Ms. Sarah Yeager
City of Pittsburgh
Department of City Planning
200 Ross Street
Pittsburgh, PA 15219
October 6, 2017
Dear Ms. Yeager,
On behalf of the Pennsylvania Environmental Council (PEC), I am writing to provide comments on the draft Pittsburgh Climate Action Plan, v 3.0. We appreciate the opportunity to participate in this process and commend the City of Pittsburgh for its leadership on this issue. Due to the quick turnaround time, I have focused my comments on the Energy Generation and Distribution chapter, for which I participated in the planning meetings.
We perceive the greatest value of the Pittsburgh Climate Action Plan to be establishing an overarching climate goal, to which the activities of not only municipal government but also businesses, universities, non-profit organizations, and community groups can contribute. We support the addition of sector-specific goals for each chapter, which is a change from previous plans. However, we question the appropriateness of the energy generation and distribution chapter goal, as discussed below.
We also believe the quality of recommendations will be more important than the quantity. We strongly encourage you to tighten the scope of this chapter to focus specifically on those activities that will result in the most significant reductions of greenhouse gases (GHGs) from energy generation and distribution. We understand the desire to be as comprehensive as possible, but fear the number of unconnected activities listed distracts from the overall goal and can be confusing, particularly to community partners not well-versed in the technical content. We suggest including an appendix of “Current and Planned Activities” as a more appropriate way to include some of the content in this draft chapter, rather than within the chapter itself.
Our other specific comments, listed by page number, are as follows:
Renewable Energy Goal
This chapter sets forth a goal of “100% renewable energy.” However, it is not clear how the actions listed will achieve this goal. Rather, the actions all have the common theme of
reducing GHG emissions from the energy sector. We recognize the importance of an easy-to-understand, concise goal that resonates with the general public. However, the substance of the goal is just as important.
Perhaps a more appropriate goal would be a target percentage reduction of GHG emissions from the energy sector, allowing for the participation of many types of projects, rather than limiting the City to a specific energy type. Or, an alternative way of phrasing this goal could be 100% clean energy, with “clean” defined as carbon-free. A visionary, 100% goal could be the public-facing message, with a working goal of reducing energy generation and distribution emissions by 80%.
To expand further on our above point, we are concerned that 100% renewable energy may not be the most prudent path to achieving deep reductions in GHG emissions, based on PEC’s comprehensive review of the most recent literature on deep decarbonization. (See Jenkins and Thernstrom, 2017[i]; Sivaram and Kann, 2016[ii]; or Trabish, 2017[iii].) Relying too much on renewable energy alone to achieve deep carbon reductions raises several challenges. These are discussed in greater detail in PEC’s June 2017 report Achieving Deep Carbon Reductions: Paths for Pennsylvania’s Electricity Future[iv].
Finally, throughout the document, the term “renewable energy” seems to be used when the terms “electricity” or “power” might be more accurate. If the goal is truly 100% renewable energy, this would also include heating and transportation fuels. Further, it would not make sense to invest in district energy systems that utilize fossil fuels, as recommended in this chapter. This concept is discussed in greater detail below.
Electricity rate decoupling is a recommended action. While we are supportive of efforts to eliminate the so-called “throughput incentive,” we recommend re-phrasing the action to be “support alternative ratemaking” or similar language. Decoupling is one potential mechanism for achieving this objective but there may be alternative ways of achieving these same goals. Legislation currently under consideration in the Pennsylvania House of Representatives (House Bill 1782; P.N. 2418) seeks to allow for alternative ratemaking utilizing decoupling; performance-based rates; formula rates; multiyear rate plans; cost-recovery mechanisms; rates to support and fully recover the allocated costs to deploy infrastructure and distributed energy resources; or rates based on a combination of these approaches. We recommend you do not limit efforts to decoupling alone. Further, we suggest expanding the recommendation to also apply these mechanisms to natural gas utilities, rather than limiting to electricity distribution companies only.
Water and Sewer Targets
PEC fully appreciates the importance of addressing sewer infrastructure and stormwater management challenges. In fact, we have staff across the Commonwealth who work on these issues. However, because the document under review is a climate action plan, we are using the ability to reduce GHG emissions as a lens to assess and prioritize actions.
While the recommended actions under Objective #4 are important sustainability actions, it is less clear to what extent they will address GHG emissions, helping to prevent further climate change. We strongly encourage the City to keep its focus in this document on those actions most likely to result in significant GHG emissions reductions. Further, if some actions are already being addressed through other sustainability initiatives or plans, we recommend leaving those out of this plan, unless explicitly related to emissions reductions.
Renewable Resource Authority
We recommend that the authority to be created be an “Energy Authority,” rather than an authority explicitly related to renewables. This will allow the Authority to achieve multiple energy goals, as the needs of the city and its residents evolve and change over time, rather than being narrowly focused on renewable energy alone.
Sankey Diagram Description
In the discussion of the Energy for Power of 32 region Sankey diagram, the amount of wasted energy is incorrectly reported as 63%, rather than 41%[v]. This paragraph could be re-written for greater clarity. For instance, the last sentence of the first paragraph (“Energy that is exported out of the region and the use of petroleum for transportation also contribute to energy waste”) is confusing and its meaning is unclear.
Additionally, in both the first and second paragraphs on this page, it is stated that approximately 9% of electricity is lost in transmission. However, it goes on to say that for each kilowatt-hour (kWh) used in Pittsburgh, 0.0582 kWh is lost in transmission. This figure (0.0582 kWh) would be equal to 5-6% loss. We strongly recommend re-writing this section for greater clarity, particularly to make it more accessible to non-energy professionals.
In the first paragraph under “District Energy,” there is a footnote/endnote reference for the statement that 60% of energy can be lost in transmission, but there does not appear to be a corresponding footnote/endnote in the document to provide a citation for this fact. While this is a simple formatting error that will undoubtedly be fixed in subsequent revisions, we question the accuracy of this number. This number seems very high for losses through transmission alone, particularly when the P32 assessment found losses across the entire system to be 41%.
While district energy systems can lead to GHG emissions reductions, the devil is in the details as to whether those will be modest or significant reductions. We urge you to add more detail to this section as to what features a district energy system should include in order to achieve the greatest reductions possible. For example, all district energy heating systems should be combine heat and power (CHP) to produce twice as much output from the fuel used, as compared to heat alone.
Further, as mentioned in our earlier comments, a district energy system that is utilizing fossil fuels, such as the Duquesne University CHP plant mentioned in the Plan, will never achieve zero emissions unless it is equipped with carbon capture and storage, or converted to a zero emissions fuel product (if/when one is commercially available). District energy projects built today represent 30-50 year investments (or longer). Therefore, projects built to utilize natural gas are locking us into fossil fuel use for at least that long. This is hard to justify in a climate action plan, especially in light of the recommendation of the Intergovernmental Panel on Climate Change to reduce emissions by at least 80% by mid-century, a mere 33 years from now.
Also, the encouragement of district energy projects that utilize natural gas for CHP are not compatible with the stated goal of 100% renewable energy. We reiterate our recommendation to make the ultimate goal one of reducing emissions, rather than marrying your efforts to one energy source, and/or clarifying the difference between power and all energy use.
There is mention of direct current not being ideal for long distance transmission. While long distance transmission is outside of the scope of this plan, we recommend re-writing this sentence to clarify that high voltage direct current (HVDC) transmission lines are a promising technology that are included in several deep decarbonization strategies to allow for transmission of renewable energy from areas of significant generation to load centers.
While EcoDistricts are a promising community sustainability tool which PEC supports, this full-page description does not include any mention of energy generation and distribution. We recommend this section be re-written to focus explicitly on the aspects of EcoDistricts that contribute to reduced GHG emissions in the energy generation and distribution sector, or left out of this chapter completely.
Western Pennsylvania Energy Consortium
To reiterate our earlier comments, we would encourage you to specify that the City intends to purchase 100% renewable power, rather than energy, which would also include heating and transportation fuels.
Local Renewable Energy
In the final sentence of this paragraph, we would encourage you to expand the potential renewable energy sources to include all economically viable sources available to you, rather than limiting to solar and wind only. Other sources could potentially include hydropower, biomass, or hydrogen fuel cells.
We would also caution you not to lump CHP into your definition of renewable energy unless specifying that the fuel source is a renewable one, as compared to natural gas or other fossil fuels in use in most CHP projects currently.
We are supportive of the exploration of anaerobic digestion as a form of renewable energy in this region. Our only suggested change to this section is to revise the methane potency figures. While the global warming potential of methane is 25 times that of carbon dioxide over its lifetime, it is 84 times more potent over its first 20 years in the atmosphere (as correctly stated on page 29).
The Pittsburgh Climate Action Plan, v. 3.0, when complete, will serve as an important guiding document for action by not only the municipal government but also businesses, non-profit organizations, and community groups. We believe the urgency of climate change necessitates a plan that leads to action, rather than one that establishes a vision. A strong, defensible goal with actions that clearly contribute its attainment will make this a useful, implementable plan.
In closing, I would like to reiterate our appreciation of your leadership on this issue and to offer our assistance as you continue to revise and review the plan. Please do not hesitate to contact me at 412-481-9400 or email@example.com if I can support your continued efforts to revise and finalize this plan.
Program Manager, Energy and Climate
Cc: Grant Ervin, Chief Resiliency Officer
[i] Jesse D. Jenkins and Samuel Thernstrom, Deep Decarbonization of the Electric Power Sector: Insights from Recent Literature, Energy innovation Reform Project, Mar. 2017, http://innovationreform.org/wp-content/uploads/2017/03/EIRP-Deep-Decarb-Lit-Review-Jenkins-Thernstrom-March-2017.pdf
[ii] Varun Sivaram and Shayle Kann, Solar power needs a more ambitious cost target, Nature, April 7, 2016, https://www.nature.com/articles/nenergy201636.epdf
[iii] Herman K. Trabish, “Is 100% renewable energy the best goal to cut power sector emissions?” Utility Dive, Mar. 20, 2017, http://www.utilitydive.com/news/is-100-renewable-energy-the-best-goal-to-cut-power-sector-emissions/438401/
[v] “Executive Summary.” Energy Baseline for the Power of 32 Region.http://www.energy4p32.org/RegionalEnergyBaselineforP32vExecSumm2.pdf
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