Tom Ewing’s Environmental Update

*  Peer review?  Federal Highway is proposing to formally add a value engineering (VE) requirement to big-ticket projects in which the feds are
significant contributors.  VE is a systematic review and analysis during a project’s concept and design phases by a multi-discipline team of persons not involved in the project.  Project managers would undertake VE to get recommendations and ideas that assure project functions – safety, reliability, efficiency – are delivered at the lowest overall cost.  VE would be required for National Highway System projects receiving Federal assistance with an estimated cost north of $50 million.  For bridge projects, that cost is $40 million.  FHWA started this process last week, requesting the Office of Management and Budget to approve this “new information collection.”  Public comments are due April 30.

*  GM and Toyota asked EPA to approve off-cycle carbon dioxide (CO2) credits allowed under EPA’s light-duty vehicle greenhouse gas emissions
standards.  ‘‘Off-cycle’’ emission reductions can be achieved by “employing technologies that result in real-world benefits, but where that benefit is not adequately captured on the test procedures used by manufacturers to demonstrate compliance with emission standards.”  EPA’s light-duty vehicle greenhouse gas program may recognize these benefits and automakers have several options for generating “off-cycle” CO2 credits.  First, however, the companies have to provide EPA with a methodology that documents the benefits, which EPA must approve.

*  Gordon van Welie, president and CEO of ISO New England, spoke to the press last week during the ISO’s annual press briefing.  Van Welie said
New England’s power grid “continues to operate reliably and competitive markets are working, but significant challenges are on the horizon.”  This is a complex (maybe ‘perfect storm’) set of issues.  As more oil, coal and nuclear plants retire in the coming years, keeping the lights on becomes more tenuous. To avoid greater reliability risks, van Welie said: “we soon may need to make sure replacement energy from new resources will be online before non-gas resources can be allowed to retire.”  That’s going to be difficult.  This is not just “drop-in fuels.”  Reliability is more than just substituting electrons.  And if you take a look at the project approval queue there aren’t many renewable generation projects, at scale, ready to go.  Critically, of the projects that are proposed, the ISO reports that “historically, about 68% of the megawatts proposed are never built.”

Tom Ewing
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