committees in many other states, and before international energy regulators. I have co-authored three textbooks, including Environmental Economics and Policy, Fundamentals of Energy Regulation (for which my co-author and I are now preparing a second edition), and Principles of Utility Corporate Finance. My testimony this morning focuses on “intermittent” generating resources – primarily wind and solar photovoltaics (PV)– their impact on electric system reliability, and the costs that must be borne to “integrate such resources onto the power grid.

On July 6, 2012, when the demand for electricity in northern Illinois and Chicago hit a record of over 22,000 megawatts, the average amount of wind generation that day was a virtually non-existent 4 megawatts. The potential loss of thousands of megawatts of intermittent generation for a short time, which has occurred in the past, means that system operators must increase the quantity of available reserve capacity. That increases cost. It is as if thousands of vehicles have their engines idling, waiting to run on the possibility they are needed. One such study, for example, by the American Tradition Institute, found reliability related transmission losses and costs for Texas alone are over $1 billion per year.

In regions with wholesale electric markets, system operators use next day forecasts of availability and demand to determine how they will operate the power system. Although even wind advocates acknowledge wind’s inherent intermittency, they claim wind generation can be predicted accurately several days in advance, allowing system operators to reduce, if not eliminate, the impacts of wind’s volatility. Forecasts and operational data, including—in areas including Texas as well as in European countries, show that is not the case.

Federal and state policies that subsidize development of intermittent generating resources, especially wind generation, reduce the reliability of the power system because of the inherently volatile nature of the output of such resources.

To compensate for this reduced reliability, power system operators must increase reserves of fossil-fuel resources, primarily gas-fired generating plants, to compensate for the ups-and-downs of intermittent resource availability, including the potential loss of thousands of megawatts of generation from intermittent resources when conditions change (i.e., the wind stops blowing or the sun stops shining). These additional reserve requirements increase reliability-related integration costs, which are socialized across all customers. As more intermittent resources are built, they increase the severity of reliability issues and increase per megawatt- hour integration costs, as well as total integration costs.

Compounding these reliability problems are policies that socialize the costs to build of new high-voltage transmission lines needed to connect intermittent resources, especially wind generation. Because wind turbines require a lot of land per turbine, wind facilities are typically built in rural areas far from urban load centers, because land is so much cheaper.

When wind turbines are built in these locations, new transmission lines must often be built to connect them to the power grid. And, because they are so far away from load centers, there are significant line losses, which reduce the actual amount of electricity delivered to customers.

Moreover, wind generation, by far the largest intermittent resource, with over 60,000 megawatts of installed capacity, tends to produce the greatest amount of electricity when the demand for electricity is lowest (at night, and in spring and fall). As a result, wind power is exacerbating economic losses of traditional “baseload generating units that are designed to run around-the-clock, and are a crucial element of providing reliable, low-cost electricity.

Subsidies, such as the wind PTC, plus socialization of reliability-related and transmission integration costs, means that intermittent generation developers pay only a small fraction of the true costs they impose on the electric system.

This is having adverse economic impacts – causing traditional generation resources to retire prematurely because of artificial price suppression – and thus further exacerbating reliability issues, and suppressing new generation investment. Left unchecked, these subsidies for intermittent generation will reduce reliability, lead to higher electric prices, and reduce economic growth and job creation.

Therefore, I recommend that (1) To the extent possible, require all generators to pay for the reliability-related integration costs they cause, rather than socializing those cost across all electric consumers; and (2) Eliminate all subsidies paid to electric generators, whether they are intermittent resources or schedulable resources.

WHAT “INTEGRATION” OF INTERMITTENT RESOURCES MEANS

Intermittent power resources are defined as resources that cannot be scheduled to provide a known quantity of electric power at a given time. There are two primary categories of intermittent resources that are the focus of integration studies and reliability concerns: wind and solar PV power. Wind turbines, of course, can only generate electricity when the wind is blowing. Solar PV can only generate electricity when the sun is shining. In contrast, fossil-fuel, nuclear, and hydroelectric power (with storage dams, such as Grand Coulee Dam on the Columbia River) can be scheduled. For example, barring the very low chance of a forced outage, a modern natural gas-fired combined-cycle generating unit will provide power around-the-clock, and can be ramped up or down quickly to meet the ever changing demand for electricity. Similarly, the amount of power produced by a hydroelectric plant can be varied simply by changing the amount of water that flows through the turbines.

Integration costs can be broken down into two main categories. The first category includes the costs of ensuring the power system is operated safely and reliably from moment to moment. The second category includes the costs of connecting resources to the power grid, called “interconnection costs, specifically building new transmission lines and substations to deliver electricity from individual generating units to load centers.

Integration and Power System Reliability

To operate a power system, the supply of electricity must continuously match demand. If demand exceeds supply, voltage and frequency drops. For example, you may notice that, when the compressor motor in your refrigerator starts, the lights in your home dim slightly. When the compressor starts, the demand for electricity increases suddenly. This causes a momentary drop in voltage, which causes the lights to dim. If power supply exceeds demand, it can cause voltage levels to increase. If the voltage is too high for the lights in your home, they will burn out, because too much electricity is being delivered to it.

Because the overall demand for electricity changes from minute-to-minute, power system operators must continually adjust electric supply to maintain voltage and frequency within operating limits. If they don’t, there will be a blackout.

The constant changing of electric supply to match demand is called “load following.” The most common method for load following is called “automatic generation control” or AGC. (It is also called “frequency reserve.”) Today, AGC consists of computer software installed at certain generating plants whose output can be increased or decreased constantly in response to changing demand. Basically, what happens is that the AGC software increases or decreases the speed of a generating turbine: when demand increases, the turbine speed is increased, just like the engine in your car speeds up when you press on the accelerator; when demand decreases, the turbine speed is slowed.

In addition to needing to adjust electric supply to meet ever changing demand, power system operators have to plan for contingencies, in other words, unexpected events. For example, on those hot, sultry August days in Washington, DC, the demand for electricity peaks because of air conditioning load. Power system operators must ensure there are sufficient resources to meet that peak demand. If a generating plant breaks down unexpectedly on that same day, there must be enough reserve capacity to take up the slack. Thus, there must always be generating capacity held in reserve, either generating units that can be switched on quickly, mechanisms to reduce demand, such as reducing electric consumption at a large manufacturer, or both. And, in fact, in the regional power system that includes DC, called PJM, both types of reserves exist.

These additional reserves come in three different flavors: spinning, non- spinning, and operating reserves. Spinning reserves are generators that are running, but not connected to the grid. They are the electric equivalent of your car engine running, but the car is in neutral gear. If you need to move, all you have to do is put the car in gear (or press on the accelerator) and away you go.

Non-spinning reserve refers to generators that are not running, but can be brought on line very quickly, generally within 10 – 30 minutes. The vehicular analogy for non-spinning reserve is finding your keys, walking out to the car, starting the engine, and driving off. You can do it relatively quickly, assuming you can find your keys, but it is certainly not as quick as if you were already in the car with the engine running.

The final category of reserves are called operating reserves. Operating reserves are generators that can be brought on line, but which require at least 30 minutes to do so. For example, as a private pilot, I can tell you that you don’t simply jump into an airplane, start the engine and fly off as quickly as you can drive off in your car.

Gas-fired generators provide most reserve capacity because they can be started, stopped, or ramped up and down fairly easily. In contrast, coal and nuclear plants are designed to run around-the-clock, generating the same amount of power all the time. Starting up a nuclear plant, for example, takes several days, and a baseload coal plant can take many hours. Although the output of both types of generating plants can be adjusted, doing so increases the “wear-and-tear” on them and raises their operating costs.

Intermittent Resources Increase the Need for Reserves

Given this description of the four types of power system reserves, it is not surprising that intermittent resources like wind and solar PV cannot provide those reserves by their very nature. Because you cannot count on the wind blowing at a certain time on a certain day, a wind turbine cannot be relied on to provide electricity if suddenly called on. And, if you have a sudden need for backup generating capacity after dark, solar PV cannot help.

In fact, intermittent resources increase the need for reserves.

The reason for this is that, not only must system operators ensure the reliability of the electric system by (1) addressing constantly changing demand, (2) having enough reserve capacity to meet demand when it is at its highest, and (3) planning for low-likelihood contingencies, they must also (4) cope with the wide swings in output from intermittent resources. That, in a nutshell, is what integrating intermittent generating resources is all about, and why integrating intermittent resources is both challenging and costly.

The integration challenge is exacerbated as the quantity of intermittent resources increases on the power system. For example, peak electric demand in PJM is over 100,000 MW in the summer. If PJM system operators had to integrate 10 MW of solar PV, doing so would be trivial. The amount of solar PV is so small that its impact on the overall PJM system would be negligible. However, the integration challenge becomes and is far more difficult and more costly to address as the quantity of intermittent resources increases.

Today, wind generation, with over 60,000 MW installed, is by far the largest intermittent resource and is clustered in the windier regions of the country, including the Pacific Northwest, Texas, and the Midwest. Texas, for example, has over 12,000 MW of wind generating capacity, California over 5,500 MW, and Iowa has over 5,000 MW. There is about 7,000 MW of wind in the Pacific Northwest that the Bonneville Power Administration must integrate. The Midwest ISO (MISO), which spans across 15 states, including most of Illinois, Indiana, Iowa, Michigan, Minnesota, and Wisconsin, integrates over 12,000 MW of wind capacity.

Some Examples

The magnitude and concentration of wind generation in these states has made integration more difficult and costly, and posed challenges for maintaining overall system reliability. The problem stems from huge swings in wind generation in very short periods of time. For example, on October 28, 2011, wind generation decreased in MISO by 2,700 MW in just two hours. In ERCOT, on December 30, 2011, wind generation decreased 2,079 MW in one hour and over 6, 100 MW between 6AM and 4PM that day. Still another example took place on October 16, 2012. On that day, wind generation on the Bonneville Power Administration system was 4,300 MW, accounting for 85% of total generation in the pre-dawn hours. The next day, wind generation fell almost to zero.

Not only do such large swings in generation by intermittent resources pose reliability concerns, so does the pattern of generation availability. Whereas solar PV tends to provide the greatest amount of generation on days when power demand peaks – such as those hot, sultry, and windless August days in DC – wind generation tends to be least available when demand is greatest, and vice-versa, as I have documented in my own published research.

Chicago’s experience during last summer’s heat wave provides a compelling local example of wind power’s failure to provide power on the hottest days. During this heat wave, Illinois wind generated less than 5% of its capacity during the record breaking heat, producing only an average of 120 MW of electricity from the over 2,700 MW installed. On July 6, 2012, when the demand for electricity in northern Illinois and Chicago hit a record of over 22,000 MW, the average amount of wind power available on that day was a virtually nonexistent 4 MW.

Integration and Interconnection Costs

By definition, generating resources that are part of the “bulk power system are those which are electrically connected to the power grid. A regional system like PJM or MISO, for example, has hundreds of generating plants, whose operations are all coordinated by system operators.

Historically, most generating plants were built near load centers. For example, generating plants were built near DC along the Potomac River to provide electricity to the city. Building generating plants near load centers reduces costs in two ways: first, it reduces the amount of power that is “lost” over transmission lines because of electrical resistance and, second, it reduces the need to build miles of transmission lines to deliver power to those load centers.

Today, new gas-fired generating plants are built near load centers. The plants have small footprints and are clean. In New York City, for example, new gas- fired generators have been built in Brooklyn and Queens, both to meet growing electric demand and to replace the generation from old, inefficient and highly polluting oil-fired plants.

Although solar PV can be installed on rooftops, wind generators are typically built in remote regions. There are several reasons for this. First, wind generators have to be built where the wind is, which tends to be more remote areas of the Midwest and western Texas. Second, wind generation requires a lot of land area because wind turbines cannot be sited too closely together. (Otherwise, they interfere with each other’s air flow, and reduce generation.) Because land is generally expensive in populated areas, wind generation developers have thus located turbines on low-cost land far from load centers. As a result of locating wind generation (and some solar facilities) in remote areas, billions of dollars must be invested in new transmission lines to deliver that power to cities and towns where the electricity is needed. Texas, for example, has built a series of transmission lines, called CRES, to connect wind generation in west Texas to the population centers in eastern Texas. Total cost so far: $6.9 billion.

III. THE COST OF INTEGRATING INTERMITTENT RESOURCES

As discussed in Section II, to ensure system reliability, operators must ensure there is enough reserve capacity to meet contingencies. As more intermittent resources are added to the power system, one of the most important contingencies has become the potential lack of supply from these resources. Again, given its magnitude, wind generation is far more of an issue than is solar PV. Second, the costs of building new transmission lines to connect intermittent resources to the power grid must be included.

The potential loss of thousands of MW of intermittent generation in a short time frame means that system operators must increase the quantity of available reserve capacity. This means the need for spinning, non-spinning, and operating reserves increases, which increases costs. It is as if thousands of vehicles are required to have their engines idling, waiting for the possibility they will be needed.

Furthermore, the variability of intermittent resource output increases the costs of load following. Not only must system operators compensate for constant changes in electric demand, they must also compensate for constant changes in intermittent resource output. As a result, more gas-fired generators must be sped up and slowed down to ensure supply and demand match. That’s costly, more so than simply operating a generator at a constant rate for long periods of time. Operating gas-fired generators in this way is inefficient (like stop-and-go driving in the city), which increases costs and air pollution.

In regions with wholesale electric markets, such as Texas, the Midwest, and PJM, system operators use next-day forecasts of generator availability and demand to determine how they will ensure the power system can meet demand and operate safely. For these planning efforts, it is also crucial to forecast intermittent resource availability, because those forecasts determine the quantity of reserve generating capacity that system planners must ensure is available “just in case.

Although even wind advocates acknowledge wind’s inherent intermittency, they claim wind generation can be predicted accurately several days in advance, allowing system operators to reduce, if not eliminate, the impacts of wind’s volatility. However, forecast and operational data in areas including Texas, as well as in European countries, do not support such a forecast.

In other words, forecasting intermittent resource availability is not especially accurate. This adds to the costs of integrating intermittent resources because inaccurate short term forecasts of intermittent generation increases the overall cost of meeting electric demand: system planners either must reimburse other generators who had been scheduled to operate, but were not needed because actual wind generation was greater than forecast, or reimburse those generators because they had not been scheduled, but were required to operate because actual wind generation was less than forecast.

Integration Cost Estimates

There have been a number of studies of the costs of integrating wind generation. In 2011, the National Renewable Energy Laboratory (NREL) published its Eastern Wind Integration Study (EWITS), which focused on the integration costs associated with maintaining system reliability. In December 2012, the American Tradition Institute (ATI) published a study that also estimated the additional costs associated with building transmission lines, power losses along those lines, and the additional fuel costs associated with operating fossil fuel generation needed to “firm up” intermittent generation.

The studies show that reliability-related integration costs increase on a per megawatt-hour (MWh) basis as more wind generation is added. This makes intuitive sense: very small amounts of wind or solar PV will have little or no impact on overall system reliability. However, as more and more intermittent generating resources have been added, their adverse impacts on reliability have increased. These impacts will only become more pronounced, and the integration costs incurred to maintain system reliability larger, as more intermittent resources are added to the power grid.

Based on the NREL study, which reported a range of reliability-related integration costs between $1 per MWh and $12 per MWh, a typical cost estimate for reliability-related integration costs of intermittent generation is $5 per MWh. In Texas, for example, applying this value to the 12,000 MW of installed capacity, and assuming a 30% capacity factor (where a generator running around-the-clock for an entire year would have a 100% capacity factor), this implies integration costs of over $150 million per year – costs that must be paid by electric consumers in Texas to ensure reliability.

The 2012 ATI study estimated the costs of the additional fuel consumption associated with having to cycle fossil generators to meet changing intermittent resource generation levels, as well as the additional costs associated with building new transmission lines and the power losses on those lines. In some cases, there may be sufficient existing transmission capacity to avoid the need to construct new lines. However, even if that is the case, there will still be line losses whose costs are part of integrating intermittent resources located far from load centers.

Using data from EWITS, they estimated the cost of new transmission lines built to deliver power generated by far-flung wind units to be $15/MWh. They also derived an estimate of $12/MWh as the cost of the line losses, for a total of $27/MWh. If we apply these values to Texas, where transmission was built specifically to deliver wind generation to load centers hundreds of miles away, the additional cost is over $850 million per year. Thus, the reliability-related and transmission/losses costs for Texas alone are $1 billion per year.

SUBSIDIES AND COST SOCIALIZATION ARE EXACERBATING INTEGRATION COST ISSUES

The fact that integrating intermittent generating resources is more costly than schedulable resources is not the reason for this hearing. Instead, this hearing seeks to examine the reliability challenges of integrating these resources. The issue of maintaining the reliability of the power system in the face of the shifting energy landscape, as the hearing’s title frames it, and the resulting integration costs can be traced directly to (1) subsidies designed to incent construction of intermittent resources; and (2) socialization of integration costs.

Consider the following analogy: long-haul trucks typically are assessed road taxes based on their weight. The reason is that, the heavier the truck, the greater the damage caused to roadways.

Assessing road taxes based on the damages caused makes intuitive sense, both from the standpoint of economic efficiency and fairness. Thus, the fact that long-haul trucks cause more road damage than passenger cars is not an issue because truck owners pay those costs. There may be disagreements as to whether the taxes are set correctly, but the “user pays” principle is reasonable.

In the case of intermittent resources, however, the subsidies and mandates designed to incent their development, such as the wind production tax credit (PTC) and individual state renewable portfolio standards (RPS), plus the socialization of integration costs among all users, has increased reliability concerns. In other words, we have put into place policies that exacerbate inefficient investments because they do not require intermittent resource developers to pay the full costs of their investments. As Commissioner Donna Nelson of the Texas Public Utility Commission stated last year: Federal incentives for renewable energy … have distorted the competitive wholesale market in ERCOT. Wind has been supported by a federal production tax credit that provides $22 per MWh [now $23 per MWh] of energy generated by a wind resource. With this substantial incentive, wind resources can actually bid negative prices into the market and still make a profit.

We’ve seen a number of days with a negative clearing price in the west zone of ERCOT where most of the wind resources are installed … The market distortions caused by renewable energy incentives are one of the primary causes I believe of our current resource adequacy issue… [T]his distortion makes it difficult for other generation types to recover their cost and discourages investment in new generation.

Subsidies Contribute to Premature Retirement of Schedulable Resources, Which Reduces System Reliability

Although not specifically limited to wind generation, approximately 75% of the total PTC credits claimed to date have been for wind generation. The magnitude of the PTC subsidy—far larger than any other form of production based energy subsidy has incented thousands of MW of wind generation. Therefore, I will focus my testimony on its impacts on system reliability.

Currently, the PTC is $23 per MWh. Because it is a tax-credit, on a before-tax basis, it is over $35 per MWh. That amount is actually higher than the market price of electricity in many regions, because of low natural gas prices. Basic economic principles state that you don’t operate your plant if doing so costs more than the value of the output you produce. For example, an old, inefficient generating plant that consumes $50 worth of fuel to generate one MWh of power will not generate if the price of electricity is less than $50 per MWh.

With the PTC, however, the economics change. If that same generator received a $35 per MWh tax credit, then it makes economic sense to operate as long as the price of electricity is at least $15 MWh ($50 – $35 = $15). The cost of operating a wind generator is close to zero.

It turns out that electric market prices can actually be negative. Although that sounds impossible – why would anyone ever pay you to use their product?– it happens in the power industry. The reason is that baseload generators cannot just be switched on and off at will. Thus, these plants will continue to operate regardless of the price of electricity. Now, if there were no PTC, then wind generators, which can be switched off at will, would not generate any power whenever prices were negative. However, with a $35 per MWh PTC, they will continue to generate as long as the price of electricity is greater than -$35 per MWh.

Coupled with the fact that wind generation tends to produce the greatest amount of power at night and in Spring and Fall, when electric demand is lowest, the wind PTC has greatly exacerbated the number of hours where electric prices are negative.

Although negative prices may sound like a great deal, from a reliability standpoint, they are harmful. The reason is that the more hours of the year prices are negative, the greater the losses to fossil fuel generators who must run, and the greater the likelihood they will shut down because of uneconomic subsidies provided to intermittent generating resources. For example, last October, PPL corporation announced it was considering shutting down its Correte coal-fired plant in Montana because of subsidized wind generation, stating: “Wind farms can make a profit even in low demand time of the season . . . because they can pay people to take their electricity . . . What we want to see is a level playing field for our plants. What bothers us is that there are actually companies paying people to take their power” Last December, the company announced it was selling all of its Montana generating plants, including Corrette, because it cannot operate the generating units profitably .

As schedulable generating plants shut down because it is uneconomic for them to operate, they jeopardize reliability, and increase the costs of maintaining reliability because additional gas-fired generators must be placed on stand-by or operated at a higher cost. Thus, rather than being able to schedule a “least-cost” mix of baseload (round-the-clock), intermediate, and peaking generators, those operators will have to meet electric demand with a more costly mix of resources, and spend more to ensure there are sufficient reserves to meet all contingencies.

Subsidies Incent Inefficient Development of Intermittent Generating Resources, Which Exacerbates Reliability Concerns and Raises Integration Costs

Subsidies promote development of generating resources that would not otherwise be competitive.

And, on a per-MWh basis, intermittent generating resources receive the largest subsidies by far. At a pre-tax value of $35 per MWh, the PTC is often greater than the market price of electricity. For example, in 2012, the overall average price in the PJM electric energy market was $33.11 per MWh – less than the PTC!14 A subsidy that is greater than the average market price introduces huge market distortions.

Consider an analogy: suppose the government subsidized gasoline to such an extent that consumers paid a price of just one penny per gallon. The amount of driving and total gasoline use would skyrocket, increasing congestion, sprawl, damage to highways, and air and water pollution. The market for fuel efficient vehicles would quickly collapse.

The PTC, coupled with socializing almost all of the reliability-related integration costs caused by intermittent resources, is driving huge levels of investment in intermittent resources, especially wind generation, exacerbating reliability issues and raising integration costs still further. As more wind generation is developed, it is built in locations with less favorable wind conditions and thus lower overall economic efficiency. This is not unusual – it makes sense to develop the lowest cost resources first, because they provide the greatest return on investment. But when such a large percentage of development costs are socialized – the PTC is paid by taxpayers and integration costs (reliability-related and new transmission lines) are paid by all electric consumers – the result is inefficient investment that would not take place but for the subsidies.

There is justification for the socialization of some transmission-system costs, because transmission capacity provides for reliable electric service, which is a public good. Thus, to the extent that additional transmission capacity increases system reliability, a reasoned economic argument can be made that, because all users of the transmission system benefit from improved reliability, the costs should be shared among all users. In essence, this is a beneficiary-pays approach to cost allocation. However, subsidized (and unsubsidized) intermittent generation does not improve reliability. In fact, it reduces reliability because of its inherent unpredictability/variability, which requires additional back-up generation and raises integration costs.

Despite this adverse reliability impact, the costs of new high-voltage transmission capacity built to deliver intermittent resource-generated electricity onto the power system are still socialized among all users, who then incur yet more costs to maintain the reliability of the power system because it is adversely affected by the intermittent resources. The net effect is to increase the magnitude of the costs that are socialized because subsidies encourage excess intermittent resource development.

MYTHS AND FACTS

Many (but not all) proponents of intermittent resources employ a variety of justifications for their continued subsidization. These include: (1)that it is necessary to protect “infant” industries so they may become fully competitive in the market, (2) that geographic dispersion of intermittent resources smooth’s out the ups-and-downs of their output (i.e., if the sun is not shining or the wind is not blowing in location A, they will be in location B); (3) that intermittent resources will lead to energy “independence” from Middle East oil; (4) that price “suppression” caused by subsidized intermittent resources benefits consumers; and (5) that intermittent resources are helping the economy by creating new “green” industry and “green” jobs. None of these arguments has any basis in fact.

The “Infant Industry” Myth

The first proponent of the “infant industry” argument was none other than Alexander Hamilton, over two centuries ago, to justify tariffs that would protect U.S. industries from imported goods.

However, the reality is that intermittent generation resources have been subsidized since enactment of the Public Utilities Regulatory Policy Act of 1978. Production and investment tax credits have been in place for over two decades, since the passage of the Energy Policy Act of 1992. And, 30 states plus the District of Columbia have RPS mandates and eight others have RPS goals. No other forms of generation have ever been provided with both production subsidies of their costs and mandates that they be used. After 35 years of subsidies, and 60,000 MW of installed capacity, it is difficult to argue the wind industry is in its “infancy.” In fact, the U.S. Environmental Protection Agency considers wind a “mature industry.” Moreover, unlike solar PV, the prospects for further reductions in wind generation costs are likely small. It is certainly true that other generating resources have been subsidized. None, however, have been subsidized to the extent of intermittent generation, with direct production tax credits and usage mandates. The way to eliminate the adverse effects of subsidies – be they for energy, agriculture, or housing– is to eliminate subsidies.

In an April op-ed in the Wall Street Journal, Patrick Jenevein, the CEO of wind generation developer Tang Energy, said the following: If our communities can’t reasonably afford to purchase and rely on the wind power we sell, it is difficult to make the moral case for our businesses, let alone an economic one.

Yet as long as these subsidies and tax credits exist, clean energy executives will likely spend most of their time pursuing advanced legal and accounting methods rather than investing in studies, innovation, new transmission technology and turbine development.

In other words, Mr. Jenevein stated an obvious, but unspoken truth: the presence of subsidies drives developers to devote their efforts to continuing those subsidies, rather than improving the efficiency of their product.

The Geographic Dispersion Myth

Yet another myth is that the broad geographic dispersion of intermittent resources reduces, or eliminates, the variations in output that exacerbate reliability problems. My detailed research of wind generation over a four- year period in Texas, the Midwest, and PJM shows this to be false.

Figure 1, for example, compares wind generation throughout all PJM – which extends from Michigan in the north, to Kentucky in the southwest, to Virginia in the southeast – and hourly loads during the week of July 1-8, 2012, when the eastern half of the country was suffering a heat wave. Figure 1: PJM Hourly Load and Wind Generation, July 1-8, 2012

The figure clearly shows the huge volatility of wind generation from hour-to- hour. Worse, it shows an inverse relationship between wind generation and electricity demand: the greater the demand, the less the amount of wind, and vice-versa. From a reliability standpoint, this is the worst sort of generation pattern: when demand is at its highest, you want to have as much generation available as possible to meet that demand. Moreover, this same pattern is repeated throughout the year. Geographic dispersion does not reduce the volatile ups-and-downs of intermittent resource output.

The Energy Independence Myth

Still another myth is that intermittent resource development will promote independence from Middle East oil. This argument is clearly false, because the amount of petroleum used to generate electricity is negligible.

Thus, until electric vehicles replace the majority of internal combustion vehicles on the road, the idea that intermittent generating resources will help secure energy independence is clearly false.

The Price Suppression Myth

Intermittent generation developers (and other developers who receive subsidies to development generating plants) point to the “benefits” of lowering or “suppressing” market prices. Although artificially reducing prices may sound like it benefits consumers – it imposes far greater long-run costs.

In a recent research paper, Pennsylvania State University professors Briggs and Kleit examined this issue. Their work finds that the “benefits” of price “suppression” quickly disappear, as government intervention drives out otherwise economic existing generation and hinders the development of new resources in all states within the market. The reason is that subsidies, and even the threat of future subsidies, drives legitimate competitors out of the market, reducing unsubsidized supplies. Investors become far more wary of providing capital for new development, leading to an increase in financing costs and, again, less investment in the market. While subsidies benefit intermittent resource developers, they harm competitive markets and, thus, raise prices for consumers: the few benefit at the expense of the many.

Thus, when government intervenes on behalf of one generator it drives out other generators, taking with it not only competitive generation capacity, but also the jobs and tax base associated with generation that exits the market. Most importantly, they find that the adverse long-run impacts in all states far outweigh any short-term “benefits” of temporary price reductions.

The Green Jobs Myth

Finally, there is the “green” jobs myth, that subsidizing green energy, including intermittent generation, will create economic growth. Basic economics shows that this, too, is another myth.

You may have read about studies promoting the jobs potential of renewable generation and energy efficiency programs. Such programs, these studies conclude, will foster new industries and create thousands of new well-paying jobs. The more stringent the requirements and mandates, the greater the economic growth. The fatal flaw of these studies is they typically assume that the money to pay for these mandates falls from the sky. In reality, the money comes from all of us in the form of higher electric costs, higher taxes, or both. It is as if the sponsors of those studies conducted a cost-benefit analysis and completely ignored the cost side. Such an analysis will always conclude the benefits are greater than the costs, because you have assumed there are no costs.

A number of European countries, including Denmark, Germany, and Spain have tried to do so with renewable energy mandates. As a result, Danish businesses and consumers pay the highest electric rates in the world. Germany and Spain have limited their renewable programs, because the programs have been so costly and the resulting job creation so limited. They, too, pay very high electric rates that have damaged their competitiveness.

The fact that higher electric costs reduce economic growth and jobs is really just basic economics. For example, in April 2010, the Rhode Island Public Utilities Commission (PUC) rejected a proposed power purchase contract between Deepwater Wind (a small offshore wind development) and National Grid. One of the reasons cited by the Rhode Island PUC was the job killing effects of higher electric prices: It is basic economics to know that the more money a business spends on energy, whether it is renewable or fossil based, the less Rhode Island businesses can spend or invest, and the more likely existing jobs will be lost to pay for these higher costs.19 The Rhode Island PUC was not rejecting wind generation per se; it was rejecting a specific project that was far more expensive than other wind generation alternatives, and more expensive than the market price of power.

Subsidizing intermittent generation leads to higher long-run electric prices, reduced reliability, and greater integration costs to restore reliability. Higher electric prices reduce job growth. Despite the temptation, you simply cannot subsidize your way to long-term economic growth. That is the ultimate “free lunch” assumption, and it is simply untrue.

CONCLUSIONS AND RECOMMENDATIONS

As the Committee addresses these issues, I offer the following conclusions and policy recommendations: 1. To the extent possible, require all generators to pay for the reliability-related integration costs they cause, rather than socializing those cost across all electric consumers. Because intermittent generation has higher per MWh, integration costs than schedulable resources, requiring those generators to bear the costs they cause makes greater economic sense than further subsidizing them. 2. Eliminate all subsidies paid to electric generators, whether they are intermittent resources or schedulable resources. The subsidies provided by the PTC and state RPS mandates are especially distorting to markets, because of their magnitude and because they are production based, e.g., generators receiving this credit are incented to generate power even when power is not needed. Subsidizing intermittent generation is exacerbating reliability problems, causing increases in integration costs, and jeopardizing the stability of competitive electric markets. The wind PTC is especially egregious, because in many cases it is larger than the actual market price of electricity. Continuing subsidies for intermittent resources will lead to higher electric prices and reduced system reliability.

Mr. WHITFIELD. In your testimony, Dr. Lesser, you had a paragraph or so, and basically in which you said that increasing use of intermittent generating resources does create obstacles to reliability or at least it exacerbates reliability, and it increases integration cost to the consumers. Would you elaborate on that a little bit for me?

Mr. LESSER. The problem with integrating intermittent resources, like wind and solar, is that you have to, in addition to planning for the ups and downs of demand all the time, you have to have additional reserve capacity in case the wind stops blowing suddenly, and that has happened. Well, that means you have to have additional costs incurred for other reserve capacity. As a result, that increases cost.

Because wind is subsidized, you get more of it, you get greater investment in wind power. That is why you have a subsidy. That tends to increase the amount of wind capacity that exacerbates the reliability issues that grid operators have to deal with. Plus when you socialize transmission costs, such as building new transmission lines in Texas, which is now up to a cost of over $7 billion, that again, you are incenting that sort of investment, which raises costs for everyone and creates more reliability problems.

It is true that the grid operators can handle wind reliability at this point. But as the amount of wind penetration increases on the system, those costs will keep increasing, and it will become more difficult to maintain a reliable power system.

Mr. WHITFIELD. Now, you know, the production tax credit was recently extended for the wind industry, and we hear a lot about negative pricing or selling electricity generation at less than your cost. There is quite a bit of that going on in the wind industry. Would you elaborate on that?

Mr. LESSER. Negative pricing sounds great. It actually happens—and it sounds very strange because why would anyone, why would the market price for any good ever be negative? You know, why would someone want to pay you to buy what they are selling? But because of the production tax credit is negative 23—is $23 per megawatt, that translates on a before tax basis of $35 per megawatt. Well, so wind power producers get in at production tax credit, have an incentive to bid in their generation into the market as long as the price is greater than negative $35. And because other power producers, like nuclear and coal plants, which are designed to run round the clock, they keep their system operating. They can’t just shut the plants down. So you end up with excess supply in certain times of the year and you end up with negative prices. That the hours of negative pricing during the year is actually increasing. What you have now is when those prices are negative, so those coal nuclear operators are actually having to pay the grid to keep operating. That obviously increases their cost, reduces their profitability; they are having to shut down. In Minnesota, for example, I believe they announced the closure of one coal plant because of subsidized wind. Therefore, what happens is, you start shutting down those plants that are needed for reliability because of wind, subsidized wind generation, well, you still have to maintain reliability, so you have to have more reserve capacity, which again, increases cost.

Mr. HALL. Dr. Lesser, I notice in your testimony you mentioned the myth of green jobs, and I sure agree with you that there is a lot of myth involved there. And I guess the question is whether or not subsidies for renewables really are creating sustainable job and economic growth. The meeting today is about examining the challenges and the consumer impacts resulting from the increased use of natural gas and renewables. And I think sometime I would like to see us have a hearing here on really what fossil fuels do for us. And 2013 is not completed yet, but in 2012 indicates that from coal we get 37% of the preliminary U.S. electric generation and about 30% from natural gas. Those are hard, cold facts that we can’t fight.

Without fossil fuels, we would all have to work our way or feel our way out of this building right today, and go to a car that wouldn’t start, and get to a home that would be cold in the winter and too hot in the summertime. So we ought to have a hearing sometime on what fossil fuels are really still doing for us, but that is not what we are here for today. We need fossil fuels, and we need to depend on it, and certainly I would ask you that. There is a lot of discussion on renewables. And do you see this as a realistic expectation? If not, why not? Dr. Lesser.

Mr. LESSER. In my own view, you will see lots of studies that will show that, say, building more wind capacity, renewable generation subsidies will increase economic growth. Well, that is true, they will increase economic growth as long as the subsidies are continued, which is why they want to continue subsidies. The problem is those studies never look at the other side of the ledger, which is who is paying for it? They assume that the money just falls from the sky. You simply cannot subsidize your way to long-term, sustained economic growth. That is economic free-lunchism. It does not work. Europe has found this out. In Spain, Germany, Denmark, they are cutting back on their subsidies of renewable power because it simply doesn’t work. They cannot afford it. In terms of global climate change and emissions, there is a small impact on emissions because of renewables, but it is very small, because you have to operate the remaining parts of the power grid more inefficiently by cycling conventional plants up and down. It is like the difference between driving your car in the city, where you are in stop-and-go driving, versus driving at a constant speed on the highway. It is less efficient; therefore, there are more emissions.

To the extent climate change is a significant issue, and you want to reduce carbon emission, then the question is what is the most efficient, what is the cheapest way of reducing those emissions? And I would suggest to you that subsidizing renewables is not the way. It is by far a very expensive way of reducing climate emissions, and there are much cheaper ways to do so.

Mr. HALL. And should Congress, then, permit recipients of subsidies, like the PTC, to bid negative prices in power markets?

Mr. LESSER. No, sir. In my view, all subsidies should be removed, not only subsidies for renewable resources, but also subsidies for conventional resources. You should have a level playing field in which all resources can compete. AWEA is now advocating master limited partnerships for wind developers. So not only will they get the PTC and a tax credit worth $35 per megawatt hour on a pretax basis, but you would have a corporate structure that doesn’t pay income taxes. That is a really good deal. You get a tax credit, and you don’t have to pay income taxes. I would like to have that for my business.

Mr. GRIFFITH. Dr. Lesser, am I to understand that your concerns are that in other places in the world where they have relied on intermittent sources, and we heard that Germany was doing a good job of moving in that direction, but isn’t it, in fact, the case that Germany is having some significant problems with their intermittent sources, and that it is actually affecting industry there because they can’t count on the reliability? And I am looking at an article from the Institute for Energy Research of January this year where they say, to illustrate the problem that renewable energy instability can cause, here is an example: electric grid weakened for just a millisecond at 3 a.m. The machines at Hydro Aluminum in Hamburg ground to a halt. Production stopped, and the aluminum belts snagged, hitting machines and destroying a piece of the mill with damages amounting to $12,300 to equipment. The voltage weakened two more times in the next 3 weeks, causing the company to purchase its own emergency system using batteries costing $185,000. Are those the kind of stories that cause you concern? Do you have similar stories that you have heard?

Mr. LESSER. Those are certainly part of the issues that are of concern, especially in Europe where the cost of electricity is extremely high, which reduces economic growth. That is why they are cutting back on all their subsidies. So my concern is here we are going down that same path, that we are making it much more difficult to maintain reliability. I know that ERCOT, the grid operator in Texas, is quite concerned about potential rolling blackouts this summer because of very high demand. They have so much wind. Wind tends not to blow when the power is most needed.

 

Mr. WEISS. The Congressional Research Service was looking at this for the utility industry, and they found that the American Society of Civil Engineers estimates we need to spend over $600 billion between now and 2020 to make our utility system more resistant to disruption from extreme weather. It is important when looking at the costs of natural gas and coal- generated electricity that those fuels include the external economic costs of their use, which includes climate change and extreme weather linked to climate change. Otherwise society is in effect subsidizing the use of coal and natural gas by paying these costs for damages from extreme weather and then the taxpayers paying $400 a household for disaster relief and recovery.

Mr. BARTON. So, Dr. Lesser, the issue is the production tax credit for wind, which I supported when it was initially proposed, because wind power was a startup, struggling sector of the energy economy, and I felt it was fair to help give it some production tax credits to get it off the ground. I think it is a more difficult proposition now, because wind power is firmly established and is a significant part of the generation system in States like Texas. So my question to you, Doctor, do you think the production tax credit impacts the way market prices are in ERCOT in Texas, and do you think that it should be allowed to use production tax credit to bid negative into the grid, which has happened, although it is disputable how often it has happened?

Mr. LESSER. Thank you, Mr. Barton. No, I do not think that wind operators, anyone receiving the PTC, should be eligible to bid negatively. There is no reason for that. Studies by the Northridge Group show that negative prices are far more prevalent than have been indicated. Those negative prices are affecting the viability of conventional generators, which has an effect on reliability. As far as the PTC going on, you now have these direct subsidies and mandates for 35 years since PURPA was passed. One of the arguments you will often hear is that the wind industry requires additional subsidies to be cost competitive, yet earlier on we hear wind is competitive, that it is cheaper. The problem with that, well, if it is cheaper, why do you continue to need subsidies?

The other issue I would raise is that if—the problem is what you are doing is you are distorting the market so much by having a subsidy that is, in fact, greater than the average market price in many areas—for example, the price in PJM that serves D.C. as well as much of the Upper Midwest and Atlantic States was less than the $35 value of the PTC last year. When you have a subsidy that is larger than the average market price, that introduces huge economic distortions. In the long run, that drives out investment of other resources. That means that consumers will end up paying higher prices. They will not—again, it is simply an economic fallacy to say that you can subsidize your way to greater economic growth, lower prices. It just cannot happen.

Today’s discussion builds on earlier hearings that address the challenges posed by changes in the Nation’s electricity generation portfolio. The proportion of electricity we get from coal, natural gas, nuclear, hydroelectric and non-hydro renewables has remained relatively constant over the last several decades. However, a shift is occurring, and what is alarming is how fast the mix has changed during the past few years. And it is this rapid transition that presents a number of pressing concerns that must be addressed in order to ensure a reliable and affordable electricity supply.

The increased use of natural gas to provide electricity cannot go smoothly unless we have the pipeline capacity to carry it from where it is produced to the many new natural gas- fired power plants that are being built. We will need new natural gas pipelines as well as storage facilities to be constructed. However, we don’t have a lot of time to build them, given the reliability challenges we face today, and we have already witnessed this scenario in areas like New England.

In addition, the federal-state policies that have given a boost to intermittent power sources could easily backfire if we don’t address the difficulties of integrating these intermittent sources into the electric grid and the additional cost that that requires. Homeowners and businesses need electricity, whether or not the sun is shining or the wind is blowing, and the supply at any moment must meet the demand. This is nearly impossible to do with intermittent renewables that are not readily and reliably available.

 

FRED UPTON, (MICHIGAN). We must also be mindful of the fact that incorporating an increased amount of renewables into the electric system presents operational challenges that in fact may impair with reliability. These resources are intermittent by their nature. The wind doesn’t always blow, and the sun doesn’t always shine. Clearly, there is a role that these resources can play and should play, but to suggest that these sources alone can meet the power demands of the manufacturing technology and consumer sectors of the U.S. economy is a stretch of the imagination. Absent the continued use of our reliable and consistent base load power workhorses, like coal, nuclear, natural gas, the U.S. will not be able to compete globally.

America’s newfound abundance of natural gas is a blessing, as are technological advances that make renewables more cost competitive and reliable. Both of these resources should and will play an important role in contributing to our energy needs, but we have got to take steps to properly and cost effectively integrate those resources into the energy and electric portfolio.

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Alternative fuels to replace transportation oil. U.S. House hearing 2012

House 112–159. July 10, 2012. The American energy initiative part 23: A focus on Alternative Fuels and vehicles. House of Representatives.

[ Excerpts from this 210 page transcript follow ]

MIKE BREEN, Vice President of the Truman National Security Project.   I am proud to be one of the leaders of Operation Free, a fiercely nonpartisan coalition of over 1,000 patriotic veterans across the country, who stand together in the common belief that our dependence on oil as a single source of fuel poses a clear national security threat to the United States.

To be clear, oil is an immensely important substance to our economy and will remain so for the foreseeable future. Its value goes far beyond its utility as a liquid fuel. Petroleum is a key input in advanced manufacturing, pharmaceuticals, agricultural products, and a host of other applications. Unfortunately, however, a near total dependence on oil as a fuel has eclipsed petroleum’s other contributions.

Our dependence on oil as a single source of transportation fuel poses a clear national security threat to the nation. Our modern military cannot operate without access to vast quantities of oil. This lack of alternatives means that oil has ceased to be a mere commodity. Oil is a vital strategic commodity, a substance without which our national security and prosperity cannot be sustained.

Until and unless we develop alternatives, the United States has no choice but to do whatever it takes in order to obtain a sufficient supply of oil.

We share that sad and dangerous predicament with virtually every other nation on earth.

Oil is a fungible, globally traded commodity with prices set on a world market. In other words, global supply and global demand set the market and drive the price, not American supply and American demand alone. This has crucial implications for policy. Since any potential increase in U.S. supply must be considered in light of global demand. Some claim that recent technological advancements will solve our oil-related national security problems, eliminating the need to develop alternatives, but this is a fallacy for at least three reasons. First, it is highly unlikely that we can drill enough here in the United States to meet our needs, at least for any appreciable length of time. Second, American families will remain vulnerable to swings in gasoline prices. Third, global demand for oil is rising at a breathtaking pace, with no sign of slowing. According to the EIA, America’s oil consumption is expected to grow by 11 percent over the next 2 decades. Meanwhile, China’s oil consumption is expected to grow by 80 percent, India’s by 96 percent.

This is a market with clear winners and losers. The winners, by and large, are non-free market countries, with nationalized oil companies, many of whom are openly opposed to the United States. According to the CIA, over 50 percent of Iran’s entire budget comes from the oil sector. As the price of oil climbs, Iran’s nuclear program and support for global terrorist organizations are among the biggest winners. Meanwhile, the losers are American service members facing oil fueled uncertainties.

Small wonder that Secretary of the Navy Ray Mabus recently called the Navy’s reliance on oil a ‘‘strategic vulnerability.’’

Our near-total dependence on oil as a fuel has eclipsed petroleum’s other contributions, threatening our prosperity and security.

Recent technological advancements such as horizontal drilling and advanced hydraulic fracturing promise to increase domestic production, allowing us to reach supplies of oil that were until recently prohibitively remote or impossible to obtain. These advances have led some to claim that the United States is suddenly capable of producing enough oil domestically to meet our needs, and that this will solve our oil-related economic and national security problems, eliminating the need to develop alternatives.

This is a fallacy, for at least three reasons. First, it is highly unlikely that we can drill enough here in the United States to meet our needs, especially for any appreciable length of time. The US consumes over 20% of the world’s oil, but has about 3% of the world’s reserves. The American economy consumes 18.8 million barrels of petroleum per day, while producing about 5.6 million barrels of crude per day. Simply put, we cannot drill our way out this problem.

Truman National Security Project. This is a market with clear winners and losers. The winners, by and large, are non-free market countries with nationalized oil companies, many of whom are openly opposed to the United States. For every $5 rise in the price of a barrel of crude oil, Putin’s Russia receives more than $18 billion annually, Chavez’s Venezuela an additional $4.9 billion annually, and Ahmadinejad’s Iran an additional $7.9 billion annually: Indeed, according to the CIA, over 50% of the Iran’s entire budget comes from the oil sector. As the price of oil climbs, Iran’s nuclear program and support for global terrorist organizations are among the biggest winners. Of course, even as the military expends tremendous resources defending oil supplies, our forces rely on oil to operate. Even as the dynamics of the global oil market drain American coffers and empower the enemies of democracy and the free market, they also serve to undermine our military’s ability to confront those same enemies. Virtually every major weapons system in the US military arsenal relies on oil to operate, from fighter aircraft to ground combat vehicles to the Navy’s surface fleet. Without it, even our most advanced fifth-generation fighter aircraft and fearsome main battle tanks are rendered useless. The losers in this game are equally clear. They are the Syrian resistance movement, being gunned down as we speak with bullets supplied by Putin’s oil-rich Russia. They are the American Soldiers and Marines who have spent the last decade confronting terrorists in Iraq and Afghanistan armed with Iranian weapons, purchased with oil money. They are everyday Americans, who struggle to pay at the pump even as our nation sends about $1 billion dollars a day overseas for oil. Small wonder, then, that oil is the single largest contributor to our foreign debt, outpacing even our trade deficit with China. In every case just mentioned, American national security is significantly threatened.

It should be no surprise that the US military spends tremendous time and resources safeguarding global oil supplies. Given the tremendous vulnerabilities in the global oil supply chain, this is no easy task. So great is the effort expended by our military on securing the supply of Middle East oil, a RAND study estimated that removing the mission to defend oil supplies and sea routes from the Persian Gulf to the US would save between 12 and 15 percent of the entire defense budget – over $90 billion dollars annually.

Recently, Secretary of the Navy Ray Mabus called the Navy’s reliance on oil a “strategic vulnerability.” And, in testimony to the Senate Armed Services Committee, he stated, “We all know the reality of a volatile global oil market. Every time the cost of a barrel of oil goes up a dollar, it costs the Department of the Navy $31 million in extra fuel costs. These price bites have to be paid for out of our operational funds. That means that our sailors and Marines are forced to steam less, fly less, and train less.” A $10 dollar increase in the price of a barrel of oil costs the Department of Defense an estimated $1.3 billion-almost equal to the entire procurement budget for the Marine Corps.   In fiscal year 2011 alone, the Department of Defense was left with a $3 billion budget shortfall because of rising fuel prices. Fortunately, our military leadership has not been idle in the face of this challenge. The U.S. Navy is committed to reducing petroleum use by 50% by 2015, with the goal of40% of total energy consumption from alternative sources by 2020. In 2010, the Navy conducted the first flight test of the “Green Hornet” an F/A-18 strike fighter powered by a 50% biofuel blend derived from the Camelina plant. This week, the Navy will evaluate a similar 50% blend under combat conditions during large-scale exercises in the Pacific. Advanced biofuels are performing well in the field, and costs are coming down. In fact, the Deputy Chief of Naval Operations predicts that advanced biofuels will be cost competitive with conventional fuels no later than 2020.

Today, oil is a strategic commodity – its supply dictates the march of armies and the fate of nations.

We can and must follow the military’s example. The credible debate on oil dependence and national security is over – there is simply no question at this point that single-source dependence threatens our future security and prosperity. It is time for Congress to act, and to lead.

References

  • S. Energy Information Agency. “United States Analysis Brief.” (July, 2010). http://205.254.135.7/countries/country-data.cfm?fips=US&trk=1#pet
  • Report from Brookings. Sandalow, David. “Ending Oil Dependence: Protecting Notional Security, the Environment and the Economy.” (February, 2007
  • Energy Information Administration, Office of Energy Markets and End Use, “World Petroleum Consumption, Annual Estimates, 1980-2008”
  • Powers, Jonathan. “Oil Addiction: Fueling Our Enemies.” Truman National Security Project, February 17, 2010.
  • CIA World Factbook. “Iran.” CIA, February 21″, 2012.
  • RAND Corporation. “Imported Oil and U.S. National Security.” P. 74 (2009)
  • “Mabus Defends Navy Alternative Energy Plan.” Sea power Magazine.
  • Remarks by the Honorable Secretary Ray Mabus, Senate Armed Services Committee, March 15″‘ 2012 CNA Report on “Powering America’s Defense: Energy and the Risks to National Security” (May 2009)
  • Q&A with Rear Adm. Philip Hart Cullom” CHIPS Magazine.

Mr. Shane Karr, Vice President of Federal Government Affairs, the Alliance of Automobile Manufacturers. We are a trade association of 12 light duty vehicle manufacturers, OEMs, representing roughly 3/4 of the market, the new car market by volume every year.   The Alliance is a trade association of twelve car and light truck manufacturers including BMW Group, Chrysler Group LLC, Ford Motor Company, General Motors Company, Jaguar Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche Cars, Toyota, Volkswagen Group and Volvo Cars. Together, Alliance members account for roughly 3 out of every 4 new vehicles sold in the U.S. each year.

Auto makers have invested $200 billion over the last decade in R&D on fuel efficiency and other features. We are perennially back and forth with pharmaceuticals for the largest R&D investors on an annual basis.

Today, consumers have more than 270 models that get over 30 miles per gallon, and we are working on a variety of additional technologies that will improve fuel economy and reduce gasoline consumption. But the fact is that none of us have a crystal ball. And ultimately, consumers over a long period of time with their vehicle purchase choices are going to decide which technologies are the right ones for them. Given that fact, while we agree that alternative fuels are an important component of an energy security and independence strategy, we strongly believe that legislation mandating a particular vehicle technology or fuel or set of fuels would be a mistake. Vehicle production mandates—there are two problems with vehicle production mandates. They divert resources that could otherwise be used on other fuel-saving technologies, and they reduce the incentive for manufacturers to innovate.

I do want to say that we agree that E85 FFVs are an important and worthwhile technology. As you know, my guys make them. We sell a little over a million a year. There are approaching 12 million on the roads today. They are clearly a piece of the puzzle, but their effectiveness in actually displacing gasoline consumption, which I understand is the goal of the Open Fuel Standards Act, has been relatively small thus far, and it—frankly, it is a function of fuel price, availability, and consumers’ willingness to use the fuel.

We hear all kinds of different numbers about the cost to manufacture FFVs, but—and everyone talks about a per car cost. I would just remind folks that we are selling about hopefully 14 million vehicles in the U.S. this year, so even $100 a car quickly gets you over $1 billion in costs to consumers for this technology.

The other thing that is particularly relevant to this committee is to know that emission standards in approximately 40% of the United States, California and the States that follow California, are about to be increased, and that increase in emissions standards is somewhat problematic with FFV technology and is likely to make FFV technology more expensive. The other important point to note is that the Open Fuel Standard requires vehicles to run on E85, which is ethanol, and M85, which is methanol. While we certainly have built vehicles that can run on methanol in the past and we could do it again, the fact is there are no production facilities in the U.S. making methanol in commercial quantities right now. There are a number of other significant issues that would have to be further studied and addressed if we were going to go in that direction.

What we are open to are policies that reflect a comprehensive commitment to make new fuel successful in the marketplace, and those are policies that address production and distribution equally with vehicles and consumer acceptance. We are looking at the timing and availability of new fuels coinciding with the availability of vehicles that can run on them. This really is a far preferable approach to introducing fuels and then trying to retroactively fit them in the marketplace.

Ultimately, consumers will determine which of these investments were wise. Given the absence of a crystal ball, and the reality that consumers will manifest their choices over a long window of time, we believe it is imperative that government not get in the business of picking technology winners and losers. Government should set performance-based standards and let auto engineers decide how best to meet them. Consumers should choose winners through their collective purchasing patterns. While we agree that alternative fuels are an important component of an energy security and independence strategy, we strongly believe that legislation mandating a particular vehicle technology or fuel or set of fuels would be a mistake. Without meaningful alternative fuel use, the energy security implications of any particular alternative fuel technology are marginal at best, and possibly less impactful than other technology applications aimed at reducing oil consumption.

Vehicle production mandates divert significant resources that could be applied to other fuel saving technologies and reduce the incentive for manufacturers to innovate. The U.S. is on pace to consume around 132 billion gallons of gasoline this year, which is down because of the relatively higher price of gasoline, the vastly improved fuel efficiency of new vehicles, and the slowing pace of broader economic recovery. As it happens, the renewable fuel standard (RFS) requires blenders to purchase 13.2 billion gallons of com ethanol this year, almost exactly 10 percent of the total gasoline pool, which will be taken up almost exclusively by E10, leaving virtually no room for higher level blends.

The U.S. is already the world’s largest producer by far of com ethanol. No one – not even the ethanol industry — is suggesting that the US should divert more of its arable land to produce additional feedstock for com ethanol. Continued production efficiencies will result in higher yields, but those will be incremental, not exponential. We won’t have the option of importing it in significant quantities (which arguably defeats the energy security goal anyway), given that the second largest ethanol producer in the world is Brazil, which itself has a shortage that will continue as long as sugar prices remain high. And we still wouldn’t have pipelines to ship ethanol around the country efficiently and cheaply or the compatible pumps at fueling stations. So, a number of very significant factors in addition to vehicles would need to change to make the theoretical notion that consumers could buy more ethanol- if they wanted to – a reality.

The Open Fuels Standard Act H.R. 1687 calls for 95 percent of vehicles to be alternative fuel vehicles beginning in model year 2017. Although the bill defines alternative fuel broadly, it is generally understood that the least expensive compliance path would be to build vehicles that meet the current requirements for flexible fuel vehicles (FFVs).

This is why the Open Fuels Standard Act (H.R. 1687) is supported primarily by the ethanol producers. Let me start by saying automakers agree with the sponsors of H.R. 1687 that FFVs, currently defined as vehicles capable of running on any blend of gasoline and ethanol up to 85 percent (E85), are an important and worthwhile technology. In fact, there are already close to 12 million E85 FFVs on U.S. roads, and we will probably sell another million this year. However, only about 2% of gas stations have an E85 pump, and most are concentrated in the Midwest, where most com ethanol is produced. This makes sense, because keeping production close to point-of-sale is the most affordable approach. But even in states where E85 pumps are concentrated, actual sale of E85 has been low and stagnant. For example, in 2009 Minnesota had 351 stations with an E85 pump (the most of any state) but the average FFV in the state used 10.3 gallons ofE85 for the whole year.

It is worth noting that achieving compliance with the vehicle production mandates in H.R. 1687 by producing E85 FFVs would cost consumers well more than $1 billion per year by the most conservative estimates. And these conservative estimates are severely understated for the vehicle mandates of the bill for two reasons: (I) H.R. 1687 requires a new kind of tri-fuel FFV that can run on gasoline, ethanol, methanol, and any combination of the 3 fuels, and which does not exist today; and (2) it will be more expensive to produce tri-fuel FFVs that can comply with H.R. 1687, especially with the forthcoming California Low Emission Vehicles (LEV III) and federal Tier 3 emissions standards along with very aggressive fuel economy/GHG emission requirements through 2025.

The Methanol Experience

In the late-I 980s to mid-90s, automakers produced a limited number of light-duty vehicle models that could run on an 85% blend of methanol in gasoline (M85). This was undertaken in response to a series of California initiatives to increase the availability of methanol fuel and M85 FFVs across the state. It should be noted that vehicle changes to accommodate methanol (then and now) are distinct from ethanol FFVs. Larger valves, greater hardening efforts associated with parts, and software changes to allow the vehicles to run effectively are some of the unique modifications necessary to allow vehicles to run on alternative fuels – and they are different for each alternative fuel involved.

The California methanol effort was abandoned for a variety of reasons. The largest was that methanol was finding its way into water supplies and its toxicity was considered a significant health concern.

But from a vehicle perspective, there were also concerns.

  • Methanol contains 50 percent less energy content than gasoline. Drivers had to refuel twice as often and consumer acceptance was low.
  • The fueling infrastructure was very expensive, and retailers were unwilling to mortgage their futures on an unproven fuel.
  • Today, there are no production facilities in the U.S. making methanol for use as transportation fuel in commercial quantities.
  • The U.S. currently imports over 80% of its methanol needs and the additional imports required to fuel an M85 compatible fleet would be counter to efforts to bolster U.S. energy independence and security.
  • There are no pipelines to ship it around the country and methanol cannot be shipped using conventional oil and gas pipelines due to its highly corrosive nature.
  • There are no pumps available at fueling stations (ethanol pumps would not be certified for methanol, which is more corrosive and much more problematic if it leaks and contaminates our ground water).

Emissions Standards and Alternative Fuels

Because ethanol is a renewable fuel and can have fewer carbon emissions, it does not perform as well as gasoline when a cold engine is started, and methanol is even worse. While California has added flexibilities to its LEV III requirements that may enable automakers to engineer E85 FFVs to comply with these standards over time, they will be more expensive than FFVs today. Even if methanol is eliminated from the equation, the cost of making E85 FFVs will increase. As emission standards continue to be tightened – which is happening as both California and EPA work to create new LEV III and Tier 3 standards respectively – designing vehicles to meet those requirements on two fuels will be very challenging and costly – adding a third fuel could dramatically increase costs. It is worth noting that engineering a vehicle to run effectively and efficiently on two fuels means that it cannot be optimally tuned to run on either, so it is a compromise design to start with. This situation is compounded substantially when you add a third fuel. Furthermore, today’s E85 FFVs do not comply with the most stringent state emissions standards and testing requirements. California and states that have adopted California regulations, which effectively governs 40% of the U.S. vehicle market, will require virtually all vehicles to certify to the most stringent standards in the coming years under its LEV III program.

It should also be noted that if manufacturers were required to design FFVs to be capable of meeting these emission standards on methanol, the challenges become far greater on all fronts – exhaust emissions, evaporative emissions, durability and test burden. Because burning methanol produces much higher levels of formaldehyde, an air toxic, a whole new development effort focused on meeting stringent formaldehyde standards would be needed. The high volatility and permeation rates of methanol blends bring into question the feasibility of meeting evaporative emission standards (we last produced methanol vehicles before the introduction of real world test procedures in the 1990s). The corrosive nature of methanol leads to durability concerns for fuel system components. Additionally, thousands of additional tests per year would be required, which include more expensive and time-consuming measurement techniques for methanol and formaldehyde, impacting both the need for additional manpower and lab equipment. Simply put, the future emission standards were not developed taking into account the challenges of methanol.

The availability of new fuels should coincide with the availability of the vehicles that can run on them, so there is a market for both. Such a prospective approach is a far preferable alternative to retroactively introducing fuels into a market that has not been designed, certified or warranted to run on them.

Past Experience with M85 Flex-Fuel Vehicles (FFVs)

In the late 1980s to mid-90s, automakers produced a limited amount light-duty vehicle models that could run on an 85% blend of methanol in gasoline (M85). This experiment was in response to a series of California initiatives to increase the availability of methanol fuel and M85 FFVs across the state. Below is a generic list of components and modifications automakers may have utilized in the late 80s and 90s to transform a vehicle into a M85 compatible FFV.

It is important to note that these vehicles were produced prior to the implementation of the federal Tier 2 vehicle emissions program or enhanced evaporative emissions standards. The Tier 2 program resulted in vehicles emitting 99% fewer smog-forming emissions compared to vehicles in the 1970s. EPA and California are currently in the process of implementing new Tier 3 and LEV III vehicle emissions standards respectively that will require automakers to significantly lower the remaining 1% of smog-forming emissions. Because of the unique nature of methanol, the M85 FFVs produced in conjunction with this CA program would not have been able to meet the Tier 2 emissions targets, much less the pending aggressive Tier 3 and CA LEV III requirements.

Generic List of Vehicle Components and Modifications Utilized in pre-Tier 2 M85 FFVs:

  • Fuel Pump Speed Controller
  • Canister Purge Valve
  • Engine Modifications:
  1. Piston Ring chrome plated face to resist corrosion and wear.
  2. Exhaust Valve & Seat material upgrade to resist corrosion and pitting.
  3. Engine Oil- formulated to reduce the tendency of methanol to remove anti-wear additives from the oil. Also contains additives to reduce corrosion and wear due to higher acidity of blow-by gases.
  4. Throttle Body – changes made to allow canister purge at idle.
  • Wiring Assemblies – modifications required for component additions.
  • Electronic Control Module (ECM) – changes required for specific methanol inputs and outputs:
  1. Fuel Composition
  2. Fuel Temperature
  3. Fuel Tank Level
  4. Prom and Software Changes
  • Fuel Injector Driver Module
  • Ignition Coil- high secondary current ignition coil for improved cold start.
  • Fuel Rail Assembly – material changes for methanol compatibility to injectors, pressure regulator, and rail coating.
  • Pipe Assemblies – material changes for methanol compatibility.
  • Variable Fuel Sensor Assembly – monitors fuel composition (% of methanol) in fuel line.
  • Catalytic Converter – revised catalyst loading for emissions control.
  • Low Fuel Light – added because of decreased driving range with methanol.
  • Fuel Sender Control Module – interrupts current through fuel level sender to reduce galvanic attack in methanol environment.
  • Fuel Tank – stainless steel required for corrosive methanol environment.
  • Solder -silver solder required for methanol compatibility.
  • Flame Arrestors – stainless steel required to prevent fame propagation from fill door to fill tank.
  • Fuel Hose and Vent Hose – revised for decreased fuel.
  • Fuel Fill Pipe and Vent Extensions stainless steel required for corrosive methanol environment.
  • Fuel Fill Pipe – modified vent pipe to provide canister clearance.
  • Canister – increased capacity evaporative canister required because of higher vapor pressures of low methanol blends.
  • Canister Bracket – unique bracket to reposition large canister.
  • Fuel Cap – gasket materials modified for methanol compatibility
  • Fuel Sender and Pump Assembly:
  1. Higher flow pump to account for reduce energy density
  2. Extensive material changes for methanol compatibility

JOHN SULLIVAN, OKLAHOMA. This morning we will be discussing alternative fuels and vehicles, both the challenges and the opportunities. Gasoline and diesel fuel currently dominate the transportation sector, and that is not likely to change any time soon. For that reason, we need to take steps to ensure plentiful and affordable supplies of petroleum and the fuels that are made from it. That means expanding domestic oil production, approving the Keystone XL pipeline to allow more Canadian oil to come into the country, and reviewing the red tape that raises the cost of refining crude into gasoline and diesel fuel. That is why I strongly supported measures like the Domestic Energy and Jobs Act, and why I will continue to fight for a commonsense, pro-consumer, pro-jobs, and pro-energy policy. But in addition, we need to look at options other than petroleum derived fuels, and indeed we are doing so. We are well into the implementation of the Renewable Fuel Standard created in the 2005 energy bill and expanded in the 2007 bill. The RFS has achieved some successes such as increased ethanol production. However, some also see shortcomings with the RFS that need to be addressed. Even beyond ethanol and other biofuels, there are many other alternative fuels and vehicles, including natural gas, electricity, coal- to-liquids, methanol, and flex-fuel vehicles. Each offers its own unique mix of advantages as well as disadvantages, and all offer the benefits of diversification. I look forward to learning more about these options, and exploring the question of what role, if any, the Federal Government should play in shaping the fuels and vehicles markets of the future.

JOHN SHIMKUS, ILLINOIS. Ethanol has been a great success at this time. Ethanol produced 14 billion gallons in 2011. U.S. oil and imports dropped to just 45% of demand that same year. Ethanol represents 10 percent of our national gasoline pool. Last year, ethanol reduced wholesale gas prices by an average of $1.09 per gallon. And as I try to remind people, that is without a blender’s credit, which has gone away. People still think that there is a tax credit with ethanol blending, and that is not the case. So the question is, why not add a variety of alternative transportation fuels to the mix. H.R. 1687 would have an increasing percent of new automobiles take on a variety of fuels like natural gas, electricity, biodiesel, hydrogen, flex fuel vehicles that can run on blends of methanol and ethanol, or other emerging technologies. This would create a marketplace where fuels can compete with each other for the consumer’s dollars.

BOBBY L. RUSH, ILLINOIS. It is extremely important that both sides work together to identify short and long-term strategies and objectives for developing alternative fuels for vehicles. So 5 or 10 years from now, this country will not be subject to fluctuating global gas prices due to unrest in the Middle East or anyplace else in the world. For too long now, we are seeing wildly fluctuating gas prices due to a lack of a comprehensive policy to move us away from imported oil and petroleum. Every year or two, we are back in the same exact position where we were a few months ago, discussing extremely high gas prices at the pump. We are no closer to permanently solving this issue which has such a devastating effect on the lower and middle income family’s budget who must, too often, choose between putting food on the table or filling up their cars in order to go to work.

JOE BARTON, TEXAS. I know there is quite a bit of controversy over biofuel program in the Navy. I think it is appropriate for the Navy to be doing some pilot programs on biofuels, but at the expected cost of over $27 a gallon, I certainly think that we shouldn’t forget, again, LNG and natural gas and even coal to liquids, for that matter, as alternative energy sources for our Navy. Biofuels should and can play an important role in a balanced energy portfolio, there is no question about that, but we shouldn’t forget the fuels that have made it possible for us to have the greatest economy in the world, and that is our basic hydrocarbon fuels that we are so adept at right now in manufacturing and discovering and producing and transporting.

Tom Tanton Executive Director, American Tradition Institute’ President T2 and Associates

Various vehicle types, such as electric vehicles, pose their own strategic concerns, such as Rare Earth metals needed for batteries and catalysts.

Consumers will face additional, unquantified, costs from purchase of qualified vehicles in addition to higher first costs, further compounded by conflicting policies. With respect to electric vehicles, for example, EPA’s promulgation of revisions to Maximum Achievable Control Technologies (MACT) and various states’ renewable portfolio standards increase the cost of electricity (necessary for recharging EV) by up to 40%, making the consumer’s going forward cost to own an EV even more prohibitive and less competitive. Extension of the Production Tax Credit (for electricity from renewable sources) will further distance consumers from an electric vehicle market. Electric vehicles and hybrids are also more expensive to insure.

California consumes 44 to 45 million gallons of gasoline and 10 million gallons of diesel fuel per day. The demand for transportation fuels increased nearly 50% in last 20 years. The number of refineries producing gasoline in California dropped from 32 in mid-1980s to 14 today. California imports 3.5+ million gallons of gasoline and components per day. Transportation fuel infrastructure is at capacity and not keeping up with rapidly growing population and demand. Future energy needs will be addressed through growing levels of imports. Local and regional congestion and air quality programs will influence future energy supplies. Permitting issues impact future energy supplies, including renewable fuels.

Total gasoline, diesel, and jet fuel demand is forecast to grow by 13.5% to 42.8% by 2030, depending on economic vitality. By 2025, imports of crude oil into CA rise 37% to 65.2% (151 million to 266 million barrels per year) while transportation fuel imports increase by 199.7 million barrels per year by 2025 in high fuel demand case. Pipeline exports from CA to NV grow by 28.7 to 36.3 million barrels per year by 2025, an increase of 50.4% to 63.7%. Exports from CA to AZ increase by 29 million barrels per year (59 percent) by 2025.

A Brief History of California Efforts to Encourage Alternatives

Since 1976, California has had numerous programs-incentives and mandates-to broaden the use of Methanol or Ethanol (twice), including as an oxygenate replacement for MTBE, Natural gas Electricity ‘flexible fuel’ vehicles, and Transportation Demand Reduction As of 2009, California had just over 136,000 alternative fuel vehicles, out of 826,000 nationwide.

136,000 represents less than one-half of one percent of the state’s vehicles, even after 30 years of incentives, mandates and other programs. Programs were initially predicated on petroleum security, but more recently have focused on either air quality and/or greenhouse gas emissions. The mechanisms have changed little, other than becoming more complex.

Methanol: California led the search for petroleum fuel alternatives with initial interest focused on methanol. Ford Motor Company and other automakers responded to California’s request for vehicles that run on methanol. In 1981, Ford delivered 40 dedicated neat methanol fuel (M100) Escorts to Los Angeles County, but only four refueling stations were installed. The biggest technical challenge in the development of alcohol vehicle technology was getting all of the fuel system materials compatible with the higher chemical reactivity of the methanol, and avoiding corrosion stemming from water absorption. Methanol was even more of a challenge than ethanol but some of the early experience gained with neat ethanol vehicle production in Brazil was transferred. The success of this small experimental fleet of M100s led California to request more of these vehicles, mainly for government fleets. However, longer-developing problems combined with high cost ultimately killed the program. At the time, almost all methanol was produced using natural gas as a feedstock, with an approximate 25% loss in energy content in the conversion from gas to methanol. Natural gas prices had increased and supplies decreased, leading to noncompetitive prices and short supplies. Ligno-cellulose based methanol (i.e. “wood alcohol”) was only available in limited quantities as is true today.

Ethanol: The earliest ethanol program in California followed the initial methanol program, and began in the mid-1980s, but suffered from anemic consumer demand and little availability of ethanol fuel. The demand and supply for ethanol fuel (produced from corn) was stimulated by the discovery in the late 90s that methyl tertiary butyl ether (MTBE), a mandated oxygenate additive in gasoline, was contaminating groundwater. Due to the risks of widespread and costly litigation, and because MTBE use in gasoline was banned in almost 20 states by 2006, the substitution of MTBE opened a larger market for ethanol fuel. This demand shift for ethanol as an oxygenate additive took place at a time when oil prices were rising. By 2006, about 50% of the gasoline used contained ethanol at different proportions (generally about 5-10%), and ethanol production grew so fast that the US became the world’s top ethanol producer, overtaking Brazil in 2005. This shift also contributed to a sharp increase in the price of corn-dependent foods including beef and dairy. In 2008, Governor Schwarzenegger proposed and the California Air Resources Board is now implementing, a Low Carbon Fuel Standard (LCFS) to reduce the carbon content of transportation fuels by 10%. Though purportedly a market-based mechanism, the LCFS is anything but, because consumers are not willing buyers of the mandated product. It is an alternative fuels plan. Under the plan, transportation fuel sold in California would be subject to a ceiling on the amount of carbon it can emit per unit of energy. The limit takes into account the carbon produced throughout the fuel’s entire life cycle, from production through consumption, albeit imperfectly.

One anticipated beneficiary of the new standard was ethanol, which has several major downsides:

  • Fuel will be less efficient. Ethanol contains about 34% less energy per gallon than gasoline, which greatly reduces the number of miles traveled per gallon.
  • Fuel will be more expensive. The reduced efficiency mentioned above increases the effective price per gallon.
  • In addition, ethanol must be transported by truck or rail because it is too corrosive for pipelines
  • These increased transportation costs contribute to higher prices at the pump.
  • Food will be more expensive. Skyrocketing com prices, driven by the clamor for ethanol, are squeezing California milk producers because of the increased cost of cattle feed, reported the California Farm Bureau. In addition to increasing the costs of animal feed, the high price of corn has encouraged farmers to switch from other grains, such as wheat, to corn, thus raising the costs of other grains because of reduced supply.
  • Energy savings will be illusory. When transportation, refining, and farming costs are factored into the production of ethanol for fuel, the energy savings is negligible. In fact, ethanol often requires more energy to produce than it yields.

http://www.api.org/~/media/files/oil-and-natural-gas/pipeline/aopl_api_ethanol_transportation.pdf

Water and biofuels fuel quality

Small amounts of water enter pipeline system s from fuels, terminals and tank roofs. This is generally not a problem during pipeline transportation of refined petroleum products, because the water can sepa rate in a tank and can be drained off. Unlike petroleum products, ethanol has an affinity for water, which can be picked up as ethanol flows through the pipeline network. The water-ethanol mixture has the potential to separate from petroleum products wit h which it may be mixed,resulting in degraded fuel quality. This can be managed by taking steps to cover tanks and remove excess water at certain points in the supply and distribution system.

“Trailback” and jet fuel quality

Most pipelines that carry re fined petroleum products carry several different products in separate “batches”. For example, a products pipeline might move regular unleaded gasoline, premium unleaded gasoline, diesel fuel, jet fuel, etc. The addition of biodiesel fatty acid methyl esters (FAME)can cause a “trailback” of small amounts of the biodiesel into jet fuel. This leads to a concern of degraded jet fuel quality , as jet fuel standards currently do not allow for any measurable level of biodiesel. One pipeline company has begun transporting biodiesel in certain pipelines that do not carry jet fuel. However, most products pipelines carry jet fuel and are unlikely to cease doing so. More work must be done to eliminate the concerns of “trailback” by jet fuel users. Jet engine manufacturers, federal regulators and fuel producers are working to determine if it is safe to have biodiesel in jet fuel, and at what levels.

Other fuel quality issues

Some biofuels can strip lacquers and deposits from internal pipeline surfaces and carry them as impurities. These impurities can clog filters in the supply system, requiring change outs, and in vehicles, impacting vehicle drivability and requiring maintenance. This is a concern when biofuels like ethanol are first introduced into a system, but once impurities have been removed becomes a lesser issue. Stress Corrosion Cracking Another challenge experienced in biofuels transportation by pipeline is Stress Corrosion Cracking (SCC associated with ethanol movement and storage in pipelines and storage tanks. Research, largely funded by pipeline companies, has made great strides in addressing this problem. Industry/government research by Pipeline Research Council International, Inc . (PRCI) 1 has found that ethanol-gasoline blends containing 15 percent or less by volume of ethanol (E-15 and below) can be transported without causing SCC in existing pipelines without any design or operation al modifications. PRCI also found that higher ethanol-containing b lends (E-20 and above and fuel-grade ethanol can be transported without SCC when certain commercial inhibitors are added. The efficacy of commercial inhibitors to mitigate SCC must be assessed prior to their use.

Biofuels and Materials

Biofuels can also impact materials used in gaskets, o-rings, and seals used in fuels transportation and storage systems. Elastomers can experience swelling, shrinking and cracking when exposed to biofuels. Polymers that are often used for coatings may also be degraded by biofuels. Biofuels may also corrode certain non-ferrous metals used in gauges, meters, valves, and pumps. Any part of the supply system that will be converted to biofuels service needs to be assessed for materials compatibility and may need to be refitted with materials that are resistant to the effects of biofuels.

Dedicated biofuels pipelines

Some pipeline companies are proposing to build dedicated biofuels pipelines to connect biofuels-producing areas with large gasoline-consuming markets , with government loan guarantee assistance. Biofuels-producing areas are often far from areas that are major gasoline-consuming areas. Also, biofuels production facilities are relatively small and spread out, requiring a gathering network to aggregate sufficient throughput for a pipeline. In addition to government assistance, pipelines would need robust markets and assurance s that supplies would be available over a long period of time, in order to finance such a project.

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Consumers have recognized ethanol’s limitations. Ethanol has lower energy content than gasoline so the miles traveled per gallon is reduced. This increases the effective price per gallon, and increases the inconvenience of refueling. The more frequent refueling can add over twenty cents per gallon to the effective cost, to account for the additional refueling time. For a vehicle with an 18 gallon tank, that is filled up once every two weeks with gasoline, it would have to be refilled every nine days if using pure ethanol. Ethanol at $2.00 per gallon has the work capability of gasoline costing $3.03 per gallon.

California does not have an adequate fuel supply infrastructure for bio-fuels such as ethanol, methanol or biodiesel and must rely on imports, typically from other countries. While biofuels may provide for some air quality benefit, they do little for energy security if demand expands greatly.

Electric Vehicles: California’s Zero-Emission Vehicle mandate, first enacted in 1990, required that by 1998, 2% of the vehicles sold in the state by large automakers had to be zero-emission (i.e. electric) vehicles. That mandate was set to increase to 5% of vehicle sales by 2001, and 10% by 2003. But it was obvious that the technology to satisfy the ZEV mandate and consumer needs was not forthcoming. In 1996, the mandate was modified to allow automakers to sell more conventional (but “super-low-emitting”) vehicles in order to get credit for meeting their ZEV mandate targets. In 2001, the mandate was further modified, to allow large automakers to satisfy their obligations if they sold just 2% “pure” zero-emission vehicles, 2% “advanced technology partial zero emission

Most recently, the ZEV mandate was further modified, and now mandates that “at least 15.4% of all cars sold by any major automaker doing business in California will have to be either fully electric, a plug-in hybrid or be powered by a hydrogen fuel cell by 2025.” Electric-vehicle technology is still unable to satisfy the demands of consumers. The all-electric Nissan Leaf, with a limited range of about 73 miles per charge sells for about $35,000. Further compounding the initial cost is battery replacement, which can occur after about five years and represent 30 to 35% of the initial cost.

Electric hybrids are also more expensive to insure. Online insurance broker Insure.com shows that it costs $1,308 to insure a Honda Civic but $1,486 to insure a Honda Civic Hybrid. Similarly, it costs $1,270 to insure a Toyota Camry but $1,517 to insure a Toyota Camry Hybrid; $1,619 to insure a Chevrolet Volt but only $1,267 for the same-size gas-powered Chevrolet Cruze; and $1,512 for the Nissan Leaf but only $1,240 for the comparable Nissan Versa 14. Annual Insurance Premiums for Hybrids vs. Gas Powered Cars $1.800 $1.600 $1.400

Californians are likely to purchase fewer new cars and to continue driving their old cars longer, partly due to the continuing economic malaise. A recent CARB staff analysis suggests that the ZEV program will only very modestly reduce emissions (and petroleum use) from the vehicle fleet, not including likely slower fleet turnover. The emissions and petroleum use resulting from longer use of older cars will overwhelm the reductions from new ZEVs.

In California, most natural gas transportation fuel is consumed by transit buses and garbage trucks. Both of these applications are partially driven by fleet rules (such as the CARB Transit Rule and SCAQMD Fleet Rules 1192 and 1193), and they also benefit from financial incentives (such as the 8 Carl Moyer Program, and Energy Policy Act, and Federal Highway Bill provisions). Common heavy-duty natural gas applications include Class 8 tractor-trailer operations such as warehouse-to-retail distribution of grocery and other products.

As recent as a decade ago, nearly all major domestic and foreign OEMs offered dedicated and/or bi-fuel CNG vehicles as part of their product line. All but Honda have dropped their NGVs from the U.S. market. Interestingly, almost all OEMs manufacture NGVs for non-U.S. markets. Consumers are not looking to buy light-duty natural gas vehicles.

Early California programs encouraged school bus operators, for example, to convert fleets to natural gas. School districts were paid subsidies to purchase new buses. However, the buses that were replaced (typically diesel fueled) were not retired, but sold to other school districts unable to participate in buying “new” buses. While these ‘middle age’ buses were more efficient compared to their same-size older buses, many school districts ended up with larger, and more fuel intensive, buses negating any net savings of emissions or petroleum.

Flexible Fuel Vehicles As an answer to the early lack of refueling infrastructure, Ford began development of a flexible-fuel vehicle in 1982, and between 1985 and 1992, 705 experimental FFVs were built and delivered to California and Canada, including the 1.6L Ford Escort, the 3.0L Taurus, and the 5.0L LTD Crown Victoria. These vehicles could operate on either gasoline or methanol with only one fuel system. Legislation was passed to encourage the US auto industry to begin production, which started in 1993 for the M85 FFVs at Ford. In 1996, a new FFV Ford Taurus was developed, with models fully capable of running on either methanol or ethanol blended with gasoline.

Today, the vast majority of alternative fuel vehicles, and a large percentage of all vehicles, are flexible fuel capable. Most consumers continue to preferentially fill with gasoline, even when given free choice.

Myth: We need alternatives to replace petroleum for energy security.

Reality: Energy security is an important goal. Energy security however, does not mean trading one set of risks for another. Heavy emphasis on reducing petroleum usage is as likely as not to create a less secure energy system for three simple reasons:

“Feedstocks for alternative fuels are weather dependent and subject to weather conditions. Much of the corn and other crops grown in the U.S. are grown with natural rainfall, and without irrigation. This subjects the crop supply to annual variability due to natural weather patterns. Further, devastating hurricanes and tornadoes have pummeled crops in several of the past few years. Moving our energy security to a system that includes crop-dependency on weather simply trades one form of insecurity for another. Energy security should come from shifting to a system of manageable risks, not the weather.

“Fuel will be competing with food demands for the major feedstock of alternative fuel production in the near to mid-term. According to the US Department of Agriculture, farmers will need to plant 90 million acres of corn by 2010 in order to keep up with the already rising demand for ethanol fuel while maintaining current demands for livestock and exports. Speaking to the Senate Environment and Public Works Committee, the Agriculture Department’s chief economist, Keith Collins, said the explosive growth in demand for corn for ethanol may have dangerous side effects. He said the thirst for ethanol may lead to high food prices and reduce soybean supplies. He also said land set aside for conservation may have to be utilized for ethanol production, estimating up to 7 million acres of land — most in the Midwestern states — now idled under the Conservation Reserve Program would need to be planted to grow corn and soybeans.

Energy ‘independence’ is not the same as energy security. Consumer activists expect independence to bring down the high price of gas and heating oil. Environmentalists hope it will promote “renewable” sources of energy. And global strategists think it will weaken anti-American oil-producing regimes. But energy independence itself is not a desirable goal. It merely brings to the field of energy the stagnant isolationism of North Korea and the nationalistic mindset that destroyed the recent Doha round of world trade talks. What the U.S. needs is a greater reliance on free markets in energy, at home and abroad.

Moreover, burdening California companies with more taxes will increase California dependence on oil from socialist regimes. National Oil Companies (NOCs) manage over 90% of the world’s oil. And 16 of the 20 biggest oil firms (ranked by reserves) are government owned. According to The Economist, ‘those with misgivings about oil–that its price is too high, that reserves are running out, that it damages the environment, that it is more a curse than an asset for countries that produce it”- must focus on NOCs, and not so-called “Big Oil” companies like Exxon Mobil, Chevron, BP, and Royal Dutch Shell.

Richard A. Bajura Director, National Research Center for Coal and Energy West Virginia University.

I have had the benefit of working with the University of Kentucky on the Consortium for Fossil Fuels Science. We believe that there are more things you can do with coal than just simply generate electricity. We can generate alternative fuels such as jet, diesel, and gasoline that are almost sulfur-free, have very few carcinogenic compounds. They out-perform petroleum, and have fewer particulate emissions. We do this by a process called gasification, where we take coal and turn it into carbon monoxide and hydrogen. These are very simple building blocks on which we can construct anything chemically, aspirin, for example, urea, and chemicals and gasoline. The other aspect is a Fischer-Tropsch process, which converts this fuel—this gas into a liquid fuel. These are known technologies. They are fairly expensive.

The other aspect I would like you to consider is using the CO2 that is captured. In an oil reservoir, we punch a hole in the ground and the oil comes up by the pressure underground. That is called primary. Next, we use water to flood the reservoir and produce additional oil. That is called secondary. We might leave as much as 70 percent of the oil in place. If we do a tertiary process with CO2 injection, we can produce additional oil, perhaps getting as much as 50 percent now of the oil in place.

We need additional research that would improve our ability to capture the carbon, to deploy these enhanced oil recovery technologies better, and to buy down the cost of putting these plants in place. It is very expensive to put a Fischer-Tropsch plant in place to produce liquid fuels.

However, we will need next-generation technologies to continue competing successfully with oil.

Therefore, federal investments are recommended for advanced research in fuels development and deployment, for next-generation EOR technologies, and for buying down the first-of-a-kind costs for pioneer plants.

The gasification process results in a mixture of carbon monoxide and hydrogen gases, which are the simple chemical compounds that serve as building blocks for multiple plastics and polymers used in products ranging from household goods to industrial-grade materials. Gasification and F-T plants must be built at large scale to operate economically. Large scale means high capital costs for such plants. If we don’t reduce risk and uncertainty in costly systems such as CTL – EOR operations, bankers will not provide the financing.

Mr. SHIMKUS. So it is called distillers dry grains after the processing of the kernel, and distillers dry grains is really a major component in feed products for livestock. And I do this for my colleagues and friends who are concerned about the corn—the food fuel debate on livestock. The distillers dry grains is a commodity product sold after the refinery process, is that correct?

Mr. DINNEEN. Yes. In fact, last year, the ethanol industry produced some 36 million metric tons of distillers dry grains that was then fed across the country.

Mr. SHIMKUS. Well, and I would also say that we have—we produce so much distillers dry grains that we are exporting distillers dry grains to other countries throughout the world, China, in particular, in their feedstock, so again, addressing the food fuel debate.

Mr. GERARD. Back to what Mr. McAdams said, these RINs are in buckets. When you look at the bucket on the biodiesel area where we found the fraud, it is 5 to 12% of the market. That is a serious problem, as those who buy the RINs and then EPA turns around and says well gee, you bought a fraudulent RIN, so go buy another one. So we have come back to the EPA and say let us create a process here where we can certify a mechanism to make sure we are not promoting or allowing fraud in the RIN process. It is that simple, but it is a serious issue.

Mr. BREEN. There is a pretty strong emerging consensus among many national security leaders, including most of the most prominent think tanks in the field, that climate change is a dire national security threat. It is what the Pentagon calls an accelerant of instability or a force multiplier of instability. It creates the conditions that lead to insurgency, terrorism, interstate warfare, large mass migrations of people. We are already seeing some of this happening, that according to even the most conservative climate projections, is set to increase, especially in some of the most volatile areas in the world where our military is the most active, including central Asia. It is a huge problem. I am not a climate scientist, but according to all the research I have seen, 95% of climate scientists do believe that climate change is real and as a military officer, if I were informed that 95% of my intelligence told me I was facing a lethal threat, if I didn’t act I would be committing unconscionable military malpractice

Ms. STADLER. Well, we are running out of time, so I don’t think we can sit around and think we have another decade to figure this out. I know this is a debate that has been dragged on for multiple decades. There is strong scientific consensus that we are nearing a tipping point and that we really need to start ratcheting down carbon pollution, and if we don’t, we are going to see more extreme storms and weather events like we have already seen. In terms of how we develop fuels policies, we need to evaluate them based on their ability to drive down carbon pollution. So when we talk about all of the above, we don’t think that works when we are in this time of a tipping point.

Mr. WAXMAN. Well, all of the above is unfortunately the direction we have to take, because no one is going to stop using coal. No one is going to stop using oil. But what we need are alternatives and market incentives to develop the technology that will allow us to use oil and coal and other fossil fuels and take the carbon out of it, because our focus has to be, I think, on this climate change threat. It is not going to happen with the free market responding to it, because there is no competition to try to achieve what is a national—international goal by entrepreneurs, unless they can also make money. So we have got to give them the financial incentives to accomplish that goal.

Mr. GRIFFITH. Dr. Bajura, one of the greatest benefits of coal-derived fuels is the ability to provide our military with a more stable domestic source of energy. I was happy to hear you mention my bill, H.R. 2036, in your testimony, the American Alternative Fuel Act of 2011, which would repeal Section 526 of the 2007 Energy Bill. This section effectively sets us on a course to rely even more on unstable regions where many of our military personnel are now deployed. Do you believe the potential to source military fuel from domestic resources, such as liquid fuel derived from coal, is a national security issue?

Mr. BAJURA. Yes, I think it is, and it makes sense for us to have a diversity of supplies. The Department of Defense wants to ensure that it has the ability to have fuel to fund all of its operations. I think another thing that could be benefitted by having the Department of Defense program put in place is we talked about $4 a gallon petroleum, we talked about $27 a gallon renewable fuels, but at the war theater, a gallon of fuel might cost $300. If we had coal-to-liquids or gasification in Fischer-Tropsch technologies, we might be able to produce that fuel right there at the theater, and that would reduce the cost of transporting it, which is another advantage to the Defense Department.

You want to ensure a security of supply, not only getting it there but the quality of supply. If you bought something elsewhere, would you know that it wasn’t contaminated, for example. So you want to ensure security. So we take our own fuel to the theater. If we made our fuel there, it would be cheaper. Using gasification Fischer-Tropsch, we could produce it with materials that are there in that country.

Mr. GRIFFITH. OK. What role do you believe long-term contracting authority for the Department of Defense could play in the development of a robust alternative fuels industry?

Mr. BAJURA. Long-term contracting is—it was proposed—was designed to provide some guarantees for a company that builds a plant. We are talking big bucks here if you are saying it is $100,000 per daily barrel of output and you need 25,000 barrels a day, you are talking billions of dollars. There is a lot of risk in investing in a technology like that. We might say the elements are known, but putting such a big plant together is very costly. The price of oil is dynamic. I think it is important for us to have the floor and ceiling for prices, and as that legislation was proposed, we were even looking at ways where the Federal Government would not have to pick up the cost if it were a higher price—if the fuel production was cheaper than on the market, it would be beneficial. I think this is important that we ensure that development of the technology, once it is developed and proven, then I think industry will step in and do it.

Mr. GRIFFITH. And so part of what you are saying is that if we use that research capability, then we put it into the field, if somebody is going to invest the billions of dollars in putting something into the field, it might need something longer than a 5-year contract from the military to feel comfortable in putting that money into the investment. Is that a correct statement?

Mr. BAJURA. That is correct. That is why I want to do a long-term contract, because you look at a coal plant and you have got a 20-, 30-year repayment cost for your capital contents. And we need that stability.

Mr. ENGEL. I am very happy that this hearing includes legislation that I have long championed, the Open Fuel Standard Act, H.R. 1687. Every President for the past 40 years has pledged to free ourselves from the dangers of oil dependence, and you know, our transportation sector is the reason why we are still dependent on oil. Only 1 percent of U.S. electricity is generated from oil, but virtually every car and truck and bus and train, ship and plane manufactured and sold in America runs on oil, and for the most part, they cannot run on anything less. It is by far the biggest reason why we send $400 billion per year to hostile nations and we know that money winds up funding terrorists in their efforts to harm us.

What frustrates me in conversations about oil dependence are usually dominated by calls to drill more or use less. Both can be helpful, but neither is even close to sufficient. Between 2000 to 2008, drilling increased by 66%, and yet gas prices tripled. OPEC merely responded by decreasing its supply, keeping the overall amount of oil in the market the same. So I believe we need a game changing way to alter this dynamic. My colleague, John Shimkus, and I believe that the cheapest way and most effective way to do this is to allow fuels to compete in every new vehicle sold in the U.S., and that is why we have worked together to write the Open Fuels Standard Act. Our bill would simply require new vehicles to be able to operate on non-petroleum fuels, in addition to or instead of petroleum-based fuels. Any kind of fuel would qualify: natural gas, alcohol, hydrogen, biodiesel, plug-in electric, fuel cell, anything other than just plain gasoline, and we are simply looking to open the fuel market to competition so that consumers can choose whichever fuel they want at any given price. Mr. McAdams, you mentioned the United States Energy Security Council, really smart people, former Secretary of State George Schultz, former Secretaries of Defense Bill Perry and Harold Brown, former Secretary of Homeland Security Tom Ridge, former Chairman of the Federal Reserve Alan Greenspan, former Director of the CIA Jim Woolsey, they are all part of this and they stress that we need to break oil’s monopoly over our transportation sector by opening the fuel market to competition from sources other than petroleum.

Mr. PETROWSKI. As I stated in my written statement and oral statement, we believe in diversity. I would not exclude petroleum. Again, we may be on the verge of seeing ethanol spike for a short period of time this summer if we don’t get sufficient rain and relief in the Midwest. You do not want to lock the industry into one fuel, whether it is ethanol or petroleum. Flexibility and optionality is the key to survival.

Mr. BREEN. Flexibility and optionality are absolutely key. It is not that oil is not incredibly important to our economy and unlikely to be so for the foreseeable future, it is. It is that we need to have choices. It is that we can’t be blocked into a single— the behavior of a single commodity that determines our national destiny. That is the issue.

Mr. MARKEY. This is a very important hearing, and because it focuses upon what became a consensus after the first oil embargo, which was that it was critical for the United States to not have American produced oil be exported to foreign countries. And that is an almost 40-year policy now, a consensus that we had reached. And with few exceptions, that has been consistent with American policy over the last 37 years, to keep American crude oil in America, to supply fuel for Americans. The problem is that even with Americans paying an average of $3.38 for a gallon of gasoline, that the large oil companies want to send our resources to foreign countries. With American men and women on the ground in the Middle East, fighting and dying to protect oil supply lines, I don’t think that it is really good for the American Petroleum Institute to say that we should be sending American crude oil abroad, because I just don’t think that we are advancing American security, American employment, and American economy if we are thinking about this oil supply is anything other than something that should be used here in the United States, given the vast amount of oil that we still import into our country on a daily basis. Exporting oil just doesn’t make any sense. It actually goes counter to our goal to reduce our total dependence upon imported oil.

We are now at our highest level of production in the United States in 18 years in the United States of America. And that is quite an achievement for the Obama administration. I mean, Obama really has embraced ‘‘drill baby, drill.’’ I mean, he is just incredible. Eighteen-year high, something the United States never achieved by the Bush administration. In fact, it kept going down during the Bush administration, so let us give this guy credit, all of us. He deserves a lot of credit.

Mr. CASSIDY. I actually met with folks from a major oil company regarding the use of methanol, because obviously produced from natural gas, a way to domestically supplement. We have the experience from California where E85 cars can run. I was told by one of their engineers—they are very nice. They brought somebody in from their testing facility—that EPA will not approve the use of the chemicals required to make methanol immiscible in gasoline. So sure, methanol itself is environmentally OK, but the chemicals used to make it mixable or miscible with the gasoline is not. Is it your understanding, this man’s understanding, that EPA is a major roadblock in using products such as E85?

Mr. Donald Althoff, Chief Executive Officer, Flex Fuel U.S.   There is an EPA-certified street legal E85 flex fuel conversion kit on the market today. Flex Fuel U.S. LLC has developed the first Federal EPA-certified product which legally converts existing cars and light duty trucks to run on any combination of ethanol and gasoline, up to E85. The conversion system is low cost, it is easy to install, factory warranties are maintained. We have had successful pilots in some of the most demanding testing done on any vehicles in the country at DOE and at the EPA. While we are a new company, we have hundreds of these vehicles converted.

Mr. Thomas Hassenboehler, Vice President of Policy Development and Legislative Affairs for America’s Natural Gas Alliance. ANGA is an educational and advocacy organization dedicated to increasing appreciation for the environmental, economic, and national security benefits of North American natural gas. ANGA’s 30 members include many leading North American independent natural gas exploration and production companies. ANGA works to promote a policy environment that increases market-driven use of natural gas as a transportation fuel. We support efforts to encourage a substantial transition of fleet vehicle to natural gas through policies that encourage natural gas vehicle conversions and original equipment manufacturer production. ANGA also supports significant expansion of natural gas fueling infrastructure along key transportation corridors throughout North America.

One region where ANGA has had recent success is the Texas Clean Transportation Triangle, or the CTT. The goal of the CTT is to develop sufficient natural gas stations and initial fleet users to transform heavy duty trucking in Texas. On July 15, 2011, Texas Governor Rick Perry signed into law Senate bill 385, a first of its kind legislation designed to help create a sustainable network of natural gas refueling stations along the interstate highways connecting Houston, San Antonio, Austin, and Dallas/Ft. Worth. The legislation allocates funding from the Texas Emissions Reduction Plan, as well as private sources, to support the development of new stations and the deployment of NGVs. Similar broad stakeholder efforts are now underway in other parts of the country, especially in areas of shale gas production like the Marcellus or Rocky Mountain regions. Another example of NGV momentum is the bipartisan effort underway by Oklahoma governor Mary Fallin and Colorado governor John Hickenlooper. Last fall, they announced a high level initiative to use NGVs in State fleets by aggregating vehicle purchase numbers. Since then, the governors of 11 additional States have signed the NGV MOU. The governors recently sent a letter to 19 auto manufacturers with plants in the U.S., pushing for the increased production of more affordable compressed natural gas vehicles. As an incentive, the governors reaffirmed their commitment to buy CNG vehicles for their respective State fleets.

While these efforts are encouraging, still less than .1 percent of domestic natural gas in 2010 fueled our Nation’s vehicles, and this remains true, despite the fact that there are over 12 million NGVs worldwide today in other parts of the world, and that number continues to grow. Only about 1 percent of those 12 million vehicles are here in the U.S., despite our resources.

We agree that it takes all of the above alternative fuels to enhance our energy security. However, current levels of support for NGVs are not on par with other alternatives. We encourage the committee to take a comprehensive technology and feedstock-neutral approach when evaluating current levels of Federal support for alternative fuels among all areas of the Federal Government, including Executive Branch, Federal fleet performance, Federal agency regulatory programs such as CAFE and EPA greenhouse gas standards, existing mandates such as the RFS, and research and development programs. ANGA appreciates the efforts of Congressmen Shimkus and Engel, and the other cosponsors of the Open Fuel Standard Act. While we are encouraged by this discussion the legislation is helping to create, we are concerned that this mandate on auto makers will not create the level playing field for fuels that is paramount to ANGA.

As of June, 2012, there are currently 53 LNG fueling stations in the U.S. serving over 3,300 LNG vehicles. Of the 53 LNG fueling stations, 36 are located in California.

CNG is ideal for light and medium duty vehicles and any heavy-duty fleets whose operations remain more local, such as municipal operations, refuse collection, and some delivery applications. There are two types of CNG stations: fast-fill and time-fill. A fast-fill station is more expensive than time fill. But it is excellent for retail sales and supporting fleets that require speedy fueling similar to conventional fuels. A time-fill station is less expensive, but works best for fleets that return to central locations and are parked for extended periods – generally overnight — such as a refuse hauling fleet Time-fill fueling is also available for passenger vehicles. with home fueling appliances that connect to the home’s gas line and fuel CNG-powered vehicles over a multi-hour timeframe.

LNG vehicles provide the best commercially available technology for heavy-duty fleets with high fuel use and long-distance travel demands. This is because cooling gaseous natural gas to make liquid takes up about 1/600th the original volume, meaning trucks can carry more energy in their tanks as LNG versus CNG. LNG is dispensed in fast-fill stations via mobile or permanent stations. Mobile stations, which consist of an insulated LNG tank and dispensing equipment built on a trailer that can be parked, provide an ideal option for off-road fueling and remote locations without pipeline access to natural gas. Mobile stations can also provide important fuel support until permanent LNG stations can be built.

Diesel fuel use is rising. Our consumer economy relies on heavy-duty trucks and fueling networks to transport our nation’s goods and drive our economy. Due to growing demand over the last several decades, the number of trucks – and associated diesel consumption – is increasing. Of the 4.8 million heavy-duty trucks (Class 7 & 8) on our roads, 4.2 million run on diesel. These heavy-duty trucks consume over 70% of all diesel in the United States. By 2035, the number of heavy-duty trucks will increase by almost 70%.

The average annual mileage per heavy-duty tractor in the United States is 69,000 miles, which equates to approximately 11,700 gallons of diesel per vehicle each year (assuming 5.9 mpg). Using the national average fuel consumption for a heavy duty tractor, the current annual diesel consumption for heavy-duty tractors is approximately 30 billion gallons of diesel per year, or 82 million diesel gallons per day.

At the federal level, ANGA supports efforts to create a level playing field among alternative fuels policies. We agree that it takes “all of the above” alternative fuels to enhance our energy security. However, current levels of federal support for NGVs are not on par with other alternatives.

Ms. Mary Ann Wright, Vice President of Global Technology Innovation, and the Chair of the Electric Drive Transportation Association, Johnson Controls, Incorporated.

On behalf of the over 25,000 Johnson Controls employees who live in work in your States, and the 115 Electric Drive Transportation Association members really appreciate the opportunity to be here today. I am going to focus on three things. One is just an overview of the powertrains available in the marketplace. Number two is where are we in the advanced battery space in the United States, and number three, where do we go next in terms of establishing the U.S. as a competitor in clean vehicle technology.

Where are we in our advanced battery industry? If we think about staying competitive with advanced vehicle technologies, the U.S. needs to continue to develop its manufacturing and technology capabilities in advanced batteries. We have laid the foundation over the last couple of years, but we are really catching up to the Pacific Rims, which have for decades been making significant investments in R&D manufacturing and supply chain development. As a result, they dominate the market for consumer electronics and advanced batteries for vehicles.

In the fall of 2010, Johnson Controls opened the first high volume domestic lithium ion battery manufacturing plant in Holland, Michigan. This plant was established with the help of the ARA matching grant, and I will tell you, this plant would not have been built in the United States had it not been for that program.

When we think about where we need to go from here, we need to develop a viable and competitive domestic advanced vehicle technology industry, which includes not only batteries, but also electric motors, drives, controls, and software.

What role does the government play? It is critically important of continued Federal support for research, development, and deployment for these technologies. The Department of Energy is successfully promoting innovation in transportation through public- private partnerships, leveraging private sector investments to accelerate technology breakthroughs, manufacturing capability, and deployment of electric vehicles and infrastructure. They are helping to fund bioresearch and development activities to advance vehicle electrification, bring down electric vehicle costs, and increase range and fast charging capabilities. The bottom line is that global competition in this industry will continue to be incredibly intense, particularly from the Pacific Rim, and we have to make sure that we are effectively competing with long-term commitment, focused investments, and continued public- private cooperation and collaboration across the industry. In conclusion, clean technology is about

This spectrum of technologies, from moderate to high vehicle electrification, provides a continuum of market opportunities which will increase fuel economy and reduce emissions. The range of gas savings for each type of vehicle is: Start-Stop 5-10% Advanced Start-Stop 10-20% Mild Hybrid 12-20% Full Hybrid 25-50% Plug-in Hybrid 40-60% Full EV 100%

There is a lot of market and industry investment in electric vehicles but the internal combustion engine, which continues to become more fuel and emissions efficient (complimented by advanced battery technology) is going to be with us for many years to come. Due to electric drive range limitations, lack of installed charging infrastructure and challenged economics, PHEVs and EVs will continue to have limited near-term market penetration in the United States.

Early adopting consumers are willing to accept these limitations, as they are motivated by attributes other than cost and performance.

In Europe, OE commitments to commercialize Start-Stop vehicles are already well established, and the new vehicle build for Start-Stop is expected to reach 70% of new vehicle production by 2016. Globally, annual production is expected to grow from 3 million today to 35 million in that same time frame. Manufacturers are just now beginning to market this technology in the United States. It offers a quick and efficient way for the industry to achieve 2015 CAFE standards with accessible technologies while hybrid and electric alternatives continue to develop and mature. If properly supported, Start-Stop vehicles could achieve 40 percent of the new vehicle market in the United States within the next five years, which would represent significant fuel savings and C02 emissions reduction. Johnson Controls has invested $140 million to convert our existing lead acid battery plant near Toledo, Ohio into a plant which will produce new Absorptive Glass Mat (AGM) batteries for Start-Stop and high efficiency internal combustion vehicles. The plant will begin production later this year with capacity to produce 6 million AGM batteries for North American auto makers.

Federal Government Support

Finally, let me conclude by emphasizing how important it is that we continue federal support for research, development and deployment of the type being conducted by the Department of Energy’s Vehicle Technologies Programs and Advanced Research Project Agency – Energy (ARPA-E). These programs have successfully promoted innovation in transportation through public-private partnerships, leveraging private sector investments. Working with the diverse stakeholders in the electric drive industry, the DOE is helping to accelerate technology breakthroughs, promoting investment in manufacturing capability, and speeding deployment of electric drive vehicles and infrastructure. The Advanced Vehicle Technologies Programs along with the Advanced Research Projects Agency – Energy (ARPA-E) help fund vital research and development activities, which we participate in to advance vehicle electrification, bring down electric vehicle costs, and increase range and fast charging capability. Continued R&D support is vital if we are to stay in the technology race with our foreign competitors.

With respect to tax credits to promote electrified vehicles, it is important to continue with targeted, time-limited and performance-based incentives. Credits such as the $7500 tax credit for vehicle purchase, Section 30B credit for clean, efficient hybrid and battery electric medium and heavy duty vehicles will help promote savings on fuel expenses for large fleets, as well as for small businesses. The expiration of Section 30C alternative fuel vehicle refueling property credit in 2011 has lead to uncertainty around renewal which is damaging to consumers and businesses planning to invest in plug-in vehicles and charging equipment.

Mr. SHIMKUS. I think the main focus of the Open Fuels Standard was to be technology and feedstock neutral. I mean, I think that is the whole focus. We can bring in electric vehicles and hybrid operations, and you see that quite a bit, what better option—and the start and stop option. So you have a start and stop option with a diversified liquid transportation fuel mix that is compatible in internal combustion engines, but also is hybrid so that you can go to electric.

Mr. DOLAN. Right now, there is about 280 million gallons of methanol production in the U.S. Most of that production is used for the chemical industry as a feedstock for hundreds of products that touch our daily lives.

Mr. KARR. We use about 130-odd billion gallons of gasoline a year. So when you are talking about making significant shifts to alternative fuels, you are talking about very significant investments, both in resources and time. It has taken us over 30 years to get to 10 percent with ethanol. It is not that we can’t do it, it is just that we need to go into that with kind of eyes open understanding with the broader context of, you know, the U.S.—the fuel pool and the motor vehicle pool situation.

Mr. HASSENBOEHLER. While there is momentum, the challenges are still enormous, competing with over 120,000 gasoline stations. There are currently 1,000 CNG stations in the U.S. with about 94 that are currently planned all over the country, and we are trying to develop corridors around that.

Mr. RUSH. So what I am seeing from each of you is that we have a long way to go, in terms of helping to bring the infrastructure on par with what we think the future of alternative fuels is, and should be. What do you suggest that we in Congress do in relation to that?

Mr. DOLAN. I think one solution is the Open Fuel Standard Act. We have got the chicken and the egg conundrum here where the retailers aren’t going to be putting any infrastructure until the vehicles are capable of using alternative fuel. The Open Fuel Standard Act would break that by having the cars capable of running on something other than gasoline, and then you have the ability with the free market competition to determine which fuels and which technologies can really make it in the marketplace.

Mr. KARR. I think the primary lesson that we have learned is that we have to pay attention to implementation. You know, at the time I think we thought that large part of the renewable fuel pool would go into the E10 and the national, and the rest would be picked up in E85, and that obviously did not develop. So now, even the first panel spent a lot of time talking about the blend wall. I will tell you all, you know, we ran the numbers really just this past week in preparation for this hearing. If the flex fuel vehicles that are already on the road today, if the owners of those vehicles were using E85 once out of every three times that they go to the pump, so 1/3 of the time that they go to the pump, we wouldn’t be having a conversation about the blend wall. With E10, not even with E15, with E10. So, you know, I don’t necessarily know the answer, you know, exactly why the E85 uptake hasn’t been what we expected in 2005 and ’06 and ’07. A lot of my guys expected it to be more significant than it has been. But it is definitely an issue that, you know, we have to look at going forward.

Mr. GREEN. Feedstocks for alternative fuels are weather dependent and subject to weather conditions. Just look at the current drought plaguing the Midwest. The news reports nightly show how the price of corn is going to go up and affect food prices and other industrial feedstocks. That is why I am a huge supporter, like my colleague and neighbor from Texas, of natural gas. Natural gas vehicles are currently most widely used alternative fuels incorporated in government fleets, and given the continued discovery of natural gas plays around our country, I think we seriously need to look at how we can support these vehicles.

Mr. GREEN. I know my colleague from Illinois has a preponderance of E85 stations in his district. I think I have one that is not in our district, but I only know of one in the Houston area. So are we going to end up being location emphasis, I guess, because obviously in the Midwest you are going to see more corn-based ethanol with E85, whereas in an oil and gas area you will see more options for natural gas. Those stations that the State envisions along those corridors, that is both for over-the-road trucking but also for individual vehicles.

Mr. ENGEL.  I have been pushing for the Open fuel standards bill for many, many years and I must say that I feel progress is being made. Some are criticizing the Open Fuel Standard as a mandate, when it reality it is just the opposite. It is opening the market up to competition. OPEC and the car manufacturers have essentially told us that we have no choice. We will drive on oil. The object is to break that. I must tell you, Mr. Karr, I am really infuriated over the automobile manufacturers. When Democrats were in the Majority, we passed a bill in this committee and on the floor that the comprehensive bill—which we tried to put an Open Fuel Standard in the bill and were fought tooth and nail. This was the so-called Cap and Trade bill. Tooth and nail by the automobile industry—I mean, given the way that we bailed out the automobile industry, I would think that there should be a little bit more of an open mind from the automobile industry about the Open Fuel Standard. I think Mr. Shimkus’s point about how people are buying flex fuel cars, but it is not being marketed. So people have it, they don’t know that they have it really. It hasn’t been a factor in them buying it because it is sort of the best kept secret in town. You talked about estimates of what it would cost to manufacture cars at the beginning with flex fuel cars. Massachusetts Institute of Technology says $90 per car. Former Director of the CIA Jim Woolsey cites General Motors as saying it is $70 per car. One expert, Dr. Robert Zugren, who has run extensive tests, has concluded it is 41 cents per car. In any case, we are talking about $100 or less. I do not understand why there is opposition, and quite frankly, I think the automobile industry is being quite ungrateful in terms of that they would have been gone if we didn’t bail them out. I supported the bailout. I voted for it. I was criticized for it, because I think it is important to have a vibrant and strong American automobile industry. But frankly, I do not understand the opposition. We are not looking to penalize the automobile industry, but on the other hand, the arguments that you are using and to some degree that I have heard today from Mr. Hassenboehler, are arguments that anybody uses to oppose any kind of change or anything that is new. If you worked with us, we would work with you. We would modify our bill. The goal here is not to penalize you guys. The goal here is to make—give Americans choices, so the choices are bring down cost and if the American consumer, you know, can do more.

Mr. Karr, I would like you to answer this. I hope you don’t think I am attacking you personally. By the way, you have a great name for your position. But I am just really frustrated.

Mr. KARR. Sure. Let me start by saying that, you know, I admire you and the place that you come from, and the fact that, as you say, you have been on this for multiple Congresses, and I know that your intentions are pure and I know that your goal is to, again, reduce the dependence on oil. Fair. Let us take that as a starting premise. The question is if we mandate, you know, E85 and M85 capable vehicles, does that get you to your goal, and the experience to date is no. Again, we don’t even produce methanol as a transportation fuel in the United States, so literally if every vehicle today was capable of running on methanol and gas prices shot to $10 a gallon, there is no methanol for people to switch to.

Mr. ENGEL. But let me just tell you, that is like what came first, the chicken or the egg? It is like on our side sometimes, we argue against drilling in Alaska because we are not going to get that oil for another 10 years, so why should we even bother with that? Well, 10 years has passed. If we had done it 10 years ago, we would have the oil. So those arguments don’t really cut water in my estimation.

Mr. KARR. I think it was OK to make the chicken and the egg argument, you know, 7 or 8 years ago, but the fact is we do have States in the Midwest, like Minnesota, where there are more than 400 E85 pumps. You know, Mr. Shimkus can hit one any place in his district. We are still seeing E85 usage at basically the equivalent of one tank full per year.

Mr. ENGEL. But let me just ask you this. Hasn’t hydro-fracking changed the game here in the United States? We are now producing more natural gas than we can use.

Mr. KARR. We talked to natural gas manufacturers. Obviously, my guys want to know what to build and they want to know what direction the market is going, and what we hear is what you are hearing here and what you are seeing in legislation in terms of the Nat Gas Act. The focus is all on LNG and CNG, and not making natural gas into methanol. I don’t know why that is, but—well, I suppose LNG and CNG are significantly cheaper, even than methanol from natural gas.

Ms. WRIGHT. So you raise a really important point, and that is not just on the rare earth, but it is just the materials we are using for any of our advanced technologies.

Mr. BILBRAY. Every study that we did at AR Resources Board show that it was better to burn the natural gas in the car than it was to burn it at the power plant, generate electricity, and transform—I think even the electric car people understand that. And so we really have missed not just an economic opportunity, but an environmental one that if you are going to generate electricity, to generate—to run the electric, you want a zero emission generator and use natural gas at onsite, which is very low technology, as the auto industry knows, but that home dispensing is absolutely an essential part. I yield back.

Mr. BILBRAY. in California, 85 percent of the homes are plumbed with natural gas. People park their cars 3 feet from their water heater in their garage, but we have not figured out how to allow the consumer to fill up at home.  My frustration is while we spend half a billion dollars subsidizing thin film photovoltaic technology, we ignored the fact that we had a 3-foot gap that not 20 years from now, 30 years from now, but could give the consumer the choice today to either fill up at home while they are sleeping with 100 miles range of natural gas, or go to the gas station. But we have sort of taken natural gas and it has been the orphan fuel out there, and that flexibility was a Federal—I mean, a local or a State government regulatory obstructionism. And oh God, I hear about the safety of it being at home, and I always say we will burn a candle next to the pump so it will be just like a water heater.

AFPM, the American Fuel & Petrochemical Manufacturers (formerly National Petrochemical & Refiners Association) respectfully submits this letter for the record regarding the House Energy and Commerce Subcommittee on Energy and Power hearing titled, “The American Energy Initiative: A Focus on Alternative Fuels and Vehicles, Both the Challenges and Opportunities,” AFPM is a trade association representing high-tech American manufacturers of virtually the entire U.S. supply of gasoline, diesel, jet fuel other fuels and home heating oil, as well as the petrochemicals used as building blocks for thousands of products vital to everyday life. Our primary principle is that free markets, not mandates, should and can drive sensible integration of alternative fuels into the consumer marketplace.

Impending “Blendwall” limits are soon to reach a point where the mandated amounts of renewable fuels blended into the fuel supply will soon reach the limits of what fuel and vehicle infrastructure can handle, which is known as the “blendwall.” Our businesses will not be able to blend the amount of ethanol mandated under the RFS without significantly causing consumer disruption. The blendwall will be reached when nearly all of the gasoline in the U.S. contains 10 percent ethanol and a portion ofE8S (fuel containing 8S percent ethanol, 15 percent gasoline) is sold for use in Flex Fuel Vehicles (FFVs). Unfortunately, recent increases in CAFE standards compound this problem. According to analysis by the National Association of Convenience Stores (NACS), by 2022 every gallon of fuel sold in the United States will need to contain nearly 40 percent renewable fuels to legally meet both the RFS and CAFE. In particular, NACS found that because CAFE standards will cause fuel demand to drop while the volumetric mandates ofthe RFS will continue to rise, obligated parties will likely be mandated to force more biofuels into an infrastructure unable to accommodate higher blends. Such a scenario would cause significant problems for consumers and their vehicles, which underscores the unintended consequences of government crafting fuel policies in a vacuum.

Natural Gas as a Transportation Fuel In addition to the problems with the RFS, AFPM has concerns with proposals to create massive subsidies and mandates for further use of natural gas as a transportation fuel. A recent IHS CERA report found that low natural-gas prices make natural gas powered vehicles economical in the transportation sector without federal incentives, and that any upfront investment costs could be recovered in three years. Moreover, natural gas is an important feedstock for petrochemical manufacturing, power generation, and many other products such as fertilizer. Distorting the market through mandates and subsidies will have unintended consequence, much like the

RFS. Markets, not mandates and subsidies, should determine the highest and best use of our natural resources. AFPM looks forward to working with you and the other members of Congress to find common sense solutions to the use of alternative fuels in the fuel supply in a manner that does not pick winners and losers through government mandates and subsidies.

In November 2010, Celanese announced that we had developed a new advanced technology, branded TCX·, that converts basic hydrocarbons such as natural gas Into ethanol. While the science behind this conversion Is not new, Celanese was able to build upon Its Industry-leading expertise In acetyl chemistry to develop a process that is highly efficient and cost-competitive.

When Congress updated the RFS under the Energy Independence & Security Act of 2007 (EISA), It significantly Increased the mandate for blending of renewable fuels. Congress, however, did not account for predictable technological advancements In the fuels market. Under the current framework, qualifying fuels must be produced from renewable biomass and must fit into one of a few narrow fuel categories.

A rigid approach falls short of a true “all of the above” energy strategy. Celanese believes that If ethanol produced using a variety of feedstocks like natural gas were eligible to compete on a level playing field in the current fuels market, it could substantially Improve energy security In the u.s. by diversifying ethanol production. It also could help reduce the negative effects of diverting food and feed crops to the fuel market. In addition, natural gas to ethanol technology offers greater energy efficiency in the conversion of feedstocks to fuel while using substantially less water than traditional fermentation technology and producing almost no waste.

Currently, most eligible fuels are made from agricultural crops grown primarily in the Midwest. Regions that cannot efficiently grow these crops are at a significant cost disadvantage. The current RFS also creates logistical Issues by effectively requiring these fuels to be transported from a largely centralized location to blending facilities across the country, which can be time-consuming, complex and expensive. Broadening the eligibility requirements of the RFS would level the playing field, enable all regions to participate in their transportation fuel future and reduce the Infrastructure development needed. For these reasons, Celanese and a broad cross-section of agricultural, small business and community based organizations from all over the US Joined together to support H.R. 3773, the Domestic Alternative Fuels Act, Introduced by Rep. Pete Olson (R-TX). This legislation would broaden the eligibility requirements of the RFS to allow innovative, home-grown, new fuel technologies like natural gas to ethanol to compete with corn-based ethanol. We believe this is the appropriate approach given the mature nature of the corn-based ethanol industry and the generally accepted view that the advanced blofuel segment needs considerably more time to develop. Finally, expanding the ellgiblflty requirements for feedstocks and manufacturing processes will help advance the science and technology needed to meet the country’s growing energy needs. It Is no secret that the advanced blofuels mandated under the RFS have been slow to commercialize.

 

BOB DINNEEN.   President & CEO, Renewable Fuels Association.

America’s ethanol industry, buttressed by a visionary Renewable Fuel Standard, is already decreasing our reliance on foreign oil, already exerting downward pressure on gasoline prices, already employing tens of thousands of American workers, and already cleaning up our air. As a result of the forward-looking nature of the RFS, the industry is poised to make even more significant contributions to our Nation’s economic and environmental security in the future. Simply put, the RFS is among the most successful energy policies this Nation has ever adopted. It is working exactly as intended. It most certainly does not need an overhaul.

We cannot frack our way to energy independence. A study that EIA produced a short while ago said that if you take the two largest shale places in this country, the Bakken fields and Eagle Ford in Texas, that that would get you 7 billion barrels of oil, a big amount, absolutely. But when put in context of our oil needs in this country, that represents 1 year and 4 months of supply. I will tell you that the need for domestic renewable fuels will outlive the current fracking frenzy.

Certainly, increased oil production from fracking has played a role, but a little context is needed. At the same time new fracking wells are ramping up in North Dakota and Texas, old conventional oil wells are running dry in Alaska, California, and Louisiana. So, while total U.S. oil production has been on the upswing the last three years, it is still well below the levels from the 1990s and even below the levels from the first several years of the new millennium.

We need to be mindful of just how long hydraulic fracking can sustain our nation’s insatiable appetite for crude oil. After all, the “tight oil” in the Bakken and Eagle Ford shale formations is a finite resource, just like the oil sitting under the deserts of Saudi Arabia, the jungles of Venezuela and Nigeria, and the deep waters of the Gulf of Mexico.

A 2011 report by the Energy Information Administration (EIA) estimates that 7 billion barrels of oil are technically recoverable from the Bakken and Eagle Ford formations, the two largest active shale plays in North America. That may sound like a lot of oil- and it is. But the U.S. oil refining industry processed 5.4 billion barrels of crude oil in 2011. That means if near-term oil demand is consistent with 2011 levels, our nation’s two largest shale plays have enough technically recoverable crude oil combined to last us about one year and four months.

Energy Information Administration. July 2011. Review of Emerging Resources: U.S. Shale Gas and Shale Oil Plays. http://205.254.135. 7/analysislstudies/usshalegas/pdflusshaleplays. pdf

 

Biodiesel RIN fraud has been described by some biofuel critics as “rampant,” “systemic,” and “widespread.” However, a closer look reveals that such descriptions of the situation are nothing more than salacious hyperbole. In truth, the fraudulent activity was very isolated and resulted from the actions of just three bad actors in the biodiesel space. The U.S. Environmental Protection Agency (EPA) effectively identified those bad actors, investigated the fraud, and pursued appropriate enforcement action. In other words, the bad apples were quickly rooted out of the barrel. Meanwhile, the vast majority of other participants in the RFS program were properly generating RINs without any problems whatsoever.

Here are a few statistics for context. Since the RFS2 program began in July of2010, nearly 29 billion RINs have been generated (this includes all RINs for all types ofbiofuels). Of that amount, 140 million RINs have been shown or alleged to be fraudulent. That means less than 0.5 percent of total RINs generated have been fraudulent or alleged to be fraudulent. Further, all of the alleged fraudulent RINs have occurred within the biodiesel space of the RFS, which constitutes a relatively smaller share of the program. “Renewable fuel” RINs the type associated with corn ethanol- have comprised the overwhelming majority of RINs generated under the RFS, accounting for 26 billion RINs (nearly 90 percent of the total). Those 26 billion ethanol RINs have been generated without a single one of them being purposely fraudulent.

The RFS requires the consumption of36 billion gallons of renewable fuel by 2022. In the Regulatory Impact Analysis that accompanied the RFS2 final rule, EPA suggested ethanol could account for as much as 33.2 billion gallons of the 2022 requirement. This level of ethanol would represent 25.4 percent of projected gasoline demand in 2022, according to data from the EIA. This means the average gallon of gasoline in 2022 would need to contain 25 percent ethanol in order to comply with the RFS2. However, only FFVs are currently approved to consume gasoline blends containing more than 15 percent ethanol by volume. The U.S. automakers have made good progress toward increasing their production ofFFVs, and the “Detroit Three” have stated their commitment to provide one-half of their sales of model year 2012 and later vehicles as FFVs. Today, an estimated II million FFVs are on American roadways. While that’s a good start, it represents just 5 percent of the light-duty automotive fleet. Without a doubt, a larger population of FFVs will be needed to consume the volumes of ethanol likely to be produced to meet the RFS’s long-term requirements.

Additionally, the RF A has joined with leaders from other alternative fuel industries to press Congress to enact the Open Fuel Standard (OFS), a visionary piece of legislation introduced by Representatives John Shimkus (R-IL) and Eliot Engel (D-NY). The OFS would require that a certain portion of passenger vehicles sold in the U.S. be alternative fueled vehicles capable of running on something other than just petroleum-derived gasoline. The OFS does not dictate what types of vehicles are to be sold, only that an increasing percentage of the passenger car fleet sold in the U.S. be capable of running on non-petroleum sources, such as electricity, ethanol blends, hydrogen, biodiesel, natural gas, or other sources. Not only would the OFS greatly enable fuel competition and reduce the strategic importance of oil to the United States, but it would also facilitate compliance with the long-term goals of the RFS2.

 

As part of their ongoing effort to undermine the RFS, opponents of biofuels have highlighted the lack of cellulosic and advanced ethanol commercially available in recent years. They have suggested that the slower-than-expected commercialization of cellulosic and advanced ethanol is evidence that Congress should step in and reform the RFS. While scale-up is occurring more slowly than anticipated, the advanced and cellulosic biofuels industry is now in the process of building new plants, modifying existing production facilities with emerging “bolt-on” technologies, and introducing new product streams that will allow the renewable fuels sector to become more profitable, diversified and efficient. These are not “phantom fuels,” as some would have us believe. In fact, it was reported just last week that the first cellulosic biofuel RINs were generated by an ethanol facility in Upton, Wyoming, a small town in the heart of the state’s oil patch. Several billion dollars have been invested in advanced biofuels development with the expectation that Congress and the Administration

Also see: Distribution – why it is so hard to add E15 or E85 at a gas station

Jack Gerard, President and CEO of the American Petroleum Institute. Over the past 7 years, the two RFS laws passed in 2005 and in 2007 have substantially expanded the role of renewables in America. Biofuels are now in almost all gasoline. While API supports the continued appropriate use of ethanol and other renewable fuels, the RFS law has become increasingly unrealistic, unworkable, and a threat to consumers. It needs an overhaul. Most of the problems relate to the law’s volume requirements. These mandates call for blending increasing amounts of renewable fuels into gasoline and diesel. Although we are already close to blending an amount that would result in a 10 percent concentration level of ethanol in every gallon of gasoline sold in America, that which is the maximum known safe level, the volumes required will more than double over the next 10 years. The E10, or 10 percent ethanol blend that we consume today could, by virtue of RFS volume requirements, become at least an E20 blend in the future. This would present an unacceptable risk to billions of dollars in consumer investment in vehicles, a vast majority of which were designed, built, and warranted to operate on a maximum blend of E10.

It also would put at risk billions of dollars of gasoline station equipment in thousands of retail outlets across America, most owned by small independent businesses. I believe well over 60 percent of retail establishments in this area are Ma and Pa operations.

Vehicle research conducted by the Auto Oil Coordinated Research Council shows that E15 could also damage the engines of millions of cars and light trucks, estimates exceeding five million vehicles on the road today. E20 blends may have similar, if not worse, compatibility issues with engines and service station attendants.

The RFS law also requires increasing use of cellulosic ethanol, an advanced form of ethanol that can be made from a broader range of feed stocks. The problem is, you can’t buy the fuel yet because no one is making it commercially. While EPA could waive that provision, it has decided to require refiners to purchase credits for this nonexistent fuel, which will drive up costs and potentially hurt consumers. Mandating the use of fuels that do not exist is absurd on its face and is inexcusably bad public policy.

To date, E85 has faced low consumer acceptance as FFV owners use E85 less than 1% of the time. The fuel economy of an FFV operated on E85 is approximately 25-30% lower than when fueled with gasoline due to ethanol’s lower energy content. Also, less than 2% of retail gasoline stations offer E85, which has high installation costs. In 2010 and 2011, EPA approved the use of E15 for a portion of the motor vehicle fleet in order to accommodate the RFS law’s volume increases. We believe these actions were premature and unlawful, and present an unacceptable risk to billions of dollars in consumer investments in vehicles. They also put at risk billions of dollars of gasoline station pump equipment in scores of thousands of retail outlets across America, most owned by small independent businesses. E15 is a different transportation fuel, well outside the range for which the vast majority of U.S. vehicles and engines have been designed and warranted. E15 is also outside the range for which service station pumping equipment has been listed and proven to be safe and compatible and conflicts with existing worker and public safety laws outlined in OSHA and Fire Codes. EPA should not have proceeded with E15, especially before a thorough evaluation was conducted to assess the full range of short- and long-term impacts of increasing the amount of ethanol in gasoline on the environment, on engine and vehicle performance, and on consumer safety. Research on higher blends was already underway when EPA approved El5 in 2010 and 2011. In response to the passage of EISA in 2007, the oil and natural gas industry, the auto industry, and other stakeholders, including EPA and DOE, recognized in early 2008 that substantial research was needed in order to assess the impact of higher ethanol blends including the compatibility of ethanol blends above 10% (E10+) with the existing fleet of vehicles and small engines. Through the Coordinating Research Council (CRC), the oil and auto industries developed and funded a comprehensive multi-year testing program prior to the biofuels industry’s E15 waiver application. API worked closely with the auto and off-road engine industries and with EPA and DOE to share and coordinate research plans. Yet, EPA approved the E15 waiver request before this research effort was finished and the results thoroughly evaluated. The potential for harm from that decision is substantial, as suggested by the results of various research studies, including testing performed by DOE’s National Renewal Energy Laboratory and by the CRC, have been completed to date. The DOE research shows an estimated half of existing service station pumping equipment may not be compatible with a 15% ethanol blend. The CRC research shows that E15 could also damage the engines of millions of cars and light trucks.

E20 may have similar, if not worse, compatibility issues with engines and service station equipment.

JOSEPH H. PETROWSKI. Gulf Oil Group, We are the Nation’s eighth largest convenience retailer of petroleum products and convenience items in over 13 States. Our wholesale oil division, Gulf Oil, carries and merchandises over 350,000 barrels of petroleum products and biofuels over 29 States, $13 billion revenue places us in the top 50 private companies in the country. We employ 8,000 employees,

We do not drill, we do not refine petroleum products. What we care to sell are products that our customers want to buy that are most economic for them to achieve their desired transport, heating, and other energy uses in a lawful manner.

We blend—in addition to selling petroleum products, which is our primary product that we sell, we blend over 1 million gallons a day of biofuels across our system, and just recently, we have purchased 24 Class A trucks to begin to fuel on natural gas to deliver our fuel products to our stations and stores.

We believe that a sound energy policy rests on four bedrocks. One is that we have diverse fuel sources, and there are two reasons for that. The future is unknowable. The new shale technology that has taken over the industry in natural gas was unheard of more than 2 decades ago. Technology and events are beyond our abilities to understand where we are going, and so to bet any of our future on one single source of fuel would be a mistake. We believe diversity in all systems ensures health and stability. And so we look for diversity in fuel, not only by fuel type, but to make sure that we are not concentrated in taking it from one region, particularly the Middle East and unstable regions.

I do want to point out to all the members that we have billions, hundreds of billions of dollars invested in terminals, gas stations, barges, transportation, and we have to live with the realities of the marketplace and the particulars.

America’s love affair with the automobile is not going away. Neither is the need for transportation fuels that underpin the economy and create jobs. In a country as vast as ours with a density of79 people per square mile (as opposed to the Netherlands with 1300 people per square mile), the cost of transport is central to economic health.

When total national energy costs exceed 16% of GDP a recession or worse is almost always the result. The United States’ current accounts trade balance for all energy products recently exceeded $1 trillion dollars, and while it has currently been reduced to one half that amount on an annualized basis we look forward to the day when the United States is a net energy exporter. Not only will that be positive to GDP and job growth, but it will position us to revitalize our industrial production, especially in energy-intensive industries with an eye toward value added product exports. And no policy would be more beneficial for the spread of world democracy

Our industry is dominated by small businesses. In fact, of the 120,950 convenience stores that sell fuel, almost sixty percent of them are single-store companies – true mom and pop operations. Many of these companies sell fuel under the brand name of their fuel supplier. This has created a common misperception in the minds of many policymakers and consumers that the large integrated oil companies own these stations. The reality is that the majors are leaving the retail marketplace and today own and operate fewer than 2% of the retail locations. Although a store may sell a particular brand of fuel associated with a refiner, the vast majority are independently owned and operated like mine. When people pull into an Exxon or a BP station, the odds are good that they are in fact refueling at a small mom-and-pop operation.

THE BLEND WALL AND THE NEED FOR A CONGRESSIONAL FIX. Since the enactment of the Energy Independence and Security Act (EISA) of2007, we have heard much about the impending arrival of the so-called “blend wall” – the point at which the market cannot absorb any additional renewable fuels. Most of the fuel sold in the United States today is blended with 10% ethanol. If 10% ethanol were blended into every gallon of gasoline sold in the nation in 2011 (33.9 billion gallons), the market would reach a maximum of 13.39 billion gallons. However, the 2012 statutory mandate for the RFS is 15.2 billion gallons. Meanwhile, the market for higher blends of ethanol (E85) for flexible fuel vehicles (FFVs) has not developed as rapidly as some had hoped. Clearly, we have reached the blend wall.

EPA recently authorized the use ofE15 in certain vehicles. However, this has so far done very little to expand the use of renewable fuels, due largely to retailers’ liability and compatibility concerns, as well as state and local restrictions on selling E15. Congress can do something immediately to mitigate other obstacles preventing new fuels from entering the market. H.R. 4345, the Domestic Fuels Protection Act of 2012-currentiy before the subcommittee on Environment and the Economy-addresses three of these obstacles: infrastructure compatibility, liability for consumer misuse of fuels, and retroactive liability of the rules governing a fuel change in the future.

The reason the retail market is unable to easily accommodate additional volumes of renewable fuels begins with the equipment found at retail stations. By law, all equipment used to store and dispense flammable and combustible liquids must be certified by a nationally recognized testing laboratory. These requirements are found in regulations of the Occupational Safety and Health Administration. Currently, there is essentially only one organization that certifies such equipment, Underwriters Laboratories (UL). UL establishes specifications for safety and compatibility and runs tests on equipment submitted by manufacturers for UL listing. Once satisfied, UL lists the equipment as meeting a certain standard for a certain fuel. Prior to 20I0, UL had not listed a single motor fuel dispenser (aka a gas pump) as compatible with any fuel containing more than 10% ethanol. This means that any dispenser in the market prior to early 20lOis not legally permitted to sell E15, E85 or anything above 10% ethanol – even if it is able to do so safely.

If a retailer fails to use listed equipment, that retailer is violating OSHA regulations and -may be violating tank insurance policies, state tank fund program requirements, bank loan covenants, and potentially other local regulations. In addition, the retailer could be found negligent per se based solely on the fact that his fuel dispensing system is not listed by UL. This brings us to the primary challenge: if no dispenser prior to early 20I0 was listed as compatible with fuels containing greater than ten percent ethanol, what options are available to retailers to sell these fuels? In order to comply with the law, retailers wishing to sell EI0+ fuels can only use equipment specifically listed by UL as compatible with such fuels. Because UL did list any equipment as compatible with E10+ fuels until 2010, only those units produced after that date can legally sell E I 0+ fuels. All previously manufactured devices, even if they are the exact same model using the exact same materials, are subject only to the UL listing available at the time of manufacture. (UL policy prevents retroactive certification of equipment.)

Practically speaking, this means that a vast majority of retailers wishing to sell EIO+ fuels must replace their dispensers. This costs an average of $20,000 per dispenser. It is less clear how many underground storage tanks and associated pipes and lines would require replacement. Many of these units are manufactured to be compatible with high concentrations of ethanol, but they may not be listed as such. Further, if there are concerns with gaskets and seals in dispensers, care must be given to ensure the underground gaskets and seals do not pose a threat to the environment. Once a retailer begins to replace underground equipment, the cost can escalate rapidly and can easily exceed $100,000 per location.

The second major issue facing retailers is the potential liability associated with improperly fueling an engine with a non-approved fuel. The EPA decision concerning EI5 puts this issue into sharp focus for retailers. Under EPA’s partial waiver, only vehicles manufactured in model year 2001 or more recently are authorized to fuel with E15. Older vehicles, motorcycles, boats, and small engines are not authorized to use E15. For the retailer, bifurcating the market in this way presents serious challenges. For instance, how does the retailer prevent the consumer from buying the wrong fuel? Typically, when new fuels are authorized they are backwards compatible so this is not a problem. In other words, older vehicles can use the new fuel. When EPA phased lead out of gasoline in the late I 970s and early 1980s, for example, older vehicles were capable of running on unleaded fuel newer vehicles, however, were required to run only on unleaded. These newer vehicle gasoline tanks were equipped with smaller fill pipes into which a leaded nozzle could not fit – likewise, unleaded dispensers were equipped with smaller nozzles. E 15 is very different: legacy engines are not permitted to use the new fuel. Doing so will violate Clean Air Act standards and could cause engine performance or safety issues. Yet there are no viable options to retroactively install physical counter measures to prevent misfueling.

Retailers could be subject to penalties under the Clean Air Act for not preventing a customer from misfueling with E15. This concern is not without justification. In the past, retailers have been held accountable for the actions of their customers. For example, because unleaded fuel was more expensive than leaded fuel, some consumers physically altered their vehicle fill pipes to accommodate the larger leaded nozzles either by using can openers or by using a funnel while fueling. We may see similar behavior in the future given the high price of gasoline relative to ethanol. As in the past, the retailer will not be able to prevent such practices, but in the case of leaded gasoline the EPA levied fines against the retailer for not physically preventing the consumer from bypassing the misfueling counter measures. To EPA’s credit, they have asserted in meetings with NACS and SIGMA that they would not be targeting retailers for consumer misfueling. But that provides little comfort to retailers. EPA policy can change in the absence of specific legal safeguards. Additionally, the Clean Air Act includes a private right of action and any citizen can file a lawsuit against a retailer that does not prevent misfueling. Whether the retailer is found guilty does not change the fact that defending against such claims is very expensive. Further, the consumer may seek to hold the retailer liable for their own actions. Using the wrong fuel could void an engine’s warranty, cause engine performance problems or even compromise the safety of some equipment. In all situations, some consumers may seek to hold the retailer accountable even when the retailer was not responsible for the improper use of the fuel. Once again, defending such claims is expensive.

An EPA decision to approve E15 for 2001 and newer vehicles is not consistent with the terms of most warranty policies issued with these affected vehicles. Consequently, while using E15 in a 2009 vehicle might be lawful under the Clean Air Act, it may in fact void the warranty of the consumer’s vehicle. Retailers have no mechanism for ensuring that consumers abide by their vehicle warranties – it is the consumer’s responsibility to comply with the terms of their contract with their vehicle manufacturer. Therefore, H.R. 4345 stipulates that no person shall be held liable in the event a self-service customer introduces a fuel into their vehicle that is not covered by their vehicle warranty.

General Liability Exposure Finally, there are widespread concerns throughout the retail community and with our product suppliers that the rules of the game may change and we could be left exposed to significant liability. For example, EI5 is approved only for certain engines and its use in other engines is prohibited by the EPA due to associated emissions and performance issues. What if E 15 does indeed cause problems in non-approved engines or even in approved engines? What if in the future the product is determined defective, the rules are changed and E 15 is no longer approved for use in commerce? There is significant concern that such a change in the law would be retroactively applied to anyone who manufactured, distributed, blended or sold the product in question.

Contrary to popular misconception, fuel marketers prefer cheap gasoline. The less the consumer pays at the pump, the more money the consumer has to spend in our stores, where our profit margins are significantly greater.

FELICE STADLER. National Wildlife Federation. We represent 4 million members and supporters.

Faced with these stark climate-changing realities, the National Wildlife Federation is propelled to ignite a national call to move this country swiftly down an alternate, sustainable, low-carbon fuels and electric generating path. We are not naive to think that getting off high-carbon liquid fuels will be an easy task. It will require a major overhaul of our car and truck fleet; a major revamping of our public transit systems; a major investment in sustainable, renewable fuels; and a major shift in our fossil fuels subsidies structure. The good news is that we are making progress in a few limited areas. Corn ethanol has shown what is possible, but it is not the long term answer to our Nation’s energy needs. We need more support to get us to the next generation of biofuels from non-food, perennial crops and wastes, that create significant greenhouse gas reductions and not lead to other major environmental problems.

Faced with these stark climate-changing realities, the National Wildlife Federation is propelled to ignite a national call to move this country, swiftly down an alternate, sustainable, low-carbon fuels path.

  1. Coal to liquids wouldn’t be on this path-From well to wheel, CO2 emissions from coal-derived fuel is twice as high as conventional petroleum-derived fuel.
  2. Canadian tar sands wouldn’t be on this path-Producing oil from tar sands emits 2-3 times the carbon pollution of conventional oil.
  3. Western oil shale wouldn’t be on this path-While still in the R&D phase, it is estimated that retorting oil shale will emit up to two times more greenhouse gas emissions than that from conventionally produced gasoline.

We’re not naive to think that getting off high-carbon liquid fuels (including conventional oil and gas) will be an easy task-it will require a major overhaul of our car and truck fleet; it will require a major revamping of our public transit systems; it will require a major investment in sustainable, renewable fuels; it will require a major shift in our subsidies structure-to level the playing field between the oil and gas giants and the companies trying to get efficient, renewable technologies into the marketplace.

Mr. Gregory Dolan, Executive Director, Americas/Europe Methanol Institute. The Methanol Institute, represents methanol producers, distributors, and related technology companies from around the world.

In the late 1970s, when high gasoline prices driven by instability in the Middle East led to long lines at the pump, our country began to explore new alternatives in earnest. At that time, the State of California looked at the range of alternative fuels that can reduce the economic burden of oil, and also provide environmental benefits for consumers. California at that time determined that methanol offered the best range of benefits. California launched the Nation’s first large scale alternative fuel demonstration program, placing nearly 18,000 methanol-fueled vehicles on the roads and establishing a network of 100 methanol fueling stations. America was leading the way in transportation innovation with the methanol experiment.

Methanol is the most basic form of alcohol, and is naturally occurring in the environment. Methanol is readily biodegradable and it is much more environmentally benign than gasoline. Commercially, methanol can be made from anything that is or ever was a plant. It can be made from natural gas and coal. It can also be made from forest thinnings, biomass, municipal solid waste, even CO2 itself. We have members at our trade association around the globe that are actively producing these second generation biofuels at the commercial scale today. Worldwide, methanol demand exceeds 15 billion gallons per year, while generating $35 billion in economic activity and 100,000 jobs.

California not only chose methanol for the wide availability of different feedstocks to produce it, they also selected methanol for its low cost and excellent performance. With its high octane rating and efficient burning performance, methanol is most often associated with racing fuels. But the low cost of methanol is its most impressive feature. For the past 5 years, the wholesale cost of methanol has ranged from $1.05 a gallon to $1.15 per gallon. If you were to sell methanol fuel as M85 at the pump today, adding distribution, retail taxes and markup, plus 15 percent gasoline, and accounting for the difference in energy content of methanol, consumers would still pay just $3 a gallon at the pump without any incentives, almost 40 cents a gallon cheaper than the national average of gasoline, which today is $3.38 a gallon. Alcohol fuels also have the lowest cost fuel infrastructure, with pumps costing just 20 to $60,000, and because you can get significant margins from selling methanol at the

California’s experiment continued for a number of years, but ultimately prices for gasoline were brought back down towards historic norms and consumers and governments quickly forgot about the stinging pains of high prices and continued business as usual.

In China, a methanol mix of about 8% of their transportation fuel pool and they use domestic feedstocks to meet that demand. The Chinese have buses, taxis, trucks, and passenger vehicles on the road that are running on a wide range of methanol fuels. China’s powerful National Development Reform Commission considers coal-based methanol to be a strategic transportation fuel. Between 2005 and 2011, China increased its methanol production capacity from 1.5 billion gallons a year to 15.5 billion gallons.

There are no technical hurdles to the use of methanol as an alternative fuel. We know what materials to use in the cars. We know how to make those cars run efficiently. The first flexible fuel vehicles that Ford built ran on both ethanol and methanol. Lotus Engineering has been building tri-fuel engines. We also know that the cost to add a flex fuel capability to a new car is just $150.

A STUDY PUBLISHED IN 2010, RESEARCHERS AT THE MASSACHUSETTS INSTITUTE OF TECHNOLOGY CONCLUDED THAT METHANOL WAS THE ‘LIQUID FUEL MOST EFFICIENTLY AND INEXPENSIVELY PRODUCED FROM NATURAL GAS: AND THEY RECOMMENDED METHANOL AS THE MOST EFFECTIVE WAY TO INTEGRATE NATURAL GAS INTO OUR TRANSPORTATION ECONOMY.

MICHAEL J. MCADAMS, Advanced Biofuels Association. I represent over 45 companies deploying advanced renewable technologies that are helping to create jobs and reduce dependence on foreign oil by adding to our domestic fuels production capacity. The Advanced Biofuels Association supports an all of the above energy approach for the United States. The Renewable Fuels Standard is the bedrock of our Nation’s renewable transportation fuels policy, and it is directly responsible for the progress that has been made to date in the advanced biofuels sector. As a result of this policy, a number of companies have made significant investments in R&D, pilot and demonstration phases, as well as commercial deployment. Currently, a number of sophisticated manufacturing companies have over a billion dollars of private capital ready to build their first commercial facilities. As you well know, uncertainty chills investment.

We have seen the top fighter planes in the Air Force, Navy, and Marines fly using drop in jet fuels produced from a wide range of feed stocks and technologies. We have seen U.S. major airlines fly U.S. transcontinental flights.   Last year alone, Lufthansa operated more than 1,000 flights in Europe on a 50/50 blend of biofuels. Last week, the Air Force flew an A–10 warthog on the first alcohol-to-jet fuel produced by U.S.—in the U.S. by Gevo, a Colorado company.

I look down the list of those testifying today, I doubt a single witness would disagree that in order to secure America’s energy and economic security, we need a wide portfolio approach to our nation’s energy policy. Energy is not a partisan issue. [t is an issue of economic and national security. It is the lifeblood of an active, vibrant economy that provides plentiful employment for its people and ultimately leads to a high gross national product and sustainable middle class. Energy policy is a key driver in the future prosperity of this nation,

 

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Overview of the United States freight transportation system. House hearing 2013

House 113-13. April 24, 2013. Overview of the United States Freight Transportation System. House of Representatives.  

[ excerpts from the 193 page transcript of the house hearing ]

Chairman Shuster and Ranking Member Rahall have designated this panel to examine the current state of freight transportation in the United States, and how improving freight transportation can strengthen the United States economy. The safe and efficient movement of freight throughout the Nation impacts the day-to-day lives of every American, from the clothes you wear to the car you drive to the food you eat—the freight transportation system impacts all aspects of everyday life. In 2011, the U.S. transportation system moved 17.6 billion tons of goods valued at over $18.8 trillion.

In the past, the conversation about freight transportation is focused on specific modes of transportation. However, given the multimodal nature of freight movement, it is important to examine the system as a whole. Goods frequently move back and forth between ocean vessels, highways, railroads, air carriers, inland waterways, ports, and pipelines. Bottlenecks arising at any point on the system can seriously impede freight mobility and drive up the cost of the goods impacted. For this reason, improving the efficient and safe flow of freight across all modes of transportation is critical to the health of the United States economy and the future of the Nation’s global competitiveness.

FREDERICK W. SMITH, CHAIRMAN, PRESIDENT, AND CEO, FEDEX CORPORATION

When I first began in transportation, logistics measured as the cost of transportation, inventory, carrying cost, and warehousing were about $.15 out of every dollar in the economy. And because of the substantial improvements in the Nation’s infrastructure, and the deregulation that took place beginning in the early seventies through 1994, logistics costs were reduced to about 9 percent.

The second thing which we feel very strongly about and is a very easy and quick solution, is to permit the use of longer vehicles in the sectors of the industry that use twin trailers. Today those are limited to 28 feet each. And the reality is, in the ground parcel business, the vehicles are significantly underutilized because the traffic being generated by the e-commerce world, the direct shipping, and the lighter weight, smaller packages, the vehicles are not very well utilized. They pull approximately 22,000 to 24,000 pounds in the two 28-foot trailers.

In the less-than-truckload industry the same thing applies. On there the cube weight ratio will get between 26,000 and 28,000, generally. So, if the Congress permitted the use of somewhat longer vehicles, our recommendation is 33-foot vehicles which would take 600,000 truck trips per year off the road. You would have very quickly vast improvement in national efficiency because you would burn hundreds of millions of gallons of fuel less.

And the third thing that would happen is that you would have significantly enhanced safety because fewer vehicles on the road at the end of the day is the most important element in reducing the number of accidents.

The permission to use longer twin vehicles, not—it does not require any weight increase, which puts more pressure on our infrastructure, in terms of repairs and things of that nature.

It is very difficult to simply raise the fuel tax on an inflation-adjusted basis, back to where it was in 1994, despite the fact that the fuel efficiency of personal automobiles and over-the-road vehicles and all is significantly greater. And I think the reason for that, quite frankly, is that we have had a vast increase in fuel taxes that have been imposed by OPEC, by the price of fuel. So people are very sensitive to the fact that today they are paying, you know, close to $4 a gallon, $3.50, and when we started this decade they were paying less than a fifth of that. FedEx Express, I remember in the spring of 2001, was paying $.67 for a gallon of jet fuel. And today it is $3.30, $3.40, something. You know, it is not a little bit. It is five times. So the average family in the United States is now paying between $2,500 and $3,000 more for gasoline per year than they were 10 years ago.

That is why you have had such a hard time, it seems to me, increasing the gasoline tax, because it just adds to that. But it still doesn’t mitigate the fact that our infrastructure is aging, and our entire economy, as Chairman Duncan said in his opening remarks, you know, depends on this transportation and logistics infrastructure. And we either fix it, improve it, modernize it, and expand it, or we will have a lower standard of living and a lower national income. That is just absolutely 100 percent predictable.

Charles W. Moorman, Chairman, President, and CEO, Norfolk Southern Corporation

Norfolk Southern is the fourth largest privately owned U.S. railroad. Our locomotives last for more than 20 years. Freight cars last a lot longer than that. New tracks can carry traffic for decades. And big terminals—we are expanding one in Bellevue, Ohio, now— serve, literally, generations of customers. We had a bridge over the Ohio River that just turned 100 years old.

We are at the point where we are approaching a crisis. The Interstate Highway System was designed with a 50-year life, and it was built about 50 years ago.

Approximately a third of all rail freight that moves in this Nation moves through Chicago. And that is because, historically, the infrastructure was routed that way. So it is absolutely critically important. It is the single most important point in the North American rail network. And I can tell you that when things don’t go well in Chicago—an example being the blizzard that we experienced up there, all of the freight rail networks start to slow down.

 

If you look at our operations into Chicago, it is our single most important link. We run about 100 freight trains a day in and out of Chicago. And once you get into Chicago, because it is infrastructure that was built over a long period of time accretively, the routes are not particularly efficient. And there is a lot of work that needs to be done. Now, at the same time, that inefficiency of moving traffic through Chicago results in significant delays to the community because of grade crossing congestion. And it presents serious problems for Metro. So it is, of all of the things that—and all the locations that matter not only to Norfolk Southern, but to the North American rail network, Chicago is always number one.

So the Crescent Corridor was identified primarily as we started to look across our network and started to see on the highway system an enormous amount of freight flow traffic, 5 to 6 million trucks a year, which essentially move from the South and the Southwest, up into New York, New Jersey, New England. And it was the largest such freight corridor which has never really had effective rail intermodal service. But it matches up very well to our routes. So, we started to develop a plan to start to add terminals, such as the one at Memphis, one at Birmingham, several in Pennsylvania, to add infrastructure, in terms of capacity, and to enable us to run higher speeds, to be able to provide service to folks like Mr. Leathers and his customers that would be competitive with the truck and offer a better economic solution.

Federal dollars made a lot of difference for us—although most of the investment is ours—is it allowed us to accelerate a lot of projects that we might have done over a 10- or 12-year period, but instead we could do them in 3 or 4 and realize those public benefits, as well as the private benefits, much faster. The Crescent Corridor has about $2 billion in public benefit built in, which has been very carefully analyzed by outside agencies. So it was the culmination of a big project on our part. But as we approached both Federal officials and State officials and told them what we were doing, and told them the impact it would have on highways like Interstate 81, it was enthusiastically embraced by a lot of people. Only in very limited instances will we need to acquire new-right-of-way where we might have to expand from one track to two. It was essentially our existing infrastructure, but a lot of money spent to enhance it. The railroads do have—historically, have always had condemnation rights for rights of way. But it is something we employ very, very rarely. And to my knowledge, did not ever employ in this corridor.

Derek J. Leathers, President and Chief Operating Officer, Werner Enterprises, Inc

We are a diversified logistics company with nationwide and global services, providing truckload freight management and intermodal services to our customers. My statement is consistent with the position of the American Trucking Association, of which we are a member.

Unlike other modes which control their capital investment decisions, the trucking industry is wholly dependent on Federal and State and public agencies to spend the $33 billion in highway user fees the trucking industry contributes annually in a way that provides the industry with good return on our investment through the improvements and highways and infrastructure on which we operate.

Highway bottlenecks cost the trucking industry $19 billion each year in lost fuel, wages, and equipment utilization. We also recommend a much greater investment in the National Highway System, which comprises just 5 percent of highway miles, yet carries 97 percent of truck freight and 55% of all traffic.

The ATA supports dedicated Federal spending for last-mile highway intermodal connectors whose generally poor condition affects the efficiencies of all our modes. It will be difficult, however, to make these strategic infrastructure investments without more revenue. As the committee is well aware, the Highway Trust Fund will be in serious financial straits in 18 months from now. We cannot continue to rely on the general fund to bail out the program year after year. And reducing the size of the program to match current user fee receipts is simply untenable, in our view. It is time for Congress to make the difficult but vital decision to raise and/or index the fuel tax, or do both, to ensure stable funding is available to address the costly deficiencies facing our highway network.

While we are bullish on the future of intermodal, and actively work with our customers on modal conversion, claims that these changes will have significant impact on modal share, in my view, are overstated. Seventy percent of all freight moves by truck today. And although intermodal volumes are growing rapidly, intermodal’s 1.8 to 2.2 percent share is unlikely to change, even in the most bullish projections.

As for whether we do or don’t pay our fair share, I think that will be much to be debated. In the meantime, what I do know is that over 70% of everything delivered to every American in this country is delivered by truck. So whatever wear and tear we may cause is probably wear and tear that people are proud to have us do so they can have the goods and services they enjoy every day. So we will continue to work with the rail, and we will continue to work within our modal solutions on longer length of hauls. But at the end of the day, unless we are going to put rail tracks behind our homes and businesses or dig canals for barges, I suggest that we continue to focus at the task at hand, which is how do we invest in the American infrastructure

James I. Newsome, III, President and CEO, South Carolina Ports Authority

The container shipping industry has been instrumental in the significant growth of globalization over the last 50 years. U.S. shippers enjoy a very competitive market for ocean transportation services. The service provided for containerized cargo is remarkably reliable, and has supported the establishment of complex import and export supply chains routinely utilized by major U.S. corporations in their global transactions.

It also should be noted that ports face significant competition. Ocean carriers have a choice of where to call and when. If a port is unable to provide an efficient and cost-effective option, its customers will go elsewhere. The prospect of heightened competition has been mentioned here this morning between east and west coast ports as a result of the Panama Canal expansion.

Globalization and the offshoring of significant amounts of manufacturing have led to significant trade growth, a lot of which was import-related.

This year we will see the largest injection of new container capacity into the global container fleet in the history of containerization. Eighty percent of the container ship capacity on order is bigger than can go through the Panama Canal today. And by the time the Panama Canal is expanded in 2015, 50% of the container ship capacity and operation will be post-Panamax in size.

These large ships bring dramatic improvements in both economic and environmental efficiency. They require reliable ports at origin and destination to realize these benefits capable of handling such ships productively, and with minimal waiting due to depth or height restrictions. Ports across the country have made and continued to make significant investment in order to satisfy such requirements. For example, the South Carolina Ports Authority is investing $1.3 billion in the next 10 years in existing and new facilities to handle mainly cargo growth. The State of South Carolina is additionally investing $700 million in port-related infrastructure. In view of the uncertainty with regard to the availability of Federal harbor deepening appropriations, the State of South Carolina has set aside the entire $300 million cost of our deepening project, both the State and the Federal share. Our deepening project is designed to provide a 50-foot harbor comparable to others already authorized on the east coast, allowing the handling of ships at 48 feet of draft without title restriction,

Going forward, it is vital that a viable strategy and process is established at the Federal level to bring the port capability in line with the handling requirements for such large ships. This is a prime responsibility of the Federal Government, as these are Federal harbors. The process for studying and funding harbor improvements and other restrictive infrastructure issues such as low bridges has neither been timely, predictable, nor well-funded.

The legislative process for approval and funding of major port projects has been—also been made more difficult by the demise of the Federal earmark, which is a traditional source of funding such projects. Accordingly, the funding is woefully short of the requirement and commitment needed to modernize the U.S. port network, and is an impediment to future freight mobility.

Edward Wytkind, President, Transportation Trades Department, AFL–CIO

I am also honored to offer the perspective of transportation workers. Whether they work in the freight rail, port, maritime, aviation, highway, or trucking sectors, they together make up a transportation system for America that works and that delivers for the American people and American businesses. They are also members of the 33-member unions of the Transportation Trades Department, AFL–CIO, that I am the head of.

We all know the facts. No matter which analysis you read, the conclusion is the same. Our infrastructure is falling apart, and the world’s strongest economy is forced to function with an infrastructure that barely cracks the world’s top 25. When channels are too shallow to receive large vessels, or railroads are located miles from ports or the aviation system’s technology improvements are stalled, unnecessary delays and congestions slow our commerce. Those inefficiencies, in turn, choke the economy and impose costs on businesses that, in turn, undermine our competitiveness and job creation efforts.

The surface transportation funding crisis needs to be solved. The Highway Trust Fund is broken, it is facing insolvency by 2015. For 20 years it hasn’t seen its buying power go up, and it is now down 33%. There is a straightforward way to do this. It requires the political leaders in Washington to tell the truth to the American people and to businesses. Unless we increase revenues flowing into this collapsing fund—yes, by raising the gas tax, I said it, I will say it five more times—our highways, bridges, and public transit systems will fail us and our economy will crater.

 

Ms. HAHN. I want to say again how pleased I am that we are talking about the Harbor Maintenance Trust Fund. I just think that is a problem in search of a solution. There is $9 billion that is surplus that is not being used for the intended purposes. And I think we really lose the public’s trust when we continue to ask for taxes, raise taxes, and don’t use them for the intended purpose. L.A./Long Beach, of course, is the donor port in that Harbor Maintenance Tax. We only get .1 percent back of what we give.

I am curious to know if we are moving towards cleaner, greener fleets with FedEx or rail? Are we closer to any kind of real cleaning or electrifying of our trains, our trucks? I know we are not close to having an electric drive system that actually can work for a long haul. But where are we, and should we, as we talk about a national freight policy, should we address this in a proactive way so that any kind of expansions or, you know, more investment in infrastructure projects, we address this at the same time so as not to have a conflict with environmental mitigation?

Mr. SMITH. The easiest and best way to reduce emissions and pollution is making our transportation infrastructure more efficient. Everything that we have talked about today, Next Generation air transportation, corridor improvements, infrastructure funding by increased fuel taxes, as long as that money is spent on infrastructure, it will reduce the number of vehicles or activities, and there will be a commensurate reduction in emissions.

Ms. HAHN. We found that to be true in the Alameda Corridor. We got rid of 200 grade—at-grade crossings. And what started out to be just an efficient way to move cargo turned into being an incredibly environmentally sound project that reduced emissions with cars, of course, waiting at grade separations.

Mr. MOORMAN. There is an enormous amount the rail industry is doing, in terms of reducing emissions. We already have a approximately 3-fold advantage, in terms of fuel efficiency versus the long-distance highway transportation. So we are generally viewed as the cleaner form of transportation.

Mr. LEATHERS. We are experimenting with natural gas, both compressed natural gas and L&G liquefied natural gas. But in both cases it is a very expensive technology.

Mr. NEWSOME. The international and domestic container shipping industry has been on the forefront of environmental efficiency. The very building of large ships is environmentally efficient. We are going to carry more cargo on the same number of ships, accommodating our growth in much more fuel and environmentally efficient ships.

Mr. WYTKIND. And let’s not forget. I know no one has mentioned the word ‘‘public transit’’ in this hearing. If you boost public transit in this country, and you boost it in some of these large, metropolitan areas and give them more resources so they can expand, not have to cut service, like we are seeing around the country, that relieves congestion, that makes more room for freight, and that is good environmental policy, as well.

 

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USA rail policy: goals, objectives, and responsibilities. House hearing 2013

House 113-28. June 27, 2013. National rail policy: Examining goals, objectives, and responsibilities. House of Representatives.

[ Excerpts of the 211 page transcript of the hearing follow ]

Edward R. Hamberger, President and Chief Executive Officer, Association of American Railroads

On behalf of the members of the Association of American Railroads, thank you for the opportunity to discuss issues surrounding the reauthorization of the Passenger Rail Investment and Improvement Act of2008 (PRIIA). AAR freight railroad members, which include the seven large U.S. Class I railroads as well as approximately 170 U.S. short line and regional railroads, account for the vast majority of freight railroad mileage, employees, and traffic in Canada, Mexico, and the United States. Amtrak and several commuter railroads are also members of the AAR. The AAR is presenting this testimony on behalf of its freight railroad members only.

Passenger railroading plays a key role in alleviating highway and airport congestion, decreasing dependence on foreign oil, reducing pollution, and enhancing mobility and safety. All of us want passenger railroads that are safe, efficient, and responsive to the transportation needs of our country.

Meanwhile, America is connected by the most efficient, affordable, and environmentally responsible freight rail system in the world. Whenever Americans grow something, eat something, export something, import something, make something, turn on a light, or get dressed, it’s likely that freight railroads were involved somewhere along the line.

Passenger Rail to Enhance Mobility

Freight railroads are already partners with passenger railroads all across the country.

We should not try to create a world-class high-speed passenger rail system at the expense of our world-class freight rail system.

Capacity issues must be properly addressed. Over the coming decades, population and economic growth will mean sharply higher demand for freight transportation, and railroads are the best way to meet this demand. But if passenger rail impedes freight rail and forces freight that otherwise would move by rail onto the highway, many of the primary reasons for having passenger rail in the first place enhanced mobility, reduced congestion, and environmental benefits would be compromised.

On many corridors, current or expected freight traffic levels usually mean there is no spare capacity for passenger trains. In these cases, new capacity will be needed before passenger trains can operate. New infrastructure built for passenger trains should fully preserve both the ability to operate freight trains as needed and the opportunity to expand further freight service as the need arises in the future, including the ability of the freight railroad to access new customers along the right-of-way. In other words, passenger rail projects cannot “box in” the freight railroad so that new freight customers cannot access the freight railroad. This would limit the ability of the freight railroad to grow and subvert good public policy by potentially forcing this business to go by truck over roads.

Passenger trains use freight railroad assets and property, it is reasonable for the host freight railroad to expect full and fair compensation. Simply put, freight railroads should not be expected to subsidize passenger rail.

Tracks on which passenger trains operate, particularly high-speed trains, must meet different standards requiring significantly higher and more expensive maintenance than tracks on which freight trains operate.

Host freight railroads should be fully compensated for these and any other added costs involved. Moreover, railroads should not be subject to any new local, state, or federal tax liability as a result of a passenger rail project.

Freight railroads want passenger railroads to succeed. We work cooperatively with passenger and commuter railroads to help make this happen, and we support Government efforts to grow passenger rail in ways that complement freight rail growth. As Mr. Szabo has said on more than one occasion, yes, America deserves a world-class passenger rail system, but not if it comes at the expense of what is already the world’s best freight rail system.

As you take a look at re authorization of PRIIA, we have five principles that we think could help guide your considerations.

  • Safety has to take priority over anything else. Under certain conditions, passenger rail can operate on freight rail tracks at more than 79 miles an hour. We believe that more than 79 miles an hour requires a separate track for passenger rail, far enough away so that if there is an accident, it does not foul the adjacent track, having even more tragic consequences.
  • Capacity issues must be properly addressed. Additional passenger train operations should both preserve the ability to operate freight trains as needed today and the opportunity to expand further freight service as our customers require in the future.
  • If passenger trains use freight railroad assets and property, it is reasonable for the freight railroad to expect full and fair compensation.
  • Freight railroads must be adequately protected from liability that would not have resulted but for the added presence of the passenger rail service.
  • There can be no one- size-fits-all approach. Each project involving passenger rail in general or high-speed rail projects in particular has its own unique challenges and circumstances and should be dealt with on a case-by-case basis.

I would like to draw your attention to my written testimony, where we go into great detail on the challenges of implementing positive train control. We join APTA in calling for an extension of the deadline. Our proposal is for at least a 3-year extension plus an additional 2 years at the Secretary’s discretion because of the unknown challenges that are out there. And let me make it very clear. We are not looking for a repeal of this mandate. We are committed. We have spent over $3 billion already. We have thousands of employees working on it. There are challenges as we try to develop the technology, as we try to develop the new radios, as we try to develop and install the equipment on 22,000 locomotives, and over 60,000 miles of track. Much of it will be installed by 2015, but not all.

Freight railroads must be adequately protected from liability that would not have resulted but for the added presence of passenger rail service. It is almost inevitable that some accidents will occur on railroads, despite railroads’ best efforts to prevent them. An accident involving passenger trains which are generally far lighter than freight trains, often travel at much higher speeds, and, most importantly, have passengers on board is far more likely to involve significant casualties than an accident involving only freight trains. Passenger operations also bring more people onto railroad property, resulting in a corresponding increase in risk. These potentially ruinous risks make freight railroads extremely reluctant to allow passenger trains on their tracks without adequate protection from liability.

There can be no one-size-fits-all approach. Each project involving passenger rail on freight-owned tracks in general, and high-speed rail projects in particular, has its own unique challenges and circumstances.

By statute, access fees that Amtrak pays to operate over the freight railroads’ tracks are only required to cover the “incremental” costs associated with Amtrak’s operations that is, the additional costs that arise solely because of Amtrak’s presence. Amtrak is not required to contribute to the freight railroads’ fixed costs or to the shared costs for which Amtrak operations have a responsibility. Consequently, Amtrak’s “track rental fee” is low and is, for all intents and purposes, an indirect subsidy paid by freight railroads to Amtrak. This means that the current structure by which Amtrak “rents” freight tracks should not necessarily serve as a guidepost for the future.

Many segments of the U.S. freight rail system are capacity constrained, such that when an Amtrak delay occurs, substantial freight traffic means that Amtrak trains are often less able to recover lost time. Exacerbating the situation is the fact that a number of Amtrak routes coexist with freight operations not only on single-track corridors, but also on heavily-used, capacity-constrained double-track corridors. This issue will not be going away any time soon: as noted earlier, the long-term forecast is for much higher freight transportation demand. Demand for passenger rail is expected to grow as well. Day-to-day realities of the rail network come into play too. For example, from time to time railroads reduce allowable operating speed for safety reasons when it is warranted by the condition of the tracks. Although these “slow orders” can cause delays for trains of all types, safety must take precedence over everything else. Similarly, railroads must devote sufficient time to needed track and signal maintenance. This often produces unavoidable delays in the short term for freight and passenger trains, but improves service reliability and enhances safety in the long term.

Obviously, Amtrak wants its trains to run on time. Freight railroads understand this and work closely with Amtrak to help make this happen. The key point, though, is that the establishment and measurement of schedules and on- time performance metrics should be undertaken jointly by host freight railroads and Amtrak and governed by private bilateral contracts and the facts and circumstances of particular routes, not by one-size-fits-all legislative mandates. The railroads involved are in the best position to have a clear understanding of the cause of the delays that occur on a particular rail system and how they can be reduced going forward. This kind of shared contract-based responsibility has worked well in the past, enabling Amtrak and freight railroads to better address problems and improve service, which, after all, the ultimate goal. That’s also why railroads oppose legislative provisions that penalize freight railroads for Amtrak delays.

Amtrak Should Be the Entity That Provides Intercity Passenger Rail Service

Due to concerns about Amtrak’s finances and other factors, some have proposed that Amtrak should be replaced by other passenger rail operators on all or part of Amtrak’s current routes and on any new passenger rail routes that may develop. Freight railroads do not support these proposals. Freight railroads would oppose the transfer or franchise of Amtrak’s right of access, preferential access rates, and operating priority to any new non- Amtrak passenger operators. Why? First, the terms and conditions under which Amtrak uses freight-owned tracks were originally negotiated 40 years ago under circumstances that are vastly different from today.

Amtrak has historically enjoyed federal financial support and has proven itself to be a safe and professional operator over four decades. Should Amtrak services be picked up by others, it is unclear what the circumstances would be. For example, private entities may have different degrees of financial backing; public authorities may or may not enjoy the full faith and credit of their sponsoring states; some prospective passenger rail operators may be less committed to safety and sound operating standards than Amtrak; and serious labor issues could arise. Clearly, the status quo would be altered in respects that are impossible to know beforehand, creating huge uncertainties that, frankly, freight railroads do not need. They would rather concentrate on helping the economy grow by meeting the freight transportation needs of their customers.

Moreover, proposals to force freight railroads to grant other passenger carriers access to their tracks under preferential terms and conditions ignores the fundamental fact that freight railroads’ rights-of-way are private, not public. In the absence of voluntary agreement, freight railroads should not be forced to allow passenger operators to use their assets any more than any other private business should be forced to allow another company to use its assets without its consent or at non-compensatory rates. Indeed, forcing freight railroads to convey mandatory access to non-Amtrak passenger operators would create serious constitutional issues. Second, simply put, Amtrak and freight railroads have “grown up” together. Certainly, there have been struggles along the way, as there are in any complex relationship, but the relationship works.

Finally, for decades prior to Amtrak’s creation, our nation’s railroads learned the hard way how difficult it is to recover the full costs of passenger railroading. Although Amtrak was created as a for-profit entity, experience has shown that this is not achievable. No comprehensive passenger system in the world operates today without significant government assistance, and the fact that Amtrak requires public support should not be seen as a primary reason for seeking alternative passenger rail providers.

Positive Train Control

The term “positive train control” (PTC) describes technologies designed to automatically stop or slow a train before certain accidents caused by human error occur. The Rail Safety Improvement Act of 2008 (RSIA) requires passenger railroads and U.S. Class I freight railroads to install PTC by the end of2015 on main lines used to transport passengers or toxic inhalation materials (TIH). Specifically, PTC as mandated by Congress must be designed to prevent train-to-train collisions; derailments caused by excessive speed; unauthorized incursions by trains onto sections of track where maintenance activities are taking place; and the movement of a train through a track switch left in the wrong position. Although PTC was mandated by the RSIA, rather than PRIIA, the issue is of such central concern to the freight and passenger rail industries that I would be remiss if I did not take an opportunity to raise it. Positive train control is an unprecedented technological challenge. A properly functioning, fully interoperable PTC system must be able to determine the precise location, direction, and speed of trains; warn train operators of potential problems; and take immediate action if the operator does not respond to the warning provided by the PTC system. For example, if a train operator fails to begin stopping a train before a stop signal or slowing down for a speed-restricted area, the PTC system would apply the brakes automatically before the train passed the stop signal or entered the speed- restricted area. Such a system requires highly complex technologies able to analyze and incorporate the huge number of variables that affect train operations. A simple example: the length of time it takes to stop a train depends on train speed, terrain, the weight and length of the train, the number and distribution of locomotives and loaded and empty freight cars on the train, and other factors. A PTC system must be able to take all of these factors into account automatically, reliably, and accurately to safely stop the train.

Freight railroads have enlisted massive resources to meet the PTC mandate. They’ve retained more than 2,200 additional signal system personnel to implement PTC, and to date have collectively spent approximately $3 billion of their own funds on PTC development and deployment. Class I freight railroads expect to spend an additional $5 billion before development and installation is complete. Currently, the estimated total cost to freight railroads for PTC development and deployment is around $8 billion, with hundreds of millions of additional dollars needed each year after that to maintain the system.

Despite railroads’ best efforts, due to PTC’s complexity and the enormity of the implementation task and the fact that much of the technology PTC requires simply did not exist when the PTC mandate was passed and has been required to be developed from scratch. Much technological work remains to be done. Railroads also face non-technological barriers to timely PTC implementation. One such challenge that railroads are struggling to overcome right now involves regulatory barriers to the construction of antenna structures. As part of PTC implementation, railroads must install tens of thousands of new antenna structures nationwide to transmit PTC signals. The vast majority of these antenna structures are small and are to be located along railroad rights-of-way. However, the Federal Communications Commission (FCC) maintains that all PTC antenna structures, regardless of their size or location on the right-of-way, are subject to the National Environmental Protection Act (NEPA) and the National Historic Preservation Act (NHPA). The FCC’s current interpretation of its rules implementing these acts would subject every PTC antenna structure to a separate, time-consuming environmental evaluation process. The FCC’s current approval process is unworkable for a deployment on the scale of PTC in the timeframe mandated by the RSIA and FRA’s rules. The railroad industry, the FRA, and the FCC are working to find a solution that will avoid the need for antenna-by-antenna reviews, but for now the installation of antenna structures is on hold. Unless that changes, the timeline for ultimate deployment of PTC will be delayed significantly.

Important PTC regulatory issues are unresolved as well. Current regulations pertaining to PTC implementation impose operational restrictions so severe that the fluidity of the rail network would be drastically impaired. It is important to resolve these issues, and the AAR appreciates that the FRA is considering them in a current rulemaking proceeding.

Reshaping the nation’s transportation system with expanded rail choices will bring significant challenges. One of the key challenges flows from the fact that in many cases intercity passenger rail will share a right-of-way with freight railroads which serve a broad range of customers whose livelihoods and market competitiveness are tied to timely and efficient rail service. Layering additional or expanded intercity passenger rail service or velocity on the freight network can work in many instances if appropriate accommodations for current freight volume and future growth are made. Pursuant to operating agreements with Amtrak, freight railroads currently provide the majority of the right of way and infrastructure necessary to accommodate more than 315 Amtrak passenger trains per day over 43 routes, carrying an average of 78,500 passengers per day. Indeed, 71 percent of the miles traveled by Amtrak trains are on tracks owned by host railroads. Access to freight rights-of-way cannot compromise service to present or future freight rail customers. Advancing high speed or passenger rail at the expense of freight rail’s ability to handle growing freight volumes would be counterproductive public policy, as degradation of current or future freight service would exacerbate highway congestion, reduce fuel efficiencies, reduce U.S. competitiveness and increase greenhouse gas emissions if freight rail were rendered an unattractive transportation alternative to customers. Service to railroad freight customers must be protected and cannot be compromised by high speed or passenger rail route schedules, curfews, or other restrictions that would affect the quality, capacity or reliability of freight service. New infrastructure construction must fully preserve both the ability to operate freight trains as needed and the opportunity to expand future freight service. New infrastructure design must fully protect the host railroad’s ability to serve existing customers, both freight and passenger, and locate future new freight customers on and adjacent to its lines.

AAR’s member railroads have and are negotiating accommodations for passenger and commuter rail service in many areas of the country. To avoid conflicts with existing and future freight rail customers, additional infrastructure, such as additional track, is often a prerequisite. While excess capacity may currently exist in some locations, it is impossible for the railroads to predict where future demand and growth in the nation’s economy will occur. For example, the growth in crude oil transport by rail could not have been foreseen just five years ago. As a consequence, freight railroads are wary of wholesale transfers of their rights of way for commuter or passenger rail service when these are services that would not feasibly be reduced or eliminated in the future.

The Railroad Industry Cannot Install PTC on the Entire Nationwide Network by the 2015 Deadline

Despite the positive developments in 2012 and the railroads spending approximately $2.8 billion to date to install PTC, the year confirmed and increased our understanding of the challenges that remain to completing a nationwide, interoperable PTC system. The most significant are:

Wayside implementation continues to be constrained by the limited number of firms that provide signal design services. The signal system must still be individually redesigned and replaced at more than 7,000 locations before PTC wayside technology can be installed at those locations. Approximately 26,000 WIUs remain to be installed. This work must be accomplished without compromising signal system safety or the ability of the railroads to efficiently move the nation’s freight. Based on current experience and available resources, it is likely that wayside design and installation will extend into 2018. The track database, including critical features such as the presence of signals and switches, must be validated. The railroads must ensure that what is displayed to the train crew via the track database and onboard system reflects what is shown by railroad signals. It is a lime-consuming and labor-intensive process.

Core software delivery dates continue to slip, particularly in connection with the Back Office Server (BOS) for I-ETMS. The railroads do not expect the final release of core software, which is necessary before the PTC system can be lab and field tested, certified, and used in revenue service, until mid-2014.

As the potential for failure of individual components became clear, systems have been designed with more redundancy, thus lengthening the design process.

PTC cannot be rolled out on an entire railroad all at once. Implementation of PTC must occur in phases and location by location, starting with less complex areas and proceeding to the more operationally complex areas, incorporating lessons learned at each step.

The reasons described in the ISP, tens of thousands of miles of existing signal system infrastructure still need to be replaced. As discussed previously, each of the approximately 12,300 replacement projects is complicated and lengthy, requiring individual analysis and design and signal replacements or upgrades before the WIU’s can be installed at these locations.7 Qualified signal personnel are needed for design, installation, and validation, both in the lab and in the field. The limited number of qualified signal design firms and personnel available to the railroad industry continues to constrain how quickly railroads can complete the design, upgrade, installation, and testing required for PTC signal projects. The railroads have hired over 2,200 signal personnel specifically for PTC8 However, the great majority of these new hires provide assistance only with the installation of PTC at wayside locations, not with the more complicated analysis and design work that is typically handled by established signal design firms. Personnel hired for installation work are, of course, limited to performing work at locations where designs have been completed. Product availability has improved, although it continues to be a concern along with the extensive lab and field testing required for these products.

One of the key challenges that has emerged is deploying a national 220 MHz communications network for PTC that includes adequate coordination between railroads to avoid interference< Various tools are being developed to help mitigate interference, but this will continue to be a substantial task.

Mr. SZABO. If you take a look at our budget submission, our mission is to ensure the safe, reliable and efficient movement of people and goods. When you start taking a look at the state of our transportation network today, the congestion costs in loss of productivity that our transportation network is already facing, and then when you take a look at the decades of underinvestment in rail, combine that with the efficiencies that rail can generate in moving people and goods, the enhanced productivity, the enhanced safety, the improved environmental sustainability that the rail offers, we believe that our budget proposal is not only realistic, but certainly appropriate, that it is time that we truly put rail on parity with the other transportation modes, that we no longer treat it like a forgotten stepchild. And because of these decades of underinvestment, there is clearly this need to advance the vision forward of real commitment of dollars and a reliable and sustainable funding pool out of a rail account in the trust fund.

Going back to our budget, you will notice that we talk about the need for grants for freight rail infrastructure improvements, and short lines would clearly be eligible here. What we have found is that so often, there are short lines that are desperate for capital, but they cannot qualify for a loan. And we believe, in these cases, particularly for safety enhancements, bridges, track improvements, that grants would be a more appropriate tool.

I think the biggest thing that we have to ensure moving forward, and this is not just from a rail standpoint, but from all of our infrastructure, is that we are now designing resiliency as well as potential recovery into the design of all transportation projects. In my mind, there is just no question that weather patterns are going to continue to become more and more uncertain and more and more severe, and so we have to have redundancy as well as resiliency built into our transportation network.

Mr. Mica. The losses are getting worse rather than better. So here for the record Mr. Chairman, I submit all these money losers:

AMTRAK California Zephyr Southwest Chief Sunset Limited East
Route Chicago to Oakland Chicago to Los Angeles New Orleans to Los Angeles
Loss per passenger

(2011)

 

$166

 

$178

 

$375

Loss Per Passenger

(2012)

 

$182

 

$183

 

$404

Amtrak Price

(coach seat)

 

$250

 

$324

 

$201

Travel time 52.2 hours 43.3 hours 47.6 hours
AIRPLANE ORD-SFO Nonstop ORD-LAX Nonstop MSY-LAX Nonstop
Cost $197 $192 $240
Travel Time 4.5 hours 4.3 hours 4.2 hours
Greyhound BUS    
Cost $228 $229 $214
Travel Time 50.0 hours 46.5 hours 45.1 hours

 

JOSEPH C. SZABO, ADMINISTRATOR, FEDERAL RAILROAD ADMINISTRATION

The Passenger Rail Investment and Improvement Act and the Rail Safety Improvement Act, both passed in 2008, were bipartisan game-changing pieces of legislation. 2012 was the safest year in railroading history. Amtrak’s on-time performance, its ridership and its revenues are now at all-time highs, and the freight rail industry has never been stronger. Today, 6,000 corridor miles are being improved, 40 stations are being upgraded, hundreds of new passenger cars and locomotives are being procured, and States are competing—or completing more than 100 different environmental, engineering and planning projects, but we still have a long way to go to make up for decades of underinvestment in rail and be ready for the challenges ahead.

Soon America’s transportation network will need to move 100 million additional people and 4 billion more tons of freight annually,

Our airports and highways are stretched to their limits.

Congestion costs our economy more than $120 billion per year. Rail is the clear mode of opportunity. It is extremely safe, cost-effective and the least oil-reliant, most environmentally friendly mode to move people and freight.

In just 10 years, Amtrak’s ridership is up more than 40% and growing faster than any other mode of travel. Our vision is for a National High-Performance Rail System that builds on today’s progress, enhancing the Nation’s rail system by addressing safety concerns, by providing funding for passenger and freight rail improvements and by promoting strong planning. Our vision is a state of good repair for Amtrak, improving safety, efficiency and reliability. With your support, we can develop new passenger rail services and substantially upgrade existing corridors, and we can fund freight rail projects critical to our Nation’s economic competitiveness.

The Passenger Rail Investment and Improvement Act of2008 (PRIIA)

Improved Financial Accounting: Section 203 required the Amtrak Board to implement a modem financial accounting and reporting system within three years of enactment. The Department of Transportation Inspector General (IG) reviewed the system and found in a March 23 report that Amtrak is better able to capture its financial performance by route, line of business, and major activity, as PRIIA requires. However, the IG also found that since Amtrak customized the system rather than using an off-the-shelf system, the system is more complex and costly to maintain, raising concerns regarding its long- term utility. The IG also found that Amtrak’s heavy reliance on cost allocation reduces the precision of performance reporting. While many companies use cost allocation to an extent, Amtrak allocates (rather than assigns) 80 percent of its costs because it does not collect sufficiently detailed cost data. For example, Amtrak does not measure and record each train journey’s fuel consumption, but rather relies on a formula that estimates a joumey’s fuel consumption.

Ms. BROWN. There has been a lot of talk in the press about eliminating long-distance routes. I strongly oppose that. These routes literally connect our east coast to our west coast. They are what make Amtrak a national railroad. Without the long-distance train, over 4 million people in 23 States and 223 communities will lose all passenger rail service.

Michael P. Lewis, Director, Rhode Island Department of Transportation, testifying for AASHTO

Association of State Highway and Transportation Officials position on national rail policy has evolved through many years of State experience with delivering passenger rail service and working with and supporting large and small freight railroads. Dating back to AASHTO’s 2002 Freight Rail Bottom Line Report, we have highlighted public-private partnerships as a model for investment in freight rail projects. Rail must be a part of a balance of transportation—a balanced mix of transportation alternatives available to our Nation’s freight trippers and the traveling public. Making increased levels of investment and realizing the public benefits of a strong freight rail system will require partnerships among the railroads, the States and the Federal Government. The Heartland Corridor and the National Gateway Corridor are major intermodal connector projects resulting from shifting patterns of freight demand. These and similar projects make it clear that we must constantly adapt to changing global economics and logistics and that rail is an essential element of our overall national transportation system. Continued Federal investment is essential. Without it, the resulting—an increased reliance on the highway system would greatly increase highway congestion and maintenance costs, driving up overall costs of goods movements in the U.S.

John P. Tolman, VP & National Legislative Rep, Brotherhood of Locomotive Engineers and Trainmen

On behalf of the 37,000 active Brotherhood of Locomotive Engineers and Trainmen members and over 70,000 rail conference members, I want to thank the committee. In order for our Nation to meet the economic and environmental challenges that we face, we must continue to invest in the infrastructure and to develop and plan for new means to get goods and people from place to place in the most fuel-efficient means possible. Rail clearly is the best means of doing this.

On the passenger side, Amtrak and the intercity commuter railroads and their employees have the knowledge, skills and abilities to develop, implement and grow passenger rail systems throughout this country. They have done great work and continue to set record riderships across the country. Passenger rail is a great example of the old quote in the ‘‘Field of Dreams’’: ‘‘If you build it, they will come.’’ On the Amtrak side, this cycle of underfunding must end. They desperately need long-term funding and predictability.

On the freight side and for its professional skilled railroad employees, intermodal freight transportation is the way of the future, with goods moving from ship to truck to train on a seamless network. To continue this, we need to ensure that we continue to invest in our infrastructure. Unfortunately, the House Appropriations spending leaves TIGER grants out entirely; it also tries to cut this year’s awards in half by rescinding $237 million before the DOT can get the already awarded grants out the door. Railroads have improved their fuel efficiency by 23 percent in the last two decades. As stated by Ed Hamberger, the freight side in the industry is investing billions annually in its infrastructure and is well positioned to handle any additional freight that comes its way, but we must also ensure that continued investments are not only to expand the capacity but also to improve safety.

MICHAEL P. MELANIPHY, PRESIDENT, AMERICAN PUBLIC TRANSPORTATION ASSOCIATION

The initial conservative estimate for PTC implementation on commuter railroads was more than $2 billion, with more than 4,000 locomotives and passenger cars with control cabs and 8,500 track miles to be equipped. Since this initial estimate, as commuter railroads have begun their contracting and technology acquisitions, the estimated costs of implementation have risen well beyond the initial $2 billion estimate. These estimates do not include costs related to the acquisition and operation of the radio spectrum necessary to meet the interoperability requirements set forth under RSIA and they do not include costs associated with operating PTC systems. To date, Congress has only appropriated $50 million of the total authorized amount. At a time when critical State of Good Repair backlogs are creeping above nearly $80 BILLION on our nation’s public transportation systems, commuter railroads are being forced to choose between performing critical system safety maintenance projects and implementing PTC by 2015. Insufficient funding is a significant impediment to implementation for publicly funded railroads.

 

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