The Case of the Missing 40 MMT/year of California Electricity Sector Emissions

The coal train needed to generate those emissions would be 1,159 miles long.

           

Would you be surprised to learn that the California Energy Commission (CEC) supplied deceptive statewide generation mix information for 2021 and 2022? This generation mix information exaggerated that amount of lower-emission natural gas fired generation and understated by about 40 million metric tons (MMT) the annual amount of highly-polluting mostly out-of-state coal-fired generation hiding behind a California-specific legal euphemism (unspecified power.)

            How long would the coal train need to be to produce 40 MMT?  CGNP's calculations show it would be about 1,159 miles long.

Here's a map showing the great-circle distance across the Earth's spherical surface between Washington, DC and Dallas, Texas would be 1,183 miles. The hypothetical coal train would span that distance less 24 miles.  (Map courtesy distancefromto.net.)

            Here is the summary data from the pair of CEC spreadsheets. CGNP calculated the emissions associated with the calculated claimed and actual statewide data for both natural gas and unspecified power for 2021 and 2022. CEC only reported this data as percentages of the power in Megawatt-hours (MWh) shown in the left-hand column of each row of the CEC spreadsheets for 2021 and 2022.

The yellow highlighted cells show about 40 MMT of California power sector emissions was missing in each of the statewide 2022 and 2021 totals. The cause was a careful under-reporting of unspecified power production by the CEC. CGNP calculated the total production in the first column by taking the product of the statewide power production for each year and the CEC's reported statewide percentages. Power production differences show over-reporting for lower-emission natural gas-fired production and under-reporting for the pollution-laden unspecified power. Please note the units of the rightmost column are MMT. The above spreadsheet is here. Emissions factors for natural gas and coal are from the U.S. EIA, with source information in the CEC correspondence link found near the end of this article.

What's going on here?

            The State of California, much like Germany, supplies deceptive statistics to exaggerate how pollution-free their power sectors are. CGNP highlighted how the California Public Utilities Commission (CPUC) artificially set the criteria pollution levels for unspecified power to zero in a 2022 procurement decision. Germany recently manipulated the information from its own ministries to falsely arrive at the conclusion that the three remaining nuclear power plants should be shut down on April 15, 2023 despite the Russian invasion of Ukraine on February 24, 2022 - and the subsequent reduction of Russian natural gas to Germany. The original misleading narrative supplied by the State of California to Diablo Canyon Power Plant (DCPP) owner Pacific Gas & Electric was that DCPP's power would not be needed after 2025. Just as in the case of Germany, it is impossible that weather-dependent  and time-of-day dependent solar and wind power will ever replace 24/7 reliable dispatchable power for California, the world's 4th largest economy. (Nuclear power opponents proffer the expansion of battery power as a replacement for DCPP's power. Battery power is not cost-effective at the required scale. Furthermore, battery power does not supply necessary synchronous grid inertia [SGI].)

            Opponents of DCPP's reliable power will force California to rely on mostly Wyoming coal-fired power if DCPP is needlessly shut down. PacifiCorp's power sales will likely increase by almost $2 billion per year if DCPP is shut down. The coal-fired power would supply both the necessary power capacity (MWh) and SGI (MVAR.)   (Germany relies mostly on its coal-fired power plants to supply the power capacity and SGI that were previously supplied by its nuclear generation fleet.)

            CGNP has highlighted since 2017 the aggressive California lobbying of Berkshire Hathaway Energy (BHE) subsidiary PacifiCorp in our regulatory filings and our public outreach. CGNP believes that PacifiCorp recently economically retaliated against CGNP. We would not be surprised if PacifiCorp's direct CPUC lobbying expenditures in excess of $2.5 million between 2019-2023 were influential in the CPUC departing from legislative mandates and precedent in completely denying CGNP's intervenor compensation request of more than $153,000 in a December 8, 2023 Proposed Decision that was ratified about a month later, despite CGNP's vigorous objections. Furthermore, this peculiar CEC distortion of California's power sector emissions that CGNP discovered on the second row of each of the pair of spreadsheets could be a consequence of the millions that PacifiCorp has expended on general California lobbying since 2019.

Spreadsheet details

            CGNP began with the CEC-supplied spreadsheets for 2022 and 2021. We calculated the products of the left-hand entries in each row with the selected percentages to determine the megawatt-hour (MWh) values. (1 MWh = 1,000 kilowatt-hours.) CGNP's MWh values are shown in grey-tinted columns. The excerpt from the 2022 spreadsheet shows partial new columns for "Eligible Renewables (TOTAL) MWh" and "Coal MWh."

            CGNP's complete power content label (PCL) 2022 spreadsheet is shown here and the complete PCL 2021 spreadsheet is shown here.  CGNP verified the total MWh for the 158 utilities shown matches the total shown in each CEC spreadsheet. Furthermore, CGNP verified that the totals for each energy source for the 158 utilities are almost exactly equal to the statewide total retail sales for each year.

            The key deceptive statistics in the second row for statewide natural gas-fired generation and unspecified power generation were highlighted in the first part of this article. The fact that the statewide totals for all the energy sources on line 2 almost exactly match the statewide total retail sales are consistent with the perspective that these are intentionally manipulated statistics.

            Here are some remarkably-candid PacifiCorp 2022 emissions intensity statistics excerpted from the CEC spreadsheet.

PacifiCorp's emissions are far in excess of the 1,000 lbs CO2e/MWh performance standard set by SB 1368 (Perata, 2006.)  On the other hand, by virtue of PG&E's use of DCPP, PG&E's emissions are a tiny fraction of PacifiCorp's. PG&E offers some of the cleanest power in the U.S.

            CGNP has been in communication with the CEC regarding these important matters for several weeks. As is apparent from this article, we have reason to remain skeptical. We have intentionally copied state and federal political leaders in our communications.  As of July 15, 2024, this is the record of those communications. When the CEC replies to our concerns, we will post their response. Allegedly, this reply will occur during the week of July 15, 2024.

Final notes

            In the 133 days since CGNP posted its first GreenNUKE Substack article regarding the importance of SGI, we have obtained 300 subscribers. We wish to continue our investigative reporting. We would appreciate more subscribers and more paid subscribers. We have several new investigative stories that we are working on.  Finally, a big "Thank you" to our paid subscribers!

CGNP looks forward with anticipation to your assistance.