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Emissions from Distributed Generation Sources Can DG Be Regulated to Ensure It is Efficiently and Cleanly Integrated Into Our Energy System? Julie Scanlon Chicago-Kent College of Law Energy Law, Spring 2004 Professor Fred Bosselman Imagine If We Had Known About This.

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Emissions from Distributed Generation SourcesCan DG Be Regulated to Ensure It is Efficiently and Cleanly Integrated Into Our Energy System?Julie ScanlonChicago-Kent College of Law

Energy Law, Spring 2004

Professor Fred

this is what dg is
This Is What DG Is
  • Small Power Generators
  • Installed at, Or Near, the Power Consumer’s Location
you would find dg most often
You Would Find DG Most Often
  • In Settings That Require Reliability In Their Electric Supply
  • Hospitals for Example
  • In high tech settings
and possibly
And Possibly…
  • In Your Own Backyard
so who might own a dg unit
So Who Might Own A DG Unit?
  • You Could
  • A Business Could
  • Or a Utility Could
greatest benefits of dg
Greatest Benefits of DG:
  • Flexibility in Use and Location
    • Modular
    • Continuous or Back-up Generation
  • High Reliability Applications
  • Source of Emergency Capacity
  • Meet Demand Spikes at Peak Hours and Seasons
  • Defer Large Capital Investment in Large Generation Facilities
  • Increase Domestic Energy Security
why should you care about regulating dg emissions
Why Should You Care About Regulating DG Emissions?
  • Because this is becoming a part of our energy system and if it is not regulated correctly it could wind up DIRTY
dg is already impacting energy use patterns
DG Is Already Impacting Energy Use Patterns
  • DG is Already Part of Our Energy System
  • 25% of Top Energy Intensive Industries Exploring DG in 2000
  • Called The “Holy Grail” of New Energy Tech in Public Utilities Reports
these are the sources that require regulation
These Are The Sources That Require Regulation
  • Sources Not Already Regulated or Not Regulated Consistently Under State or Federal Law
    • Generators Under 1 MW Generally Go Unregulated
    • Typically On-site Applications are not Regulated

1 kilowatt = 1,000 watts1 megawatt = 1 million watts or 1,000 kilowattsKilowatt-hour = unit of energy equivalent to the power of 1 kilowatt working for an hour and the rate at which we pay for our energy.

a typical coal burning power station produces about 1 gigawatt or 1000 megawatts of power
A typical coal-burning power station produces about 1 gigawatt or 1000 megawatts of power.
contrasted with
The Siemens Solid Oxide Generator Generates 220kw, or 220,000 watts ~ about ¼ of a megawatt

The Natural Gas Microturbine at UIC Generates 30kw, or 30,000 watts ~ about 1/30 of a megawatt

Contrasted With
what dg should be regulated most closely
What DG Should Be Regulated Most Closely?
  • Microturbines and Reciprocating Engines Powered By
    • Fossil Fuels – Diesel and Natural Gas
Because:Diesel and Natural Gas Turbines Account for The Lion’s ShareOf Generation andEmissions From DG
especially bugs
Especially BUGS !!
  • BUGS are Back-up Generation Systems that are Usually Diesel Powered
  • Diesel Generators emit more than 110 times the NOx and PM than the cleanest large scale generator, a combined cycle
goals of regulation
Goals of Regulation
  • Prevent DG from being installed where it ought not to be
    • Siting and Displacement Issues
  • And in a form it ought not to be, DIESEL BUGS for example
  • Encourage clean and efficient wind, solar, cell, and combined heat and power (CHP)
models of regulation who and how
Models of RegulationWho and How?
  • Federal v. State
  • Input Based v. Output Based
  • Industry Written v. Government v. Other Stakeholders
federally regulated
Federally Regulated
  • Advantages
    • Uniformity
      • Aids R&D
      • Lowers Compliance Costs for Consumers and Manufacturers
      • Easier to Enforce
  • Disadvantages
    • Lack of Flexibility
      • Hinders Experimentation
state by state
State by State
  • Advantages
    • Flexibility in Implementation
  • Disadvantages
    • Lack of Uniformity
input v output
Input Measures Emissions Based on Heat Energy In

Lb of pollutant/BTu fuel input

Output Measures Emissions Based on the Energy Produced

Lb of pollutant/MWh energy output

Input v. Output
input v output1
Input v. Output

Input standards measure emissions by fuel input into the plant:

Example: for every unit of fuel input, two units of pollutant are allowed. This disregards the amount of energy created by the amount of fuel input. One plant may create two units of energy from one unit of fuel, while a less efficient plant would only create one.

Output standards measure emissions by the units of energy produced:

Example: for every unit of energy produced, a unit of pollution may be emitted. The consequence being that a less efficient plant would require more fuel to create the same amount of energy, and more pollution control equipment to assure the plant complied with the output standard.

who writes the standards what concerns do they protect
Who Writes the Standards?What Concerns do they Protect?
  • Industry
    • Costs $$$
  • Government
    • Ideally Government should protect industry, consumers, and others impacted by emissions and siting issues
  • Other Stakeholders
    • Consumers and others impacted
mobile source standards a model for regulation of dg
Mobile Source Standards- A Model For Regulation of DG?
  • Automobiles
    • There are some parallels – multiple sources, sometimes individually or privately owned
    • There are some differences – primarily the psychological factors
dg may not replace cars as the mid life crisis toy of choice
DG May Not Replace Cars as the Mid-life Crisis Toy of Choice
  • But, there are some shared factors motivating purchase
  • Fear and insecurity might drive the need for bigger and dirtier DG – as they do for larger vehicles
  • Fear of the unreliability of the network
  • Concern about rising electricity rates
  • Likely blackouts during summer peaks
  • Increasing cost of IT disruptions
auto regs are set by the federal government
Auto Regs Are Set By The Federal Government
  • They are technology forcing, but with lead time to allow for Research & Development Cycles
  • They are output based – Grams of Pollutant/Miles Driven
  • A uniform standard, with a 2nd more stringent standard available
    • The California Emissions Standard
  • Successful in lowering emissions and raising mpg
however there s a loophole so big you can drive through it
HOWEVER, There’s A Loophole So Big You Can Drive Through It
  • Different emissions standards for light duty and heavy duty vehicles have allowed for

SUVs to emit more pollutants and use fuel less efficiently than they could

    • Allowing higher emissions standards and lower fuel efficiency requirements meant for working vehicles to be applied to family-owned vehicles
model rule for dg emissions regulation
Model Rule for DG Emissions Regulation
  • Written by the Regulatory Assistance Project (RAP) and Stakeholder Groups
    • State Utility and Environmental Regulators
    • Industry representatives
    • Environmental advocates
    • Federal officials




Phase 1 Reasonably Achievable

Phases 2 & 3 More Protective


One Standard for All DG





regulations already in effect
Regulations Already in Effect
  • California
  • Texas
  • Japan
  • The Netherlands
  • Great Britain
  • Output Based /Multi-Pollutant
    • NOx, CO, CO2, VOCs, PM
  • Two Step Phase In
  • Technology Review Half-Way In
    • To assure final phase goals may be attained
    • To make the final phase more protective if the capability exists
  • Credit for CHP
  • BUT no BUGS Regulation
  • Output based for NOx –
    • Standard written for non attainment and attainment
  • For facilities under 10 MW
  • Phased in over 4 Years
  • Credit for CHP
japan netherlands eu
Japan, Netherlands, EU
  • All output based and provide credit for efficient cogeneration and thermal output.
  • The Failure to Regulate BUGS
  • The Difficulty of Siting
  • Costs of Monitoring Widely Dispersed Generators- (Answers? Certification or CEM)

Siting- The Where It Should Be Component

  • Over-regulation could put a serious limitation on distributed generation in areas where emissions are rigorously controlled, even where DG could affect a substantial reduction in emissions compared to the generation it would displace
  • Other concerns are health effects on those around DG sites – this isn’t dispersed, as stack emissions are- and effects are felt close to the source
if i was writing the rule what would i include
If I Was Writing The Rule, What Would I Include
  • Uniform to Aid R&D, Lower Compliance Costs, and Lower Costs for Consumers
  • One, technology and fuel neutral, output based standard

Standards that recognize the environmental benefits of efficiency

  • Multi-pollutant
  • Credit for thermal uses and co-generation
  • DG emissions must not go unchecked, this needs to be addressed now
  • Develop comprehensive plan/modeling for siting
    • Hours of operation
    • What facilities are being displaced by DG
  • Federally regulated in recognition of the transboundary nature of pollutants