Category Archives: Insights and Advice

Using my experience as a consultant involved in various Department of Energy (DOE) processes, these articles will be my venue to share some insider tips and tricks about those federal energy and policy processes. Whether through detailing the intricacies of the federal rulemaking process, analyzing the energy policies coming through the Federal Register, or providing copy-editing advice for technical and/or government writing, the “Insights and Advice” series will highlight some best practices and provide the perspective from a career consultant to the DOE processes.

About That Tesla Roadster Flying Through Space– What Kind of Gas Mileage Is It Getting?

Elon Musk and his SpaceX team made huge news last week when they successfully completed the maiden launch of the Falcon Heavy on the afternoon of February 6, 2018. This launch was such a monumental accomplishment because the private company venture (the heaviest commercial rocket ever launched) could one day be used to take astronauts to the Moon and Mars, and it demonstrated the ability to do so with the ability to guide the rocket boosters back to Earth for reuse.

While all of this news was one of the most amazing accomplishments by a private sector company in terms of scale and implications for humanity, one of the most gripping aspects of the project ended up being the fact that the test payload Musk chose to attach to the rocket was his personal Tesla Roadster, painted cherry red to represent the launch’s step towards getting to Mars. The reason behind launching this $100,000 car into space (never to return) was purely to capture people’s attention and imagination, a goal that was undeniably achieved as Musk was able to give the world this image that mindbogglingly is real and not using any sort of Photoshop and was compelling enough to get everyone to take notice of this amazing accomplishment.

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Given that the mission statement of Tesla is “to accelerate the advent of sustainable transport by bringing compelling mass market electric cars to market as soon as possible,” I found it cheekily ironic that fossil fuel– rocket fuel, no less– had to be used to get this Tesla mobile. This not entirely serious thinking led me to the tongue-in-cheek line of questioning– how did the fuel economy of this space-bound Tesla compare with the fuel economies of cars that are restricted to a terrestrial existence? What about the relative carbon dioxide (CO2) emissions?

Let’s bust out that handy back-of-the-envelope to scratch out some (very) approximate estimates!



The Tesla Roadster

The car that was sent into an elliptical orbit around the Sun was Elon Musk’s personal 2008 Tesla Roadster, ‘piloted’ by a mannequin in a SpaceX flight suit named Starman. This model of Tesla electric cars weighs in at 2,723 pounds, went for a base price of $98,000, sold 2,400 units before production was stopped, and was notable as the first highway legal serial production all-electric car using lithium-ion batteries and the first all-electric car to travel more than 200 miles per charge.

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Fuel Economy

The official fuel economy rating of the Tesla Roadster from the Environmental Protection Agency (EPA) is 119 miles per gallon equivalent (MPGe), being able to travel 245 miles on an eight-hour charge (the MPGe value compares the amount of electricity needed to move an electric car with the amount of gasoline needed to move a gasoline-powered car using the energy equivalence of one gallon of gas matching 33.7 kilowatt-hours of electricity).

As a comparison for the fuel economy of a Tesla Roadster:

The following table summarizes this range of fuel economies of the Earth-restricted vehicles:

Carbon dioxide emissions

While the use of electricity when driving a Tesla (or any electric car) is indeed carbon neutral in that no CO2 is being emitted from a tailpipe, it is not entirely true to rate the CO2 emissions per mile driven as zero. The simple reason behind that is that the generation of electricity that ends up in the vehicles come tied to the CO2 emissions at the electric power generation plants. While the portion of the U.S. power sector that is driven by carbon neutral sources like wind, solar, and nuclear is growing, fossil fuels like coal, natural gas, and petroleum still accounted for over 60% of U.S. electricity generation in 2017. As such, whenever a Tesla gets plugged into the grid it is likely receiving electricity that comes from CO2-emitting sources (not to mention the inefficiencies that come from the transmission & distribution of the electricity, the charging losses of the batteries, and the ‘vampire losses’ of charge when the car is not plugged in and not in use). Because of this, the CO2 footprint of driving a Tesla, or any electric vehicle, is intrinsically tied with the energy makeup of the particular electricity supplier.

The Nissan Leaf, another all-electric vehicle, accounts for about 200 grams of CO2 per mile (g CO2/mile) on average across the United States, while California (with one of the highest proportions of clean electricity in the country) comes in at 100 g CO2/mile and Minnesota (a state that is very dependent on fossil fuel) comes in at 300 g CO2/mile. For the sake of this exercise we’ll use these readily available Nissan Leaf numbers as the benchmark CO2 emissions per mile of an electric car, even though the Tesla Roadster is likely slightly different due to different charging rates and battery technologies.

As a comparison for this rate of CO2 emissions of an electric car:

The following table summarizes this range of CO2 emissions for non-rocket fueled vehicles:

Launching Starman’s Roadster

At pre-launch, Musk noted that ultimately the payload (i.e., Starman’s Tesla Roadster) would get 400,000 million kilometers (almost 250,000 million miles) away from Earth, traveling at 11 kilometers per second (almost 7 miles per second), and would orbit for hundreds of millions, or even billions of years (see below graphic of the initial orbit that Musk tweeted out after the launch). To accomplish this, the Falcon Heavy generated 5 million pounds of thrust at liftoff (making it the most powerful liftoff since Nasa’s Saturn V). Generating this amount of power is no small feat.

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To estimate exactly how much fuel was used (and how much that would be in the equivalent gallons of motor gasoline) requires some estimates, but we have enough information to get at least in the ballpark.

When fueling its rockets, SpaceX uses a highly refined type of kerosene (also known as RP-1) because of its high energy per gallon, in addition to liquid oxygen (LOX) needed for combustion (the amount of LOX required is about double the amount of RP-1). The first stage of a Falcon 9 rocket (another type of rocket used by SpaceX) uses 119,100 kilograms (kg) of RP-1 and 276,600 kg of LOX, while the second stage uses 27,850 kg of RP-1 and 64,820 kg of LOX (see graphic below for what that multi-stage launch sequence looks like). A simplified explanation of the Falcon Heavy is really that it’s composed of three Falcon 9 rockets merged into the first stage and the second stage consisting of disconnecting from the three Falcon 9 rockets and a single stage 2 rocket (along with the payload) continuing on. Making rough estimates, this means the Falcon Heavy required three times the fuel of the first stage and one times to fuel of the second stage of the Falcon 9, or a total of 385,150 kg of RP-1 and 894,620 kg of LOX (this is admittedly a simplification of the fueling process, but I’m also admittedly not a rocket scientist. In attempting to keep these estimates as rigorous as possible, see the citations and links contained here and let me know in the comments if I got something wrong– particularly if you are a rocket scientist!).

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Musk, when discussing the potential dangers of the Falcon Heavy launch, noted that the fuel on board was 4 million pounds of TNT equivalent. In fact, the energy contained within looks like it could be over double that (whether this is a sign of Musk simplifying for the sake of giving the press a quote, speaking approximately without reference to the exact calculations beforehand, or missteps in my calculations, I’ll let you decide). While the total weight of the LOX is over double the weight of the RP-1, the LOX is simply there to allow for combustion and maximize the efficiency with which the rocket is burned. As such, the energy density of RP-1 is what we care about. Using an energy density of 43.2 Megajoules (MJ) per kg, we find that the energy contained in the Falcon Heavy’s fuel tanks was over 16.6 million MJ, which is equal to about 126,000 gallons of gasoline equivalent (or over 8.7 million pounds of TNT— so while our estimate is over double Musk’s offhand remark, we can take solace that we’re in the same order of magnitude!).

In terms of the CO2 released by burning this much fuel, we can use the “well to wake” emissions number of RP-1 of 85 grams of CO2-equivalent per MJ to estimate that the total CO2 emissions were over 1.4 million kg (or 1,400 metric tons) of CO2.

Comparing Starman’s Tesla with Earth vehicles

First things first– that’s definitely the most fossil fuel used and CO2 emitted ever in getting a car from point A to point B. But that doesn’t necessarily mean that Starman’s Tesla is the least efficient or most harmful to the environment. That’s because once the fuel is burned and Starman’s Tesla  was set into orbit in perpetual motion, logging millions of miles on the odometer while traveling 25,000 miles per hour, the rest of its journey was all without additional energy input.  Even the camera and communication equipment on board were attached to a battery with 12 hours of life with no other sources of energy, so after the 12 hours the equipment went dark and there was no more energy input to Starman’s Tesla– just momentum and gravity working their magic. So despite this initial abundance of fossil fuel and related CO2 emissions to set the Tesla in motion, on a per mile basis (which is how fuel economy and emissions are calculated) it will inevitably becomes the most efficient and clean car of all time!

But how long will it take for this to be true?

Fuel economy

In terms of fuel economy, the MPGe of Starman’s Tesla improves linearly with every mile traversed through space. After 1,200 miles, the Falcon Heavy and its payload of Starman and his Tesla left Low Earth Orbit, but the massive amount of fuel means it barely even registers as a blip on this graph at about 0.0095 MPGe.

After two days when Starman’s Tesla had traveled 450,000 miles, the fuel economy had risen to a little less than half that of the freight truck. You can also note in the graph that at the point of the 36,000 mile warranty of the Tesla Roadster the fuel economy aws still less than 0.3 MPGe– you’d certainly have a lot of angry Tesla owners if that’s all they were able to recoup on gasoline costs by the end of their warranty!

Lastly, after teasing out how far Starman’s Tesla would have to travel to become the most fuel efficient car (that is or ever was) on Earth, we find that it would take:

  • About 900,000 miles to beat the fuel economy of freight trucks;
  • About 2.9 million miles to beat the average of the U.S. light-duty stock fuel economy;
  • About 3.7 million miles to meet the 2018 light truck standards;
  • About 5.0 million miles to meet the 2018 car standards;
  • About 7.3 million miles to meet the most efficient gas powered car available;
  • About 15 million miles to meet the efficiency of an Earthly Tesla Roadster; and
  • About 17.2 million miles traveled to equal the 136 MPGe of the Hyundai Ioniq Electric, the most efficient car available.

As previously mentioned, the equipment on board Starman’s Tesla was attached to a battery that only had 12 hours of life, after which there was no functioning equipment on the Roadster. As such, there is no inherent tracking or communicating with Starman’s vehicle as it continues on its journey, making its exact tracking through space difficult.

But fear not– a great tool was launched after the Roadster was launched into orbit called ‘Where is Roadster?‘ Using the knowledge available regarding the position, orbit, and speed of the Tesla, this tool shows approximately where in its orbit the Roadster is and how far it has traveled in aggregate. This tool does not allow going back to see when exactly certain distances were passed, but from watching the site myself I can attest that Starman’s Roadster passed 17.2 million miles on the afternoon of February 14, 2018– meaning it only took eight days for this Tesla Roadster to become the most efficient car ever! Any distance it continues to travel will only increase the overall fuel economy (if you want to calculate this for yourself at any given moment, divide the current miles from ‘Where is Roadster?‘ by 126,279 gallons of gasoline equivalent).

CO2 emissions

In terms of CO2 emissions per mile, Starman’s Tesla improves according to a power equation– meaning in this case that there are drastic improvements in CO2 emissions per mile initially that flatten out over time. By the time Starman’s Tesla leaves Low Earth Orbit, not nearly enough miles have been traveled to offset the massive amount of CO2 emissions from the rocket launch, with Starman’s Tesla coming in at a mindblowing 1.2 million g CO2/mile at 1,200 miles– the equivalent of 182 freight trucks moving a mile at a time.

After two days and 450,000 miles traveled, the CO2 emissions per mile had dropped to 3,143 g CO2/mile, blowing way past the average freight truck emissions after about 219,000 miles. After the 36,000 mile warranty, the emissions still averaged over 39,000 g CO2/mile– another tidbit that would enrage an environmentally conscious electric car owner if it happened to them.

Again projecting out how far Starman’s Tesla would have to travel to become the cleanest car in existence, we find that it would take:

  • About 3.4 million miles to be cleaner than the average passenger vehicle;
  • About 4.7 million miles to be cleaner than an electric vehicle charged in fossil-fuel-dependent Minnesota;
  • About 5.0 million miles to meet the emissions standards for light trucks in 2018;
  • About 7.0 million miles to meet the emissions standards for cars in 2018;
  • About 7.1 million miles to be cleaner than the average electric vehicle in the United States; and
  • About 14.1 million miles to be cleaner than an electric vehicle charged in renewable-energy-heavy California.

Again by watching the ‘Where is the Roadster?‘ tool, I found that Starman’s Tesla also became the cleanest car ever (on a g CO2/mile basis) on February 14, only 8 days after launch. As with the fuel economy, this figure will only get better and better as Starman racks up the limitless miles circling the Sun for millions or billions of years (to calculate an updated emissions per mile, divide 1,414,270,800 grams of CO2 emissions by the updated miles traveled from ‘Where is Roadster?‘).

Conclusion

So there you have it, despite the massive amounts of fuel and resultant CO2 emissions required to launch the Tesla Roadster in space, it only took eight days of traveling faster than any car ever before to become the most fuel efficient and least CO2-emitting (on a per mile basis) ever made. But that fact was inevitable given that it’s in orbit around the Sun and will likely be for the rest of humanity’s existence– so what really is the point of crunching the numbers like this? Hopefully you’ll come away from this article with a handful of takeaways and topics/issues on which to do some more reading and learning:

  1. The impressiveness of this feat accomplished by Musk adn the whole team at SpaceX cannot be overstated. The Tesla Roadster weighs just 2,723 pounds, but this launch was testing a rocket system whose ultimate payload capacity extends to almost 141,000 pounds sent to Low Earth Orbit, 37,000 pounds sent to Mars, and 7,700 pounds sent to Pluto– all at decreased cost compared with historical launches that really opens up doors. That is the most important takeaway from the Falcon Heavy launch, a huge step towards what Musk hopes to be the next great space race.
  2. Beyond that, running through these tongue-in-cheek calculations should hopefully serve to pique your interest and give some information on the relative fuel efficiency electric cars are able to achieve, but also some of the current shortcomings in terms of using them as a way to reduce CO2 emissions. A lot of interesting pieces have been written on the true environmental impact of electric cars, as well as how that might evolve in the future. I’ll recommend a couple (from Green Car Reports, Wired, The Union of Concerned Scientists, and Scientific American, just to name a few), but it’s an important topic with much more out there to be read and debated.
  3. In addition, given the relative fuel economies and CO2 emissions of various vehicles (as wella s regulations covering these measurements), let that be a reason to look more into the efficiencies and emissions of your vehicles. In particular, you’ll note the average passenger vehicle has twice the emissions per mile as a new Model Year 2018 car that complies with EPA regulations, while the new cars will also get up to 74% more MPG compared with the average for the U.S. fleet of light-duty vehicles. Keep these types of figures in mind the next time you’re in the market for a vehicle, and consider how much fuel and emissions savings are being protected and increased by these existing regulations (both fuel economy and car emissions regulations are being considered for rollbacks by the Trump administration) as automotive regulations and policies continue to make the news.

Sources and additional reading

Can Driving a Tesla Offset the Impact Of A SpaceX Launch? Clean Technica

Electric Cars Are Not Necessarily Clean: Scientific American

Elon Musk says SpaceX has ‘done everything you can think of’ to prepare Falcon Heavy for launch today: Business Insider

Falcon 9 v1.1 & F9R Launch Vehicle Overview: Spaceflight 101

Falcon Heavy: SpaceX

Falcon Heavy: SpaceX stages an amazing launch — but what about the environmental impact? The Conversation

How Much Fuel Does It Take To Get To The Moon? Huffington Post

Musk’s Falcon Heavy Packs a Huge Payload: Forbes

SpaceX’s Falcon Heavy Rocket: By the Numbers: Space.com

SpaceX’s Falcon Heavy rocket nails its maiden test flight: NBC News

SpaceX launch: Why is there a Starman spacesuit in the Tesla Roadster? Express

The Falcon Heavy Packs A Huge Payload: Statista

Where is Elon Musk’s Tesla Roadster with Starman?

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Playing Politics with Energy Security: How the Latest Congressional Budget Deal Raids the Strategic Petroleum Reserve

Looking to finally reach a longer-term agreement to avoid an extended federal government shutdown last week, a bipartisan deal was reached in Congress in the early morning of February 9 that would fund the government for the next two years. As the details of the deal get combed over there is plenty to digest, even in just energy-related topics (such as the inclusion of climate-related policy), but one notable part of the budget agreement was the mandate to sell 100 million barrels of oil from the Strategic Petroleum Reserve (SPR). The stated goal of this move was to help pay for tax cuts and budgetary items elsewhere in the deal, but will that goal be realized or is Congress paying lip service to the idea of fiscal responsibility at the expense of future energy security?



Purpose and typical operation of the SPR

In a previous post, I covered more extensively the background and purpose of the SPR. In short, the SPR is the largest reserve supply of crude oil in the world and is operated by the U.S. Department of Energy (DOE). The SPR was established in the wake of the oil crisis of the late 1970s with the goal of providing a strategic fail-safe for the country’s energy sector– ensuring that oil is reliably available in times of emergency, protecting against foreign threats to cut off trade, and minimizing the effect to the U.S. economy that drastic oil price fluctuations might cause.

In general, decisions regarding SPR withdrawals are made by the President when he or she 1) “has found drawdown and sale are required by a severe energy supply interruption or by obligations of the United States under the international energy program,” 2) determines that an emergency has significantly reduced the worldwide oil supply available and increased the market price of oil in such a way that would cause “major adverse impact on the national economy,” 3) sees the need to resolve internal U.S. disruptions without the need to declare “a severe energy supply interruption, or 4) sees it a suitable way to comply with international energy agreements. These drawdowns, following the intended purpose of the SPR, are limited to a maximum of 30 million barrels at a time.

Outside of these standard withdrawals, the Secretary of the DOE can also direct test sales of up to 5 million barrels, SPR oil can be sold out on a loan to companies attempting to respond to small supply disruptions, or Congress can enact laws to authorize SPR non-emergency sales intended to respond to small supply disruptions and/or raise funds for the government. This last type of sale is what Congress authorized with the passing of the budget deal (see the previous article on the SPR to read more about how the SPR oil actually gets sold).

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While selling SPR oil to raise funds is legislatively permitted, this announced sale of 100 million barrels (15% of the balance of the SPR) is an unprecedented amount– the biggest non-emergency sale in history according to ClearView Energy Partners. More concerning than the amount of oil to be sold, though, is the ambiguity behind what exactly the sale of SPR oil will fund. Historically, an unwritten and bipartisan rule was that the SPR was not to be used as a ‘piggy bank’ to fund political measures. However, that resistance to using the SPR as a convenient way to raise money (for causes like infrastructure or medical research) was waned as Congress has faced the perennial opposition to raising taxes and the need for new sources of income.

Lisa Murkowski, Chairwoman of the Senate Energy and Natural Resources Committee, has echoed these frustrations about how the funds from the SPR sell-off will be used. When asked how Congress would spend the money, she simply replied it would be spent on “whatever they want. That’s why I get annoyed.” Despite the history of the SPR being an insurance policy for the U.S. energy sector and economy from threats of embargo from foreign nations, natural disasters, and unexpected and drastic changes in the market, the inclusion of SPR sales in this budget is just further indication of Congress trading out energy security and buying into other priorities. Taking the issue a step further, once the oil from the SPR is sold off, it likely becomes that much harder to convince Congress in the future to find the money to rebuild stocks with any additional oil stocks that might become necessary, both because the trajectory of oil prices is always climbing and thus naturally becomes more expensive to do so over time and because getting Congressional approval for new spending will always be more difficult politically than ‘doing nothing’ and just keeping SPR stocks at their current levels.

But is this selling of the SPR oil really in the name of deficit reduction and fiscal responsibility? Will the sale of this oil make an appreciable difference and help balance out the budget that Congress agreed to at (or, rather, past) the eleventh hour?

Crunching the numbers

Ignoring the previously authorized SPR sales, this budget deal alone included directive for DOE to sell 100 million barrels of oil from the SPR. What level of funds would this actually raise, and would it be enough to make a dent in the deficit? At current prices of crude oil that have hovered in the $60 per barrel (b) range, the sale would translate to about $6 billion– but the actual number depends on the price at which the oil gets sold, an uncertain number because the oil is being sold over the next 10 years and oil prices are notoriously variable.

We can make a certain degree of estimates based on the outlook of crude oil prices going forward (acknowledging at the outset the significant uncertainty that any forecast inherently assumes, especially in the oil markets that are affected by outside factors like government policy and geopolitical relations). To get a rough idea, though, we can look at the recently released 2018 Annual Energy Outlook (AEO2018) from the Energy Information Administration (EIA) which projects energy production, consumption, and prices under a variety of different scenarios (such as high vs. low investment in oil and gas technology, high vs. low oil prices, and high vs. low economic growth).

Source (Click to enlarge)

Brent crude oil (representative of oil on the European markets) starts at about $53/b in 2018 and goes up to about $89/b by 2027 in the ‘reference case’ (going from $27/b to $36/b in the low oil price scenario and $80/b to $174/b in the high oil price scenario). Similarly, West Texas Intermediate (WTI) oil (representative of the U.S. markets) starts at about $50/b in 2018 and goes to $85/b in 2027 in the ‘reference case’ ($243/b to $33/b in the low oil price scenario and $48/b to $168/b in the high oil price scenario). These figures present a pretty wide range of possibilities, but that is unfortunately the nature of oil prices in today’s climate. Further, EIA does unofficially consider these ranges to be akin to the 95% confidence intervals between which the actual prices are almost assured to be found, so we can still find value in these prices as the ‘best’ and ‘worst’ case scenarios.

For simplicity’s sake, we can assume this 100 million barrels sold will be sold in equal chunks of 10 million barrels per year from 2018 to 2027 (though the actual sale will certainly not follow this neat order, but the assumption will get us in the approximate range). In the below charts, see the amount of funds raised from this SPR sale assuming the actual sale price is the average of Brent and WTI prices in the AEO2018 reference case compared with using the price of Brent in the high oil price scenario (the largest total oil price in any side case) and the price of WTI in the low oil price scenario (the lowest oil price in all of the side cases). The top chart tracks the amount of money raised in each of the 10 years while the bottom chart then shows the cumulative money raised in these three scenarios over the course of the decade.

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As shown, the low oil price scenario raises between $226 million and $326 million every year for a decade, totaling just shy of $3 billion in funds. In the high price scenario, the annual amount brought in is between $800 million and $1.7 billion per year, totaling about $14 billion in funds. In the reference case, the one that is most likely (though not at all assured) to be representative, each year the selling of SPR oil would bring in between $512 million and $868 million for a total of $7.5 billion in funds.

Now let’s be clear about one thing–raising somewhere between $3 billion and $14 billion is a lot of money. But in the context of this budget that was passed and the rising deficit of the federal government, how much of a dent will this fundraising through the sale of SPR oil really make?

The budget deal will add $320 billion to deficits over the next decade, which is almost $420 billion when factoring in interest according to the Congressional Budget Office. That massive increase in spending, an average of $42 billion per year, makes the funds from the SPR sale look like pocket change:

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Both the sale of SPR oil and the impact of this budget will be felt over the next 10 years, meaning these dollar figure present very apt comparisons. At the end of the decade, the high oil price scenario shows that SPR oil sales will only account for 3.4% of the deficit increase, while the reference case would account for 1.8% of the deficit increase and the low oil price scenario would only account for 0.7% of the deficit increase. Since the deficit would increase over the course of 10 years, another way to think of it is that the selling of SPR oil would account for 124 days of the deficit increase in the high oil price scenario, while the reference case would account for 65 days of the deficit increase and the low oil price scenario would account for 26 days of the deficit increase.

Outside of the increase to the deficit, the discretionary spending from the budget increase are to be $296 billion over the next two years (not including money given immediately to disaster spending, healthcare, and tax cuts). The SPR oil sale translates to between 1.0 and 4.8% of the discretionary spending increase or 7 to 35 days of the two years worth of spending increases.

Lastly, after accounting for this latest Congressional budget agreement, the CBO projects the federal deficit will increase to $1.2 trillion in 2019. If the sale of SPR oil is attempted to be pushed as a degree of fiscal responsibility in the wake of this budget deal, it is worth noting that the authorized sale of the SPR oil would only account for 1.2% of the total federal deficit in the best case scenario of high oil prices (0.2% in the low oil price scenario)– a metaphorical drop in the bucket (though for those curious, it’s actually significantly more than a literal drop in the bucket!).

What’s it all mean?

Buckets get filled drop by drop all the time, and it inherently requires many drops to fill up that bucket. So in this metaphor, each drop need not be disparaged for not being larger and doing more to fill up the bucket as it is the aggregate effect we should care about. Despite that truth, it is still fair to bring up whether the sacrifices required to gather that ‘drop’ were worthwhile. Going back to the origin and history of the SPR, Congress selling off large portions of the stocks of oil was never meant to fund ambiguous budgetary measures.

This 100 million barrels to be sold should also not be taken without the context of the sales already authorized by Congress last year that will also become reality in the next decade. Combined with the previously mandated sales, after this budget deal the SPR will be left with just over 300 million barrels of oil— about half of what it had been. So the negative side of this is that Congress appears ready and willing to gut the SPR. However the other side is that, because of the U.S. shale oil boom and other factors, the amount of net imports of oil and oil products to the United States has been dropping significantly. In the context of decreasing net imports, the amount of SPR stock measured in terms of ‘days of supply of total petroleum net imports’ has seen a comparable rise. What this means is that because the United States has become less dependent on foreign oil, less oil needs to be stored in the SPR to provide the same amount of import coverage.

Source (Click to enlarge)

In the wake of this budget passing and the previously announced SPR oil sales, many energy analysts came out to call these moves short-sighted at best, citing the following among the many reasons:

Because the budget that was passed was over 600 pages and was voted on before most people (or anyone) would realistically have a chance to read it, it’s yet to be clear what part of the budget will cause the most noise. But in terms of this surprising move by Congress with respect to the SPR, the questions to wrestle with become the following: Is it wise to sell off our oil insurance policy that might be needed in future tough times just because things are looking good for the present U.S. oil market? Is the financial benefit of reducing SPR oil stocks by such a significant amount  worth paying off a couple of weeks to a couple of months of the increased deficit, or is it possible that such a sale is only paying lip service to fiscal responsibility that allows politicans to point to an impressive sounding source of funds (up to $14 billion!) when in reality it doesn’t move the needle much (a maximum of 3% of the increase in deficit)?

Sources and additional reading

2018 Annual Energy Outlook: Energy Information Administration

America’s (not so) Strategic Petroleum Reserve: The Hill

Budget deal envisions largest stockpile sale in history: The Hill

CBO Finds Budget Deal Will Cost $320 Billion: Congressional Budget Office

DOE in Focus: Strategic Petroleum Reserve

Harvey, Irma show value of Strategic Petroleum Reserve, energy experts say: Chron

Petroleum reserve sell-off sparks pushback: E&E Daily

U.S. Looks To Sell 15% Of Strategic Petroleum Reserve: OilPrice.com

U.S. SPR Stocks as Days of Supply of Total Petroleum Net Imports: Energy Information Administration

Weekly U.S. Ending Stocks of Crude Oil in SPR: Energy Information Administration

Why the U.S. Shouldn’t Sell Off the Strategic Petroleum Reserve: Wall Street Journal

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Debunking Trump’s Claim of “War on Beautiful, Clean Coal” Using Graphs

In President Trump’s first State of the Union Address last week, a wide range of topics in the Administration’s agenda were covered extensively while energy was largely pushed to the side. Trump did include two sentences on his self-described push for “American Energy Dominance,” and these two sentences sent wonks in the energy industry into a frenzy on social media:

“We have ended the war on American energy. And we have ended the war on beautiful, clean coal.”

My Twitter feed lit up with various energy journalists and market watchers who noted the impressiveness that just 18 words over two sentences could contain so many misleading, or outright false, claims.

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As one of those energy reporters who immediately took to Twitter with my frustration, I thought I would follow up on these statements last week with arguments why the claims of ‘clean coal’ and the supposed ‘war’ on it do not reflect the reality the Trump Administration would have you believe, and I’ll do so with just a handful of graphs.



What is ‘clean coal’?

As a pure fuel, coal is indisputably the ‘dirtiest’ energy source in common use in the power sector, accounting for about 100 kilograms (kg) of carbon dioxide (CO2) per million British thermal unit (MMBtu) of energy output. This output is notably larger than other major energy sources, including natural gas (about 50 kg/MMBtu), petroleum products like propane and gasoline (about 60 to 70 kg/MMBtu), and carbon neutral fuels like nuclear, hydroelectric, wind, and solar. In the face of the scientific consensus on CO2’s contributions to climate change, many have noted that one of the best actions that can be taken in the energy industry is to shift away from coal to fuels that emit less CO2— which has definitively given coal a dirty reputation.

The premise of ‘clean coal’ is largely a PR push (literally invented by an advertising agency in 2008)– an ingenious marketing term, but one that does not have much in the way of legs. When you hear politicians talking about ‘clean coal,’ it is usually referring to one or more of the following suite of technologies:

  • Washing coal before it’s burned to remove soil and rock and thus reduce ash and weight of the coal;
  • Using wet scrubbers on the gas generated from burning coal to remove the sulfur dioxide from being released;
  • Various carbon capture and storage (CCS) technologies for new or existing coal plants that intervene in the coal burning process (either pre-combustion or post-combustion) to capture up to 90% of the CO2 produced from its burning and then sending it miles underground for permanent storage instead of releasing it into the atmosphere; or
  • Anything done to the coal-fired power plant to increase the efficiency of the entire process of generating electricity (e.g., the 700 Megawatt supercritical coal plant in West Virginia that is so efficient it reportedly releases 20% less CO2 than older coal plants) and reduce the overall emissions.

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When most in the energy industry discuss ‘clean coal’ technology, they are typically referring to CCS. However it should be noted that Trump did not mention CCS by name in this (or any) speech. Some analysts have noted that the White House’s attempts to cut CCS funding and send the Secretaries of the Department of Energy (DOE) and Environmental Protection Agency (EPA) to supercritical coal plants are not-so-subtle hints that the Trump Administration’s preferred type of ‘clean coal’ is improving the efficiency of coal-fired generation. Even Bob Murray, the influential coal magnate, has written to the President to indicate his contempt for CCS, calling it a ‘pseudonym for no coal,‘ echoing the concerns of many proponents of coal that CCS is being pushed as the only ‘clean coal’ option so that if/when it fails (due to economic impracticalities) it would be the death knell of coal-fired generation altogether.

So regardless of which ‘clean coal’ technology the Trump Administration supports, issues remain. With regard to wet scrubbers, coal washing, and general plant efficiency improvements, the reductions in CO2 emissions are not nearly enough to compete with cleaner fuels. Even if all coal plants could be made 20% more efficient (and less reduce CO2 emissions by about 20%) like the West Virginia supercritical plant, which would be a massive undertaking, it would still result in coal generation being among the dirtiest energy in the country.

With regard to CCS, not only is the cost one of the biggest issues (which will be looked at in more detail later), but it does not remove all the pollutants from burning coal. Even with the most effective CCS capturing 90% of CO2 emissions, that leaves 10% of CO2 making its way into the atmosphere along with the other notable pollutants in coal gas (including mercury, nitrogen oxide, and other poisonous contaminants). When compared with the carbon neutral energy sources increasingly gaining ground in the United States, coal plants with CCS still hardly seem clean.

Again, the Energy Information Administration’s (EIA) listing of carbon dioxide emissions coefficients shows the CO2 emissions associated with different fuel types when burned as fuel. As previously noted, coal is the far-away leader on CO2 emissions coefficients as a pure fuel. In DOE analysis of future-built generation (an analysis that focuses on the costs and values of different types of power plants to be built in the future, which will come up again in more detail later), the only type of coal generation even considered is coal with either 30% or 90% carbon sequestration, with 90% being the technological ceiling and 30% being the minimum example of new coal-fired generation that would still be compliant with the Clean Air Act. The below graph, our first in demonstrating the issues with claims of a ‘war on beautiful, clean coal,’ plots the CO2 coefficients of major fuel sources in the U.S. power sector, including coal using no CCS, 30% CCS, or 90% CCS. Existing power plants do not have the same requirements under the Clean Air Act, so they might still be producing CO2 at the far right of the ‘coal’ bar (indeed, last year almost 70% of U.S. coal was delivered to power plants that are at least 38 years old meaning they are likely far from the most efficient coal plants out there). Coal plants that are touted as ‘clean’ because of their up to 20% increases in efficiency would still find themselves in the same (or greater) range of emissions as 30% CCS coal plants, while 90% CCS coal plants appear to the be the only ones that can compete with other fuels environmentally (though it comes at a potentially prohibitive cost, which will show up in a later graph).

Note that the data for these CO2 emission coefficients come from this EIA listing. The lines for 30%/90% CCS are not just drawn 30%/90% lower, but rather account for the presence of CCS requiring more energy and thus cause a dip in efficiency– this graph uses the rough efficiency drop assumed for CCS plants in this International Energy Agency report

These numbers paint a scary picture of coal and are the source of what causes many energy prognosticators to scoff at the utterance of ‘beautiful, clean coal,’ though it is important to be clear that these numbers don’t tell the whole story. While nuclear and renewable energy sources do not emit any fuel-related CO2, they are not completely carbon neutral over their lifetimes, as the building, operation, and maintenance of nuclear and renewable generation plants (as with any utility-scale generation source) all have their own non-zero effect on the environment. However, since fuel makes up the vast majority of carbon output in the electricity generation sector, any discussion of clean vs. dirty energy must return to these numbers.

Further, the separation of dispatchable vs. non-dispatchable technologies (i.e., energy sources whose output can be varied to follow demand vs. those that are tied to the availability of an intermittent resource) shown in the above graph is important. Until batteries and other energy-storage technologies reach a point technologically and economically to assist renewable (non-dispatchable) energy sources fill in the times when the energy resource is unavailable, dispatchable technologies will always be necessary to plug the gaps. So regardless of what drawbacks might exist for each of the dispatchable technologies, CO2 emissions and overall costs included, at least some dispatchable energy  will still be critical in the coming decades.

Who is orchestrating the ‘war on coal’?

Even with the knowledge that coal will never truly be ‘clean,’ the question then becomes why haven’t the advancements in coal energy that is cleaner and more efficient than traditional coal-fired plants become more prominent in the face of climate and environmental concerns? The common talking point from the Trump Administration is that there is a biased war on coal being orchestrated, and the actions of President Trump to roll back regulation is the only way to fight back against this unjust onslaught that the coal industry is facing. But again, from where is this onslaught coming?

The answer to this question is actually pretty easy– it’s not regulation that is causing coal to lose its place as the king of the U.S. power sector, it’s competition from more affordable energy sources (that also happen to be cleaner). The two charts below demonstrate this pointedly, with the left graph showing the fuel makeup of the U.S. electric power sector since 1990 along with the relative carbon intensity of the major CO2-emitting fuel sources, while the right graph shows what’s happened to the price of each each major fuel type over the past decade. The carbon intensity shown on the left graph is even more indicative than the first graph above in detailing the actual degree to which each fuel is ‘clean’ as it factors in the efficiency of plants using the fuel and indicates the direct CO2 emissions relative to electricity delivered to customers.

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Note that the costs are taken from this EIA chart, with coal taken from fossil steam, natural gas taken from gas turbine and small scale, and wind/solar taken as the gas turbine and small scale price after removing the cost of fuel. Electric power generation and carbon emission data taken from this EIA source

Just from analysing these two graphs, a number of key observations and conclusions can be made about the electric power sector and coal’s evolving place in it:

  • In 1990, coal accounted for almost 1.6 million Gigawatt-hours (GWh) of power generation, representing 52% of the sector. By 2016, that figure dropped to 1.2 million GWh or 30% of U.S. power generation.
  • Over that same time period, natural gas went from less than 400,000 GWh (12%) to almost 1.4 million GWh (34%); nuclear went from less than 600,000 GWh (19%) to over 800 GWh (20%), and combined wind and solar went from 3,000 GWh (0.1%) to over 260,000 GWh (6%).
  • While the coal sector’s carbon intensity hovered around 1.0 kg of CO2 per kilowatt-hour (kWh) of electricity produced from 1990 to 2016 (even as CCS and other ‘clean coal’ technologies began to break into the market), natural gas dropped from 0.6 kg CO2/kWh to less than 0.5 kg CO2/kWh, while nuclear, wind, and solar do not have any emissions associated with their generation (again noting that there are some emissions associated with the operation and maintenance of these technologies, but they are neglible compared with fossil fuel-related emissions). The drop in natural gas carbon intensity combined with coal losing ground to natural gas, nuclear, and renewable energy led the electric power sector’s overall average carbon intensity to drop from over 0.6 kg CO2/kWh to less than 0.5 kg CO2/kWh.
  • While the narrative some would prefer to push is that coal is getting replaced because of a regulatory ‘war on coal,’ the real answer comes from the right graph where the cost to generated a kWh of electricity for coal increased notably from 2006 to 2016. Meanwhile, natural gas (which started the decade more expensive than coal) experienced a drastic drop in price to become cheaper than coal (thanks to advances in natural gas production technologies) while the low cost of nuclear fuel and ‘free’ cost of wind and solar allowed these energy sources to start and remain well below the total cost of coal generation. This natural, free-market competition from other energy sources, thanks to increasingly widespread availability and ever decreasing prices, is what put pressure on coal and ultimately led to natural gas dethroning coal as the predominant energy source in the U.S. power sector.

What these two graphs show is that the energy market is naturally evolving, there is no conspiratorial ‘war’ on coal. The technologies behind solar and wind are improving, getting cheaper, and becoming more prolific for economic, environmental, and accessibility reasons. Nuclear power is holding strong in its corner of the electricity market. Natural gas, more than any other, is getting cheaper and much more prominent to the U.S. power sector (while having the benefit of about half the CO2 emissions of coal), which is what has made it the natural ‘enemy’ of coal of the past decade or two. All that’s to say, the only ‘war on coal’ that’s been widespread in recent memory is a capitalistic, free-market war that will naturally play out when new energy sources are available at cheaper prices and contribute significantly less to climate change.

Will Trump policies reverse the course of coal in the United States?

Going back to the statement from Trump’s State of the Union Address, he claimed that his Administration had ended the war on clean coal. As stated previously, there was never an outward war on coal that was hindering the fuel. Even still, the main policy change from the Trump Administration with regard to coal was to repeal the Clean Power Plan (CPP) that aimed to cut carbon emissions from power generation.  However, many analysts predicted that would not change the current trends, as repealing the CPP does nothing to reverse the pricing pattern of the fuels. Indeed, this week EIA released its Annual Energy Outlook for 2018 and confirmed the tough future that coal generation has compared with natural gas and renewables– both with and without the CPP. While the CPP reduces the projections of coal generation, it doesn’t move the needle all that much and natural gas and renewables are still shown to surpass coal.

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So the major policy decision of the Trump Administration with respect to coal generation doesn’t appear to reverse the course of coal’s future. Again, this conclusion isn’t terribly surprising considering the economics of coal compared with other fuels. EIA projects the Levelized Cost of Electricity (LCOE) for different type of new power generation (assumed to be added in 2022) which serves to show the relative costs to install new power generation. In the same analysis, EIA projects Levelized Avoided Cost of New Generation (LACE), which can be thought of as the ‘value’ of the new generation to the grid (for more detailed description in the calculations and uses of these measures, read through the full report). When the LACE is equal or greater than the LCOE, that is in indication of a financially viable type of power to build (evaluated over the lifetime of the plant). So by looking at the relative costs (LCOE) of each power type and whether or not they are exceeded by their values (LACE), we can get a clear picture of what fuel types are going to be built in the coming years (and to continue the focus on whether coal or other fuels are ‘clean,’ let’s put the economics graph side-by-side with the CO2 emissions coefficients):

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Note that the source of the data on the left graph is the EIA Levelized Cost of Electricity analysis, with the ends of the boxes representing the minimum and maximum values and the line in the middle representing the average– the difference in possible values comes from variations in power plants, such as geographic differences in availability and cost of fuel. Also note that, counter-intuitively, EIA’s assumed costs for 30% CCS are actually greater than for 90% CCS because the 30% CCS coal plants would ‘still be considered a high emitter relative to other new sources and thus may continue to face potential financial risk if carbon emissions controls are further strengthened. Again, the data for the right graph takes CO2 emission coefficients from this EIA listing by fuel type

Looking at these graphs, we can see that the cost of new coal generation (regardless of CCS level) not only exceeds the value it would bring to the grid, but also largely exceeds the cost of natural gas, nuclear, geothermal, biomass, onshore wind, solar photovoltaic (PV), and hydroelectric power (all of which emit less CO2 than coal). Thus even in the scenario where 90% of carbon is captured by CCS (which allows it to be ‘cleaner’ than natural gas and biomass), it still comes at a significant cost premium compared with most of the other fuel types. These are the facts that are putting the hurt on the coal industry, not any policy-based ‘war on coal.’ Even the existing tax credits that are given to renewable energy generation are minor when looking at the big picture, as the below graph (which repeats the above graph but removes the renewable tax credits from the equation) shows. Even if these tax credits are allowed to expire, the renewable technology would still outperform coal both economically and environmentally.

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The last graphical rebuttal to President Trump’s statement on energy and coal during the State of the Union that I’ll cite comes from Tyler Norris, a DOE adviser under President Obama:

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As pointed out by Norris and other energy journalists chiming in during the State of the Union address, if the goal were to expand ‘clean coal,’ then the Trump Administration’s budget is doing the opposite by taking money away from DOE programs that support the research and development of the technology. In fact, at the end of last week a leaked White House budget proposal indicated even further slashes to the DOE budget that would further hamper the ability of the government to give a leg up to the development of ‘clean coal’ technology. Any war on energy is coming from the Trump Administration, and any battle that coal is fighting is coming from the free market of cheaper and cleaner fuels.

Sources and additional reading

20 Years of Carbon Capture and Storage: International Energy Agency

Annual Energy Outlook 2018: Energy Information Administration

Average Power Plant Operating Expenses for Major U.S. Investor-Owned Electric Utilities, 2006 through 2016: Energy Information Administration

Carbon Dioxide Emissions Coefficients: Energy Information Administration

Did Trump End the War on Clean Coal? Fact-Checking the President’s State of the Union Claim: Newsweek

How Does Clean Coal Work? Popular Mechanics

How much carbon dioxide is produced per kilowatthour when generating electricity with fossil fuels? Energy Information Administration

Is There Really Such a Thing as Clean Coal? Big Think

Levelized Cost and Levelized Avoided Cost of New Generation Resources in the Annual Energy Outlook 2017: Energy Information Administration

Trump touts end of ‘war on beautiful, clean coal’ in State of the Union: Utility Dive

Trump’s Deceptive Energy Policy: New York Times

What is clean coal technology: How Stuff Works

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Drilling in the Alaskan Arctic National Wildlife Reserve vs. Renewable Energy: The Drilling Debate, Economic and Environmental Effects, and How Solar and Wind Energy Investment Would Compare

In a first for this blog, the focus of this post comes directly from a reader request– so I’ll let this person’s words speak for themselves:

With Congress recently passing a bill allowing for drilling of oil and gas in Alaska’s Arctic National Wilidlife Refuge (ANWR), it got me curious (as a citizen of the sun-rich American Southwest) how much land would need to be covered in solar panels in order to generate the same amount of energy that would be found in these potential new oil and gas drilling sites. Obviously each energy source would have their individual costs to consider, but I am curious as to how efficient and cost-effective it would be to drill in the Alaskan arctic if there are cleaner and cheaper alternatives– it seems covering up the deserts of New Mexico and Arizona could be preferable to potentially harming some of the Alaskan environment and wildlife. Is drilling in this new area even an efficient and safe way for us to get additional oil and gas?
– Case

I loved the thoughtfulness and importance of this question and was inspired to immediately jump into research (also I was so happy to have a suggestion from an outside perspective– so if you read this or any of my other posts and you get inspired or curious, please do reach out to me!). From my perspective, this overall inquiry can be broken down into five questions to be answered individually:

  1. What is ANWR and what exactly did Congress authorize with regards to drilling in ANWR?
  2. How much potential oil and gas would be produced from the drilling?
  3. What are the economics associated with extracting and using oil and gas from ANWR?
  4. What are the environmental effects of that drilling?
  5. Can we do better to just install renewable energy resources instead of drilling in ANWR? How much capacity in renewable sources would be needed? How would the costs of renewable installations compare with the ANWR drilling?



Question 1: What is ANWR and what exactly did Congress authorize with regards to drilling in ANWR?

The Arctic National Wildlife Refuge, or ANWR, has long been a flash point topic of debate, viewed by proponents of oil and gas drilling as a key waiting to unlock fuel and energy independence in the United States, while opponents argue that such drilling unnecessarily threatens the habitat of hundreds of species of wildlife and the pristine environment that’s been protected for decades. ANWR is a 19.6-million-acre section of northeastern Alaska, long considered one of the most pristine and preserved nature refuges in the United States. Having stayed untouched for so long has allowed the native population of polar bears, caribou, moose, wolverines, and more to flourish. ANWR was only able to remain pristine due to oil and gas drilling in the refuge being banned in 1980 by the Alaskan National Interest Conservation Act, with Section 1002 of that act deferring decision on the management of oil and gas exploration on a 1.5-million-acre coastal plane area of ANWR known to have the greatest potential for fossil fuels. This stretch of ANWR has since become known as the ‘1002 Area.’

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This 1002 Area of ANWR is at the center of the ANWR debate, as Presidents and Congresses have had to fight various bills over the past couple decades that sought to lift those drilling bans, doing so successfully until recently. At the end of 2017, with Republicans (who have long been pushing to allow such oil and gas exploration in ANWR) controlling the White House and both Houses of Congress, decisive action was finally made. The Senate Energy and Natural Resources Committee, led by Lisa Murkowski of Alaska, voted in November to approve a bill that would allow oil and gas exploration, with that bill ultimately getting attached to and approved along with the Senate’s tax-reform package in December, with the justification for that attachment being that the drilling would help pay for the proposed tax cuts.

Specifically, the legislation that ended the ban on oil and gas drilling in ANWR did so by mandating two lease sales (of at least 400,000 acres each) in the 1002 Area over the next 10 years. The government’s royalties on these leases are expected to generate over $2 billion, half of which would go to Alaska and the other half to the federal government.

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Question 2: How much potential oil and gas would be produced from the drilling?

This really is the million dollar (or, rather, billion dollar) question, because part of the issue is that no one really knows how much fossil fuel is hidden deep under ANWR. The situation is a bit of a catch-22, as you cannot get a good idea for how much oil there is without drilling, but under the drilling ban you cannot explore how much there is. A number of surface geology and seismic exploration surveys have been conducted, and the one exploratory drilling project by oil companies was allowed in the mid-1980s, but the results of that study remain a heavily guarded secret to this day (although National Geographic has previously reported that the results of the test were disappointing). In contrast even to regions bordering ANWR in Alaska that have the benefit of exploratory drilling, any analysis of the 1002 Area is restricted to field studies, well data, and analysis of seismic data.

The publicly available estimates from the 1998 U.S. Geological Survey (USGS) (the most recent one done on the 1002 Area) indicate there are between 4.3 billion and 11.8 billion barrels of technically recoverable crude oil products and between 3.48 and 10.02 trillion cubic feet (TCF) of technically recoverable natural gas in the coastal plain of ANWR. Even though there is that much oil and gas that is technically recoverable, though, does not mean that all of it would be economical to recover. A 2008 report by the Department of Energy (DOE), based on the 1998 USGS survey and acknowledging the uncertainty in the USGS numbers given that the technology for the USGS survey is now outdated, estimates that development of the 1002 Area would actually result in 1.9 to 4.3 billion barrels of crude oil extracted over a 13-year period (while the rest of the oil would not be cost effective to extract). The report also estimates that peak oil production would range from 510,000 barrels per day (b/d) to 1.45 million b/d. These estimates must be taken with a grain of salt, however, as not only are they based on the use of now-outdated technology, but the technology to extract oil is also greatly improved. These technology improvements mean the USGS estimates could be low, but on the other side, oil exploration is always a lottery and recent exploration near ANWR has been disappointing. That’s all to say, current estimate are just that, estimates– which makes the weighing of pros and cons of drilling all the more complicated.

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The 2008 DOE report did not assess the potential extraction of natural gas reserves (note that much of the analysis and debate surrounding ANWR drilling focuses mainly on the oil reserves and not the natural gas reserves, likely because the oil is more valuable, cost-effective to extract, and in demand. Where relevant, I will include the facts and figures of natural gas in addition to the oil, but note that certain parts of this analysis will have to center just on the oil based the the availability of data).

To put that in context, the total U.S. proved crude oil reserves at the end of 2015 were 35.2 billion barrels, so the technically recoverable oil in the 1002 Area would account for 12 to 34% of total U.S. oil reserves. At the end of 2015 the U.S. proved reserves of natural gas were 324.3 TCF, making the technically recoverable natural gas in the 1002 Area equal to 1 to 3% of total U.S. natural gas reserves. Put another way, the the technically recoverable oil reserves would equal 218 to 599 days worth of U.S. oil consumption (using the 2016 daily average), while the natural gas reserves would equal 47 to 134 days worth of U.S. natural gas consumption (using the 2016 daily average).

Question 3: What are the economics associated with extracting and using oil and gas from ANWR?

In addition to the push towards ‘energy independence’ (i.e., minimizing the need for oil imports from foreign nations where prices and availability can be volatile), a main motivation for drilling in the 1002 Area of ANWR is the economic benefits it could bring. In addition to the $1 billion for the Alaskan government and $1 billion for the federal government from the leasing of the land, Senator Murkowski boasted that the eventual oil and gas production would bring in more than $100 billion for the federal treasury through federal royalties on the oil extracted from the land.

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However, these theorized economic benefits to drilling is strongly disputed by the plan’s opponents, with president of the Wilderness Society noting that ‘the whole notion that you are going to trim a trillion-dollar deficit with phony oil revenue is just a cynical political ploy.’ When digging into the numbers more closely, the $1 billion to the federal government from leasing the land would end up offsetting less than 0.1% of the $1.5 trillion in tax  cuts to which the drilling provision was attached (while some analyses question whether the land would gather that much in reality, noting the estimates assume oil leases selling for 10 times what they sold for a year ago when domestic oil was scarcer and more expensive).

Outside of the federal revenue, the money coming to the Alaskan government would be even more influential, which is why the charge to open ANWR to drilling is often led by Alaskan policymakers. In fact, while a majority of Americans oppose drilling in ANWR, most Alaskans are cited as supporting responsible oil exploration. While that may seem counterintuitive, the Arctic Slope Regional Corporation explains that “a clear majority of the North Slope support responsible development in ANWR; they should have the same rights to economic self-determination as people in the rest of the United States.

In addition to the money raised by the government is the potential economic benefit to the country from the extraction of the oil. According to the previously mentioned 2008 DOE report, the extraction of the ANWR oil would reduce the need for the United States to import $135 to $327 billion of oil. This shift would have a positive benefit to the U.S. balance of trade by that same amount, but the reduction of reliance on imported foreign oil would only drop from 54% to 49%, and the effect on global oil prices would be small enough to be neutralized by modest collective action by the Organization of Petroleum Exporting Countries (OPEC), meaning U.S. consumers would likely not see an effect on their energy prices.

The last economic consideration would be the worth of the oil and the cost to the companies doing the drilling to extract and bring to market the oil products. A study done by the researchers at Elsevier found that the worth of the oil in the 1002 Area of ANWR is $374 billion, while the cost to extract and bring to market would be $123 billion. The difference, $251 billion, would be the profits to the companies— which theoretically would generate social/economic benefits through means such as industry rents, tax revenues, and jobs created and sustained.

So in short, the decision about whether or not to drill in ANWR has the potential to cause a significant economic effect for the federal and Alaskan state governments, the oil companies who win the leasing auctions, and those who might be directly impacted from increased profits to the oil and gas companies. As with all analytical aspects of ANWR drilling, though, the exact scale of that effect is hotly debated and subject to the great uncertainty surrounding how much oil and gas are technically recoverable from the 1002 Area. Further, the amount of oil that is economically sound to recover and put into the market (not to mention the price oil and gas companies would be willing to spend on leasing this land) is entirely depending on the ever-fluctuating and difficult to forecast price of crude oil, adding further potential variability to the estimates.

Question 4: What are the environmental effects of that drilling?

As previously noted, drilling in ANWR is an especially sensitive environmental  subject because it is one of the very few places left on Earth that remains pristine and untouched by humanity’s polluted fingerprint. The vast and beautiful land has been described by National Geographic as ‘primordial wilderness that stretches from spruce forests in the south, over the jagged Brooks Range, onto gently sloping wetlands that flow into the ice-curdled Beaufort Sea’ and is often called ‘America’s Serengeti.’ In terms of wildlife, ANWR is noted as fertile ground for its dozens of species of land and marine mammals (notably caribou and polar bears) and hundreds of species of migratory birds from six continents and each of the 48 contiguous United States.

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While the exact environmental effects of oil exploration and drilling are not known for certain, the potential ills that can befall the environment and wildlife in ANWR include the following:

  • Oil development is found to be very disruptive to the area’s famed porcupine caribou, potentially threatening their existence (an existence which the native Gwich’in people depend upon for survival), with the Canadian government even issuing a statement in the wake of the ANWR drilling bill reminding the U.S. government of the 1987 bilateral agreement to conserve the caribou and their habitat;
  • ANWR consists of a biodiversity that’s so unique globally that the opportunity for scientific study is huge, and any development of that land is a threat to that existing natural biodiversity in irreparable way;
  • The National Academy of Sciences has concluded that once oil and gas infrastructure are built in the Alaskan arctic region, it would be unlikely for that infrastructure to ever be removed or have the land be fully restored, as doing so would be immensely difficult and costly;
  • Anywhere that oil and gas drilling occurs opens up the threat of further environmental damage from oil spills, such as the recent BP oil leak in the North Slopes of Alaska that was caused by thawing permafrost; and
  • Not only do the direct effects of drilling for oil in ANWR need to be considered, but also the compounding effects that the eventual burning of that oil must be weighed. The use of the oil contained underground in Alaska will only serve to increase the effects of climate change in the Arctic, where temperatures already rise twice as quickly as the world average. The shores of Alaska are ground zero for the effects of climate change, with melting sea ice and rising sea levels causing additional concerns for survival of both wildlife and human populations that call Alaska home. The most climate-friendly way to treat the oil underneath ANWR would be to leave it in the ground.

Question 5: Can we do better to just install renewable energy resources instead of drilling in ANWR? How much capacity in renewable sources would be needed? How would the costs of renewable installations compare with ANWR drilling?

Part 1: Can we just install renewable energy instead of drilling?

At the crux of the original question was whether the country would be better off if we diverted resources away from ANWR drilling and instead developed comparable renewable energy sources. While this question is rooted in noble intent, the reality of the situation is that it would not always work in practice to swap the energy sources one-for-one.

Looking at the way in which petroleum (which includes all oils and liquid fuels derived from oil drilling) was used in the United States in 2016 using the below graphic that is created every year by the Lawrence Livermore National Laboratory (a DOE national lab), we find that 35.9 quadrillion Btus (or quads) of petroleum were consumed. This massive sum of oil energy (more than the total primary energy, regardless of fuel type, consumed by any single country other than the United States and Canada in 2015) is broken down as 25.7 quads (72%) in the transportation sector, 8.12 quads (23%) in the industrial sector, 1.02 quads (3% in the residential sector, 0.88 quads (2%) in the commercial sector, and 0.24 quads (1%) in the electric power sector. Meanwhile, the 28.5 quads of natural gas goes 36% to the electric power sector, 34% to the industrial sector, 16% to the residential sector, 11% to the commercial sector, and 3% to the transportation sector.

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(side note– I think this is one of the most useful graphics created to understand the U.S. energy landscape every year. I have it printed and hanging at my desk and if you are trying to learn more about the different energy types and relative sizes of the energy sector then I recommend this as a great graphic to always have handy)

Compare this breakdown with some of the non-fossil fuels:

  • 100% of wind power (2.11 quads) goes to the electric power sector;
  • 99% of hydropower (2.48 quads) goes to the electric power sector, with the rest going to the industrial sector;
  • 70% of geothermal power (0.16 quads) goes to the electric power sector, with the rest going to the residential and commercial sectors (using geothermal as a heat source as a direct substitute for the electric power sector); and
  • 58% of solar power (0.34 quads) goes to the electric power sector, while 27% goes to residential sector (in the form of residential solar generation or solar heating, essentially a direct substitute for the electric power sector), 12% goes to the commercial sector (also basically a direct substitute for the electric power sector), and less than 1% goes to the industrial sector.

We see that renewable energy sources are capable of displacing a large chunk of the electric power sector, particularly the types of renewable sources like wind and solar that could be installed in vast open land like the original question asked. However, the oil and gas resources that are the subject of the ANWR debate are largely not powering electricity generation, and as such renewable energy sources cannot easily displace most of the uses of the oil and gas.

The issue with thinking ‘why don’t we not drill and instead just invest in renewable energy’ is that in today’s world, there are lots of uses of energy that can only be served, or at least can only be served optimally, by oil products. For example, renewable fuel replacements for jet fuel are not very promising on a one or two generation timescale and 43% of industrial heating applications require temperatures (above 750 degrees Fahrenheit) that cannot be met by electric means or renewable heating technologies. And regarding the millions of cars on the road, the most pervasive and entrenched oil use in daily life, the looming transition to electric vehicles is taking a long time for a reason– not the least of which is that gasoline’s energy density remains unmatched to deliver power in such a safe, economical, and space-efficient manner. Indeed when analysts or journalists speculate about the world using up all of the oil, what they’re really talking about is the transportation sector because other sectors already largely utilize other fuel types. So when considering where renewable energy can replace fossil fuels, it is important to note that the transportation sector and industrial sector are powered 95% and 72%, respectively, by oil and gas, and that there are sometimes technological, institutional, and infrastructure-related reasons for that that go beyond price and availability.

That said, we are experiencing the eventual shift of some energy uses away from fossil fuels– notably in the transportation sector– but many of these shifts will take time and money to convert infrastructure. Many continue to study and debate whether we’ll be able to convert to 100% renewable energy without the aid of fossil fuels (with some concluding it’s possible, others that it’s not), and if so how far away are we from such an energy landscape. Even considering that it will take 10 years from passing of legislation to beginning of actual ANWR oil production, the American energy mix is only expected to change so much in the next few decades (see the Energy Information Administration forecast for renewable energy, natural gas, and liquid oil fuels below), and for better or worse fossil fuels look to be a part of that mix.

Source

The most significant area in which renewable energy can continue to make headway is the electricity generation sector, the sector that is most suited for renewables even though they only account for 17% of total generation as of 2017. In the meantime, though, fossil fuels like oil and gas will play a crucial role in the energy markets and the potential windfall of resources laying readily underground will continue to be seen as valuable to oil and gas companies (though it is important to ask whether, in the midst of increasing availability of shale oil, will the energy markets need the ANWR oil or will the oil companies even want to gamble on the risky and expensive play).

Part 2: But theoretically, how much renewable energy would need to be installed to account for the energy that would be extracted from ANWR?

All that said, though, for the sake of the academic exercise originally asked, let’s ignore the differences between fuel types and assume that by leaving all the oil and gas from the 1002 Area in the ground and instead installing renewable energy sources (i.e., wind and solar farms) we can extract the same amount of energy for the same needs.

The 2008 DOE report estimated between 1.9 and 4.3 billion barrels of crude oil would be extracted in a developed ANWR. This amount of oil can be converted to between 10.5 and 23.9 quads. The peak extraction according to the DOE report would end up being between 867 and 2,464 gigawatt-hours (GWh) per day.

The 1998 USGS Survey pegged the technically recoverable pegged the technically recoverable natural gas at between 3.48 and 10.02 TCF, which easily converts to between 3.48 and 10.02 quads. Because the DOE report did not break down how much of the technically recoverable natural gas would actually be economical to extract, we’ll assume for simplicity’s sake that it all will be extracted (there’s enough uncertainty in the estimates in all of the USGS and DOE numbers that we need not worry about exactness, but rather make the estimates needed to get an order of magnitude estimate). Without any estimates about the rate of extraction expected from the natural gas, we’ll make a very back-of-the-envelope estimate that it will peak proportionally with oil and reach a maximum rate of 274 to 990 GWh per day.

Adding the cumulative crude oil and natural gas extracted from the 1002 Area would be between 14.0 and 33.9 quads— an amount of energy that would find itself somewhere between the total 2016 U.S. consumption of coal (14.2 quads) and petroleum (35.9 quads). Adding the peak rate of oil and gas extracted from ANWR would imply the total peak of oil plus natural gas of between 1,140 and 3,454 GWh per day (we’re again playing fast and loose with some natural gas assumptions here). This range of rates for the peak energy being pumped into the total U.S. energy supply will be the numbers used to compare with renewable energy rather than the cumulative energy extracted.*

*The reason for this is because it is the best basis of comparison we have to the renewable nature of solar and wind. Why is that? At first glance it would seem that once the cumulative fossil fuels are used up that the installed renewables would then really shine as their fuel is theoretically limitless. However that would be an oversimplification, as every solar panel and wind turbine is made from largely non-renewable sources and the technologies behind them have a limited lifespan (about 25 years for solar panels and 12 to 15 years for wind turbines). As such, every utility-scale renewable energy plant will need replacing in the future, likely repeatedly over the decades. So while the renewable energy sources will not dry up, it is still important to look at the sources from a daily or yearly capacity basis instead of cumulative energy production. Additionally, energy (whether oil or renewable energy) is not extracted and transported all at once, that process takes time. Because of this, energy markets center around the rate of energy delivery and not the cumulative energy delivery.

So given our target range of 1,140 to 3,454 GWh/day, how much solar or wind would need to be installed?

Solar

The reader who asked this question comes from prime solar power territory, so let’s start there. In 2013, the National Renewable Energy Laboratory (NREL) released a report on how much land was used by solar power plants across the United States. With regards to the total area (meaning not just the solar panels but all of the required equipment, buildings, etc.), the generation-weighted average land use was between 2.8 and 5.3 acres per GWh per year, depending on the type of solar technology used. Using the most land-efficient technology (2.8 acres per GWh per year using increasingly common technology that tilts the solar panels to track the sun throughout the day), this amount of solar power would require about 1,166,000 to 3,530,000 acres, or about 4,700 to 14,300 square kilometers, of land.

Source

For reference, in the sun-bathed state of New Mexico, the largest city by land area is Albuquerque at 469 square kilometers. Given that, to equal peak potential oil output from the 1002 Area of ANWR woudl required solar power plant installations with land area about 10 to 30 times greater than Albuquerque. With the whole state of New Mexico totaling 314,258 square kilometers, the amount of land required for solar installations would be between 2 to 5% of New Mexico’s entire land area (put another way, the lower end of the land-requirement range is the size of Rhode Island and the upper end of the land-requirement range is the size of Connecticut).

Wind

Wind energy is set to take over as the number one American source of renewable energy by the end of 2019, a trend that is likely to continue in the future. One reason for the increasing capacity of U.S. wind power in the electric power sector is its ability to be installed both on land and in the water (i.e., onshore wind and offshore wind). Depending on whether the wind power installed is onshore or offshore, the efficiency, cost, and land-use requirements will vary.

NREL also conducted studies of the land-use requirements of wind energy. For both onshore and offshore wind installations, based on the existing wind projects studied, the wind power generating capacity per area (i.e., the capacity density) comes out to an average of 3.0 megawatts (MW) per square kilometer. As with the solar power land-use requirements, note that this figure goes beyond the theoretical space required by physics but includes all required equipment and land-use averaged across all projects.

Source

Operating at 100% capacity, that 3.0 MW per square kilometer would translate to 72 megatwatt-hours (MWh) produced per square kilometer each day. However utility scale wind power does not operate anywhere near 100% due to the prevalence of low wind speeds and changing directionality of winds, among other reasons. NREL’s Transparent Cost Database indicates that offshore wind operates at a median capacity factor of 43.00%, while onshore wind operates at a median of 40.35% capacity. Accounting for these figures, the land use of offshore wind energy comes out to 31.0 MWh per square kilometer per day, with onshore wind energy averaging 29.1 MWh per square kilometer per day. To reach the 1,140 and 3,454 GWh per day from peak-ANWR-oil would thus require about 33,000 to 100,000 square kilometers of area for offshore wind energy and about 35,000 to 107,000 square kilometers of land for onshore wind energy.

Using the same references points as with solar, wind energy resources would require an area roughly between 71 to 228 times the size of Albuquerque, between 11 and 34% the size of New Mexico, or a land-use requirement between the sizes of Maryland and Kentucky. It might seem jarring to realize just how much more land would be required for wind energy than solar energy, but multiple papers appear to support the notion that total land needed for utility-scale wind energy requires as much as six to eight times more land area than utility-scale solar energy on average. Indeed, the land-use required by renewable sources is one of the biggest costs of the energy at this time. If we’re willing to accept nuclear power as a source of clean, though not renewable, energy, then the technology currently outperforms them all by leaps and bounds– requiring 7 to 12 times less land than the same amount of solar power. But obviously nuclear power comes with its own set of political and environmental challenges, furthering the sentiment that there is not one and only one energy that will ever check all of the boxes and meet all of our needs.

Part 3: How would the costs of that scale of renewable energy sources compare with the previously discussed costs of drilling in ANWR?

Considering these results for the amount of land required by solar or wind energy resource to equal the peak oil and gas output of drilling in ANWR, the true scale of the potential energy resources underground the Alaska region really becomes clear. Further, it becomes clear just how difficult it would be to offset all of that potential energy by building utility-scale renewable energy generation. But the remaining question is how would the costs (both financial and environmental) of drilling in ANWR compare with the costs of the same capacity of renewable energy generation?

Source

 

Economically, the government (both state and federal) is only set to really profit from the drilling in ANWR because the area is government-owned and the money paid by the oil companies to lease the land for oil exploration would go directly to the government and because the government would also take a royalty on the profits made from said oil (a method to raise revenue also looking to be repeated in the sale of offshore drilling in almost all U.S. coastal waters). So while there will always be some degree of money provided to the government from renewable energy sources (e.g, through taxes), the land being used for our hypothetical vast solar or wind farms must come from the sale of government-owned land to provide the same sort of government revenue injection as drilling in ANWR. With wind power, at least, federally leasing for offshore wind farming has started to become somewhat common, though from 2013 to 2016 that only generated $16 million for the leasing of more than one million acres.

In terms of the noted benefits of helping U.S. energy trade by reducing the amount of oil that would need to be imported, the same can be said for a comparable amount of renewable energy– if that renewable energy is offsetting the import of fossil fuels, say for the electric power sector, then an equal effect on U.S. energy trade would be achieved.

In terms of the rough cost to install that amount of renewable energy, we can estimate total costs based on the levelized costs of energy (LCOE), which compares different methods of electricity generation based on costs to build, maintain, and fuel the plant over the lifetime. If we ignore the economic benefits that renewable energy sources enjoy from tax credits, the regionally-weighted LCOE’s of solar and wind power generation sources entering service in 2022 are 73.7 cents per MWh and 55.8 cents per MWh, respectively (compared with 96.2 cents per MWh for nuclear and 53.8 to 100.7 cents per MWh for natural gas, depending on the type of technology used). Compared with the total ANWR costs to extract of $123 billion to reach the 14.0 and 33.9 quads equivalent, the cost for solar would be between $3.0 billion and $7.3 billion and the cost for wind would be between $2.3 billion and $5.5 billion (again emphasizing the uncertainty in how much oil/gas is actually under ANWR as well as the very rough-estimate nature of these cost estimates). These numbers are just for the generation, not to mention the cost for transmission and distribution. However, with state-of-the-art renewable energy technology, it’s important to note that the costs are constantly decreasing and these estimates ignored the current tax credits allotted for renewable energy installations.

While renewable energy sources are seen as more environmentally friendly due to being carbon neutral, there are some environmental effects that cannot be ignored. Any energy source that takes up land is potentially displacing wildlife and using water and other resources. Further, just because the energy source is carbon neutral does not mean that the manufacturing, materials transportation, installation, or maintenance of those renewable plants are without emissions. Solar cells are also known to use some hazardous materials in their manufacturing. Regarding wind energy, extensive studies have had to be conducted on the danger wind turbines pose to birds, bats, and marine wildlife, though largely the conclusions of those studies has been that the impacts to such wildlife is low. Large wind turbines have also caused some concerns of public health regarding their sound and visual impact, but careful siting and planning is able to mitigate these concerns. So while the environmental effects of these renewable source are not nonexistent, they do appear to be much more manageable and avoidable than those of drilling for oil and gas.

Source

Conclusion

Even with the caveat that’s necessary to repeat throughout this post that all the numbers and calculations this analysis is based on are best-guess estimates and averages, much can be gleaned from looking at the results all together. Especially when you consider that the technologies involved for all discussed energy sources are constantly improving and each can be optimized for a particular region (such as using solar energy in lieu of wind energy in particularly sunny areas), the answer of how to best answer the energy future questions of the United States and the world is always going to be a strong mix of energy sources. There is no silver bullet, even among renewable energy resources, but rather heavy doses of appropriate renewable energy sources and nuclear energy sources will need to be mixed with the responsible use of fossil fuels for immediately visible future. Since the United States is quite unlikely to go cold turkey on fossil fuels overnight, the continued supply of crude oil products is going to be necessary for the time being. And the potential costs of largely relying on foreign imports to meet that demand are going to be feared by government and industry leaders alike. As such, it can be of no surprise that the massive resources of oil and gas underneath ANWR have been a continued focus of politicians and the oil industry for decades. However, none of that is to dismiss the legitimate environmental concerns the opponents have with sacrificing one of the last true areas of untouched wilderness in the United States to the predominantly-financial-based goals of drilling proponents, and if indeed the U.S. oil markets can prosper without drilling then that needs to be seriously considered.

The debate of whether or not to drill in ANWR is surrounded with so much uncertainty, along with passion on both sides. Because of this, the answer of what to do is not clear cut to many. The best thing you can do is educate yourself on the issues (I highly recommend a thorough read of the links in the ‘sources and additional reading’ section, as so much has been written about this topic that there is an unbelievable amount of information to learn) and stay informed as it evolves. Like it or not, drilling in ANWR is an inherently political debate and that affords all U.S. citizens the right, even the duty, to take your informed opinion and be active with it– call your Congressional representatives, join in the debate, donate to action groups. While the opening ANWR land for leasing to oil companies in the recently passed tax bill was the most significant action in this policy debate in years, the lengthy nature of the legislature and leasing process assures that the matter is anything but settled.

Sources and additional reading

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Deconstructing Units of Energy into Pizza, Fly Push Ups, and Grenades

When looking at energy use in everyday life situations, it is easy to overlook what the units used actually mean. When getting the electric bill in the mail, most people will simply compare the kilowatt-hours from last month to this month and note if their bill has gone up or down. When buying a new energy-efficient dryer, you know the fewer watts used the less energy it will be. The same mental comparisons are used all the time by people who do not have to deal with energy extensively– such as with the horsepower of a car or the calories in a sandwich.

However, it is all too common for people to forget the real significance of and differences between various units of measure related to energy and power use once they pass their high school physics class. Newscasters will constantly use kilowatts and kilowatt-hours as if they’re interchangeable (they’re not). Writers will misrepresent statistics online as if the difference between megawatts and gigawatts are not massive (they are).



For those of us that work in the energy industry, these numbers are much more tangible and easy to understand. However that does not describe a majority of citizens who are having these statistics thrown at them all the time, so this article will serve as a reference and allow you to re-up your energy statistics literacy.

The Basics

Energy vs. Power

The cardinal sin when dealing with energy units is confusing energy and power, a mistake that is unfortunately one of the most common as well. Even in mainstream news articles, it is not uncommon to see the total energy used for something to be listed in watts or vice versa (e.g., this article quotes the rate of energy use of a soccer stadium in kilowatts per hour, which you will shortly understand to be nonsensical if taken literally). So clearing up the confusion here is top priority.

The technical definitions of energy and power, according to the Energy Information Administration (EIA), are as follows:

Energy: The capacity for doing work as measured by the capability of doing work (potential energy) or the conversion of this capability to motion (kinetic energy)

Power: The rate of producing, transferring, or using energy, most commonly associated with electricity

Put simply, energy is the total work that is done while power is the rate at which that work is done. This concept can still be a bit tricky, so the easiest way to keep it straight is through metaphors. As one example, you can think of the relationship between energy and power as water flowing from a hose to a bucket. The volume of water that has been added to the bucket at any given point is comparable to the total energy use, while the rate that the water is flowing from the hose into the bucket can be considered the power. Another useful metaphor is to consider power to be the speed a car travels along a highway, while the total distance traveled would be the total energy. The main point is to think of power as a rate that is occurring with time (gallons of water per second, miles per hour) while the energy can then be thought of as that rate multiplied by the amount of time to get the total quantity (gallons of water per second times total seconds = total gallons of water, miles per hour times total hours = total miles driven).

To bring it to real world applications of energy and power, think of a light bulb in the lamp of your living room. The light bulb might be rated at 60 Watts, which is the power rating. 60 Watts is the rate of energy use of the bulb, and if you leave it operating for 2 hours then the total energy use is 60 Watts times 2 hours or 120 Watt-hours. Watt-hours, often divided by 1,000 to be expressed in kilowatt-hours, are the total energy use you will see come up on your monthly power bill (for more real-world applications of power and energy calculations, see the recent blog post on the energy used in various Thanksgiving turkey cooking methods).

Once you understand the difference between energy and power, you will start to see them used improperly all too often.

SI units vs. Imperial units vs. every other type of unit

To anyone who has to deal with the variety of units available to measure the same quantity, it can seem very confusing and unnecessary. Certainly it would be easier if everything and everyone used the same units and no conversion was needed. Unfortunately, that is not the world we live in for a variety of reasons– everyone has seen or heard how hard it has been to try to get the metric system adopted in the United States.

The reality is that there are many different units because these units originated at different times, by different people/industries, for different uses. The development of the metric system during the French Revolution was the first attempt to create internationally agreed upon units. Prior to that time, the world was a much larger place and it was not uncommon for units that even carried the same name to vary in actual measurement depending on where you were and who you asked. As science and trade expanded with the ever-shrinking global stage, units became more and more standardized until the International System of Units (SI) was created in the mid-20th century. These units are standard and widely accepted across the scientific landscape, no small victory for unit standardization.

Even with that success, however, many industries were already set in their way. For example, even though the automotive industry could use the widely accepted wattage to describe the power of an engine, people already understood horsepower in the context of a car. Because of the inertia and history of units like this, the implementation of the SI system did not take off in all sectors. While this may have been the easiest choice for those industries, it leaves the layperson with an alphabet soup of units and abbreviations to wrap their head around. Hopefully this article will do a small part to clearing that all up.

Prefixes

Another important part of the tangled web of units, particularly among SI and metric units, is the use of standard prefixes. Prefixes are used to take a standard unit and modify it by a power of ten. A familiar example would be the difference between a meter and a kilometer. Kilo- is the standard prefix for a multiplier of 10^3 or 1,000, which is why a kilometer equals 1,000 meters. These types of prefixes, summarized in the table below, can be applied across all sorts of units and the meaning is always the same– look at the power of ten multiplier and apply it to the unit.

The prefixes at the extreme of either end (such as yotta- and yocto-) are rarely used because they are so large/small that they are not needed to describe real, tangible energy/power quantities you’ll come across. The ones that are commonly used include giga-, mega-, kilo-, milli-, and micro-, and in fact some of the units described in the below tables will have those prefixes because the power-of-ten-adjusted units are more commonly used in certain applications than their base units.

Units to know

Energy

With all that background out of the way, we can look at 24 various units used to measure energy. Some of these are more common and will be familiar to most people, others are more niche and relate to specific industries or fields of study, while others still are rarely used but are still interesting to consider. Again keep in mind you may run across more units made up of the measures below combined with one of the prefixes above– simply use the prefix multiplier to modify the designated unit in the below table.

This first table will list these energy-measuring units, from smallest to largest, along with the manner in which they are typically used, the qualitative fundamental equivalence by definition, and the standard quantitative reference.

Table 2: Units of Energy Across Industries and Applications

UnitAbbreviationTypical useFundamental equivalenceStandard Reference
electronvolteVUsed by astronomers to measure energy of electromagnetic radiation, as well as to describe the difference in atomic/molecular energy states.

Also used by particle physicists to measure mass (based on E=mc 2 )
Amount of energy one electron acquires from accelerating through one volt1.602 x 10^ -19 Joules
RydbergRyUsed by chemists and physicists to claculate the energy levels in that are absorbed or emitted as photons as electrons move between energy levels of a hydrogen atomGround-state energy of an electron in the Bohr model for the hydrogen atom13.605693009 eV
HartreeEhUsed in calculating energy of molecular orbitsThe electic potential energy of the hydrogen atom in ground state (and thus double E h )27.211 eV
ergergNot commonly used today, but can still be found in old European scientific papersAmout of energy used when a force of one dyne is exerted over one centimeter 100 nanojoules
jouleJUsed in electricity, mechanics, thermal energy, and other basic sciences on a small scaleAmount of energy transferred to an object when a force of one newton acts on the object in the direction of its motion through a distance of one meter (i.e., one Newton-meter)As the SI unit of measurment for energy, considered the base use unit of all energy and is the common reference for other units of energy
foot-pound forceft*lbUsed to describe muzzle energy of a bullet in small arms ballistsAmount of energy transferred to an object when applying one pound of force over a distance of one foot1.35581795 Joules
thermochemical calorie**cal thUsed in chemistry to describe the energy released in a chemical reactionAmount of heat/energy needed to raise the temperature of 1 gram of water 1 o C (at 17 o C)4.8140 Joules
gram calorie**calUsed in chemistry to describe the energy released in a chemical reactionAmount of heat/energy needed to raise the temperature of 1 gram of water 1 o C (from 14.5 to 15.5 o C)4.8155 Joules
British thermal unitBTUUsed as a common unit of energy content by industry and analysts to compare energy sources or fuels on an equal basisAmount of heat/energy needed to raise the temperature of one pound of water by 1 o F1,055 Joules
Watt-hourWhUsed commonly in electrical applications Amout of energy used when one Watt of power is expended for one hour3,600 Joules
food Calorie, or kilocalorie**kcalIn common practice, nutritional calories are referring to these kilocalories (or Calorie, capitalized) as a means to measure the relative heating/metabolizing energy contained within a foodAmount of heat/energy needed to raise the temperature of 1 kilogram of water 1 o C (from 14.5 to 15.5 o C)1,000 thermochemical calories
gram of TNTg of TNTUsed to compare the relative size of explosions based on their release of energyAmout of energy in the explosive yield of one gram of Trinitrotoluene (TNT)4,184 Joules
(The real use of a gram of TNT would result in a range of energy outputs between about 2,700 and 6,700 Joules, so the actual conversion was somewhat arbitrarily defined as 4,184 Joules or exactly 1 kilocalorie)
megajoulesMJUsed to describe the energy content of liquefied petroleum gas (LPG) and natural gas in the context of gas heaters in buildingsOne million times the amount of energy transferred to an object when a force of one Newton acts on the object in the direction of its motion through a distance of one meter (i.e., one Newton-meter)1.0 million Joules
horse-power hourhphUsed in railroad industry to describe a performance-use basis when companies lend locomotives to others (e.g., Railroad A lent Railroad B a 4,000 horsepower locomotive to use for 2 hours, Railroad B now owes Railroad A a payback favor of 8,000 horsepower-hours)Amount of work that can be done (or energy that can be expended) by a horse over one hour2.686 x 10^6 Joules
kilowatt-hourkWhThe common unit of measure used as a billing unit for electricity delivered to consumersAmount of energy if a constant power of one kilowatt is transmitted for one hour3.6 x 10^6 Joules
kilogram of hard coalkg of hard coalUsed within the coal industry to compare the energy output of other fuel types to the output of a standard measure of coalAmount of energy emitted when burning one kilogram of coal7,000 kilocalories
ThermthmUsed by natural gas companies to convert volume of gases to its equivalent ability to heatAmount of heat energy from burning 100 cubic feet of natural gas100,000 BTU
gasoline gallon equivalentGGEUsed to compare the cost of gasoline with other fuels that are sold in different units for internal combustion enginesAmout of energy equivalent to that found in one liquid gallon of gasoline5.660 pounds of natural gas
gigajoulesGJUsed on a global scale to compare the amount of energy used by different nations over given time periodsOne billion times the amount of energy transferred to an object when a force of one Newton acts on the object in the direction of its motion through a distance of one meter (i.e., one Newton-meter)1.0 billion Joules
ton of TNTton of TNTUsed to describe the energy released in an explosionAmount of energy released in the detonation of a metric ton of TNT4.184 Gigajoules
barrels of oil equivalentBOEUsed by oil and natural gas companies (and analysts of those industries) that have access to both fuel types to describe the overall energy content of their reserves in a simple, single numberAmount of energy equivalent to that found in a barrel of crude oil (42 gallons); for natural gas, the conversion is to about 6,000 cubic feet of natural gas5.8 million BTU*
Ton of coal equivalentTCEUsed to describe very large amounts of energy output on a national or global scale with coal as the reference pointAmount of energy generated from burning one metric ton of coal0.697 tonne of oil equivalent (according to World Coal Association)
0.700 tonne of oil equivalent (according to International Energy Agency)
tonne of oil equivalentTOEUsed to describe very large amounts of oil or natural gas, either in terms of trade and transportation or natural production/consumptionAmount of energy equivalent to that found in one tonne (i.e., a metric ton, or 1,000 kilograms) of crude oil7.33 BOE (according to SPE)
41.868 GJ (according to OECD)
10.0 kcal (according to IEA)*
quadquadUsed by the Department of Energy and others in the field to discuss the total energy production and use across the globeEqual to exactly 10 15 BTU, i.e., one quadrillion BTU (quad for short)1,000,000,000,000,000 BTU

*These values are approximate because different grades of oil/gas have slightly different energy equivalents, and thus different agencies/bodies sometimes use slightly different measures of them.

**It’s important to note the difference between calories and Calories– Calories with a capital C are the nutrtional Calories everyone is familiar with counting on diets. These Calories are actually known as kilocalories and are 1000 thermonuclear calories, so do not mix up Calories and calories…

To make some more sense of this array of units, both massively large and incomprehensibly small, the following table puts the units into some more context. In this table, you’ll find a real-world example of what can be done with a single unit of that energy measurement, how many Joules it equates to for comparison’s sake, and the multiplier needed to get from the previous unit of energy to that one.

Click to enlarge

Power

The same exercise can be done for units of power (or rate of energy over time), as there are just as many different units for various industries, applications, and technical necessities. For power, we’ll focus on 17 of the more commonly used units– though remember you might come across all of them modified by the previously discussed prefixes.

Again, this first table will list all the power-measuring units, from smallest to largest, along with the manner in which they are typically used, the qualitative fundamental equivalence by definition, and the standard quantitative reference.

Table 4: Units of Power Across Industries and Applications

UnitAbbreviationTypical useFundamental equivalenceStandard Reference
erg per seconderg/sNot commonly used today, but in old scientific papers could be used to express power on an atomic scaleAmout of power used when a force of one dyne is exerted over one centimeter in one second100 nanowatts
milliwattmWUsed to measure the power needed by very small electrical components, such as small lasers to read CDsEqual to one thousandth of a Joule per second, or the work/power needed to hold an object's velocity constant at one meter per second against a constant force of one thousandth of a Newton0.001 Watts
dBmdBmUsed as a measure of power in wires in radio, microwave, and fiber-optic networksdBm is measured as the decibals relative to one milliwatt on a logarithmic scale, where the dBm of a power P in millwatts equals 10 x log(P)Not applicable because of the log-based scale. While 1 dBm is about 1.3 milliwatts, 50 dBm is 100 Watts and -50 dBm is 10 nanowatts.
Foot-pounds per minuteft*lb/minCommonly used as a mesaure of power in the foot-pound-second (FPS) unit system, which was the most common scientific unit system in English publications until the mid-1900s. The work done to apply a force of one pound-force over a linear dispalcement of one foot over the course of a minuteConsidered the base use unit for power in the FPS system, others reference the foot-pound per minute
kilowatt-hour per yearkWh/yEnergy consumption of some household appliances is often expressed based on the kilowatt-hours used over the course of a year given certain assumptions (kWh/y of a washing machine based on 180 standard cleaning cycles). While this may appear to be an energy unit and not a power unit, the time component of hour of kWh and the year cancel out to leave you with a measure of power-- which is what this measure really is, an understandable way to compare the power rating of various appliances Based on the assumptions given by the particular appliance label, each additional kWh/y is another expected kilowatt-hour to show up on your power bill over the course of an entire year with typical appliance use1 kilowatt-hour per year divided by 8,760 hours per year, or about 0.114 Watts
British Thermal Units per hourBTU/hOften used as the power rating for furnaces and other large heating systemsAmount of power needed to raise the temperature of one pound of water by 1 o F over the course of an hour1,055 BTU/hr divided by 3,600 seconds/hr, or 1055/3600 Joule/second which equals about 0.293 Watts
WattWUsed as the basic measurement of electrical power in small household-sized applicationsEqual to one Joule of energy per second, or the work/power needed to hold an object's velocity constant at one meter per second against a constant force of one NewtonAs the SI unit of measurement for power, considered the base use unit of all power and is the common reference for other units of power
kilocalories per hourkcal/hUsed to measure the metabolic rate of the human body, that is the amount of Calories your body will burn per hour doing various activities (e.g, exercising, sleeping, etc.)The amount of work needed to increase the temperature of one liter of water by 1 o C over the course of an hour1,000 calories per hour
calories per secondcal/sUsed by chemists when describing the rate of heat/energy transfer in chemical reactionsAmount of power needed to raise the temperature of 1 gram of water 1 o C (at 17 o C) over the course of 1 second4.184 Watts
Metric horsepowerPSUsed for advertising in the same applications as mechanical horsepower but in countries who use the metric system (often leading to confusion and mixing up the units, though the official horsepower ratings of engines are typically conservative enough that it's not overpromising power0Equal to the power required to raise a mass of 75 kilograms over a distance of one meter in one second75 kilogram*meters per second
Mechanical HorsepowerhpUsed to measure the output shaft of an engine, turbine, or motor in applications from cars and trucks down to chain saws and vacuum cleanersWhen invented by James Watt (inventor of the steam engine), it was derived by calculating the average work a pony at a coal mine could do in a minute and then increasing that by 50 percent33,000 foot pounds per minute
Electrical horsepowerhp(E)Used in the United States for the nameplace power output capacity of electrical motorsIntended to be equivalent in use to the mechanical horsepower, but is defined as exactly 746 Watts746 Watts
kilowattkWTypically used to describe power output of engines, motors, and other machinery. The work done to apply a force of one thousand pounds-force over a linear dispalcement of one foot over the course of a minute1,000 Watts
Tons of refrigerationTRUsed to rate the power of commercial refrigeration systemsThe power needed to freeze a short ton of water at 0 o Cover a 24 hour period12,000 BTU/hr
Boiler horsepowerhp(S)Used to denote a boiler's capacity to deliver steam to a steam engineEqual to the thermal energy rate required to evaporate 34.5 pounds of fresh water at 212 o F in one hour33,475 BTU/h
megawattMWUsed to describe the power used by very large electical equipment and vehicles, such as warships, super colliders, electric trains, or large commercial buildingsThe work done to apply a force of one million pounds-force over a linear dispalcement of one foot over the course of a minute1,000,000 Watts
gigawattGWDenotes the power output of large power plants and electrical capacity on a national scaleThe work done to apply a force of one billion pounds-force over a linear dispalcement of one foot over the course of a minute1,000,000,000 Watts

Again, a useful way to make sense of all these power units is to give them more meaningful context. The next table shows some of the real world examples of these different levels of power output, converts them all to Watts for the sake of comparison, and the multiplier between two consecutive units.

Click to enlarge

Conclusion

Armed with the knowledge of these units of energy and power, you’ll be well prepared to tackle statistics anew– you’ll have useful context for how much energy was in the recent 5,000 barrel oil spill on the Keystone Pipeline (using the above information, we can calculate that 5,000 barrels of oil is over 30,000 Gigajoules– or equivalent to the average annual electricity consumption of over 700 American households), or you’ll also have not so useful (but fun!) context for the energy content of a gallon of gasoline (the same as over 127 slices of large cheese pizza or 30 kg of TNT).  Either way, being literate in your scientific and energy-related units will make you a more informed consumer of the news– if only everyone editing the news could do the same and stop using ‘Watts per hour’!

Sources and additional reading

A Megajoule or MJ Probably Isn’t What You Think: Elgas

Aqua-calc: Conversions and Calculations

Arkansas State Energy Profile: Energy Information Administration

Ask Trains from December 2007: Trains Magazine

Atomic Units: Nature

Barrel of Oil Equivalent: Investopedia

Blast effects of external explosions: Isabelle Sochet

Bluetooth range and Power: Electronics Stack

Brief history of the SI: National Institute of Standards and Technology

British Thermal Units (BTU): Energy Information Administration

By gum! Chewing to power your hearing aid: CNBC

Calorie: Encyclopedia Britannica

Choose the right charger and power your gadgets properly: Wired

Coal conversion statistics: World Coal

Coal equivalent: European Nuclear Society

CODATA Recommended Values of the Fundamental Physical Constraints

Conversion factors: Organization of Petroleum Exporting Countries

Electron Volt: Universe Today 

Elephants: San Diego Zoo

Energies in Electron Volts: Hyper Physics

Energy Conversion Calculators: Energy Information Administration

Energy Examples: Genesis Now

Energy Units: APS Physics

Energy Units and Conversions: Dennis Silverman

erg: WhatIs.com

Eu Energy Labels: What does kWh/Annum mean?

Exploding Laptop Batteries

Foot-Pound Force Per Minute: eFunda

Frequently Asked Questions: Energy Information Administration

Glossary: Energy Information Administration

Horsepower-hour: Collins Dictionary

Horsepower: Encyclopedia Britannica

How Hard Does It Hit? Jim Taylor

How Horsepower Works

How Many Calories Are Burned By Coughing? LiveStrong

How Many Calories Do You Burn Doing Everyday Activities?

How Many Flies Would It Take To Pull A Car? Neatorama

How much electricity does a solar panel produce? Solar Power Rocks

How much energy do my household appliances use? Energy Guide

Is it really worth my time to eat that last grain of rice?

Joule: techopedia

Launching satellites: Science Learning Hub

Measuring energy: IEEE 

Metric Conversions

Nanotechnology Introduction: Nanotechnology Now

NIST Guide to the SI: National Institute of Standards and Technology

Nonconventional Source Fuel Credit

One Calorie is Equivalent to One Gram of TNT In Terms of Energy: Today I Found Out

Papa John’s Nutritional Calculator

Physical Phenomena: University of Sydney

Physlink

Projectiles, Kinetic/Muzzle Energy and Stopping Power

Report of the British Association for the Advancement of Science

Rydberg: Wolfram Research

Rydberg Constant: National Institute of  Standards and Technology

Rydberg Unit of Energy: Energy Wave Theory

The Adoption of Joules as Units of Energy: FAO

Tonne of coal equivalent: Business Dictionary

Tonne of oil equivalent: Organization for Economic Cooperation and Development

Turning sweat into watts: IEEE

Understanding Energy Units: Green Building Advisor

Unit Conversion Factors: Society of Petroleum Engineers

Unit converter: International Energy Agency

USB Flash Drives: AnandTech

watt-hour (Wh): WhatIs.com

What’s a hartree? National Institute of Standards and Technology

What is a Joule? Universe Today

What is a GJ? Natural Resources Canada

What is a Ton of Refrigeration: Power Knot

What is a Watt, Anyway? Building Green

What is a Watt Hour? SolarLife

What is resting metabolic rate?

Why Do We Use a Dumb Unit to Measure Explosions? Gizmodo

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Advice for Effective Public Comments in the Federal Rulemaking Process

Having spent a few years earlier in my career entrenched in the rulemaking process behind a number of regulations from the Department of Energy concerning appliance standards, I am able to empathize with the teams of analysts at federal agencies that are tasked with receiving and addressing the feedback that comes in during public comment periods. During every rulemaking process, there are real humans reading every single public comment received (even when those comments number in the thousands), cataloging the specific concerns from the stakeholders, conducting research and analysis regarding the points that were brought up, and ultimately responding to those comments– either by detailing why the existing analysis already addresses the comment or, if the stakeholder comment has successfully done its job, adjusting the analysis during the next round of the rulemaking to account for the issues brought up in the comment.

While submitting a comment in response to the federal rulemaking process can seem intimidating, the truth is that every rulemaking process receives comments from every sort of stakeholder, large and small, with the widest range of expertise on the topics possible (see previous article on how the rulemaking process works and what the function of the public comment period is here). Those involved in the regulatory process know to expect multi-page comment submissions with loads of data and testimonials from powerful trade associations or advocacy groups, but it is also common to receive more pointed and specific comments from concerned private citizens who don’t have any experience in the relevant industry, but simply have their own opinions and concerns. The beauty of the public rulemaking process, however, is that every single comment must be summarized in the next step of the rulemaking, along with a response as to how the new analysis addresses the concerns, no matter who submits it. With that in mind, regardless of whether you are representing a larger organization or just your personal interests as a citizen, what follows are six methods you can employ that will ensure your comment most effectively influence the federal rulemaking process.



1. Be accurate

This piece of advice should go without saying, but rest assured I have found that it needs to be said. If a comment submitted to the federal agency is found to have a basic inaccuracy in it, then the rest of the comment on that topic will be called into question and it can potentially carry less weight. An underlying inaccuracy in the comment will make responding to, or dismissing, the whole comment all too easy. So while it may be overly obvious, if you hope to make an impact on a regulatory rulemaking then be sure to verify the accuracy in everything you say.

 

2. Be specific with issues and provide alternatives

If you want your comment to be addressed specifically in the analysis, be sure to include specifics in the comment. Don’t say that something would be detrimental to businesses– state exactly what the detriment would be and why. Don’t state that a discussed technology would not be technologically or economically feasible– state what technology would be feasible and note what exactly is preventing the original technology from being so. Don’t state that a pricing analysis is unrepresentative of the market– describe how and why the analysis is off.

The point is that if the federal agency is given a vague reason for why the analysis is ‘bad’ or ‘off,’ but not given any specifics, then there is nothing tangible to address. The rebuttal to the non-specific comment can simply be to restate the original analysis and reasons behind it. However if a specific reasoning and alternative is instead provided, then you are giving the federal agency something meaty to address. The subsequent analysis must either move towards your alternative or give details about why that alternative is incorrect. But if your alternative is airtight and there are not holes to poke in it, then you will likely find success in shifting the analysis behind the rulemaking.

 

3. Address the issues the rulemaking asks about– but don’t be restricted to those topics

When reviewing a rulemaking document, whether in the early stages with a Request for Information (RFI) or later during the Notice of Proposed Rulemaking (NOPR) stage, you will often find specific issues called out on which the agency behind the rulemaking is seeking comment. These issues are numbered for ease of finding them, and sometimes (but not always!) listed in a single place at the end of the notice. If you do not see a list at the end of the notice, be sure to go through the document carefully to find them all in-line, where they’ll appear as in the example below.

Source

When the agency is pointing out these specific issues on which it requests comment, that shows where the most impact of a comment might be received. These are the issues that they might have the least amount of information (or they have information but recognize it’s outdated) concerning, or where they recognize there is considerable debate. Regardless of the reason, all comments on each of these numbered issues end up getting aggregated to get a clear picture of the available information and data before a decision on the direction of the rulemaking is made (though it is important to note that it is not decided by what received the most comments, but rather the accuracy and quality of the comments outweigh the quantity of comments received on an issue). If your position on the rulemaking is related to any of these specifically identified issues, make sure to frame your comment in direct response to the question asked (it even helps to note by number which issue your comment is addressing).

With all of that said, you should not feel that the identified issues are the only ones eligible for response or that the agency will not put equal weight behind comments regarding other aspects of the analysis. You might have comment or information on a topic on which the agency wasn’t focused or didn’t realize was controversial. So while it is important to fit your comments into the box of the issues identified by the notice if they are relevant to those issues, do not feel restricted to those topics. You just might be the only one to bring up this new issue, influencing the next stage of the rulemaking to address it more specifically.

 

4. Include hard data

The best way to back up your comment and encourage a specific response in the next stage in the analysis is to include your own data as evidence. Perhaps you think this data was overlooked by original analysis, or maybe you think the data that was included originally does not tell the whole story. Either way, if your data supports a change in the analysis and a different conclusion, then providing the full set of that data in your public comment is the best way to influence the rulemaking. Doing so will force the next stage of the analysis to either include that data (and thus changing the course of the analysis towards your desired outcome) or at the very least will require the next stage of the analysis to refute your data.

 

5. Include sources

Similar to including your own hard data, crucial to an effective public comment is providing evidence towards your points. Providing a comment that breaks down to be essentially subjective is unlikely to be effective, but if you can demonstrate your points with sources– e.g., scientific studies, experimental results, industry information, or marketing analysis, then the comment will make a bigger splash. The more you can ‘show’ your point rather than ‘tell’ it, the more substance and weight your comment will have.

 

6. Offer to follow up

An under-utilized strategy with regards to public comments on the public rulemaking process is making yourself available to the federal agency. The public comment stands on the record as a written statement of your thoughts and concerns on the rulemaking, but in commenting you can also offer to discuss the points further with the agency pursuing the rulemaking. Doing so may result in you being interviewed in the next fact-finding stage of the analysis, or you might also be invited to the next public meeting on the rulemaking to discuss your concerns further. These conversations can be the most valuable tool for really getting your point across and making sure the agency understands the basis of your viewpoint. Written comments only have the opportunity for a single back and forth between commenter and government agency, but conversations allow for the complete back-and-forth required for full understanding between the parties.

 

Conclusion

While there is no guarantee any single public comment will change the course of a particular rulemaking, if you follow these six guidelines then there is a greater chance that your comment will be well-received by the agency and carry the weight of consideration it deserves. If you have any additional questions on this process, don’t hesitate to reach out in the comments below or by contacting me directly.

Additional Reading

A Guide to the Public Rulemaking Process: Office of the Federal Register

Frequently Asked Questions: Office of Information and Regulatory Affairs

Notice and Comment: Justia

Notice-and-Comment Rulemaking: Center for Effective Government

Policy Rulemaking for Dummies

Rulemaking Process and Steps to Comment: The Network for Public Health Law

Tips for Submitting Effective Comments: Regulations.gov

 

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Best from “Today in Energy” in 2017

Among the wide array of regular articles the Energy Information Administration (EIA) releases, as detailed in this post on navigating EIA’s data sets , one of the most varied and interesting is the Today in Energy (TIE) series of articles released every weekday. According to EIA, TIE articles “provide topical, timely, short articles with energy news and information you can understand and use.”   

What makes TIE particularly compelling to read each day is that the topics it covers range across the spectrum of energy-related topics. Where most of the other reports released by the EIA are restricted to a specific fuel type or survey of consumers, TIE articles bring all of these topics from across EIA into relevant, digestible, and fascinating briefs to give a broad spectrum of information to its readers.



Further, TIE articles feature both stories that are relevant and important to current events (e.g., Hurricane Irma may cause problems for East Coast energy infrastructure) and stories that provide useful background information that can be referenced for years to come (e.g., Crude oil distillation and the definition of refinery). Not only that, but keeping up with TIE articles is a great way to keep up with other EIA publications as well, such as when articles such as the Annual Energy Outlook, International Energy Outlook, or Short-Term Energy Outlook are posted, TIE often includes an overview of some of the relevant conclusions of those articles and a link to read the full version.

To prove how valuable TIE articles can be for all these reasons, I’ve picked a sampling of 13 of my favorite TIE articles thus far in 2017 that are particularly interesting and demonstrate the cross-cutting topics offered by TIE. The ones I’ve chosen are based on the topics I find the most engaging, as well as the graphics that are the most clever and elegant.

1. EIA’s AEO2017 projects the United States to be a net energy exporter in most cases

January 5, 2017

Released the same morning as the Annual Energy Outlook 2017 (AEO2017), this article demonstrates the tendency of TIE to alert the readers of the latest EIA publications, while also providing a good overview to new readers as to what AEO2017 is and what the main takeaways from the report were.

2. Canada is the United States’ largest partner for energy trade

March 1, 2017

Utilizing the latest data from the U.S. census bureau, this article details the energy imports/exports between the United States and Canada broken out by U.S. region and fuel type and demonstrates TIE articles on the topic of trade. Most interesting is the graph showing the difference in electricity trade over the years from each of four U.S. regions.

Source: Energy Information Administration

3. U.S. energy-related CO2 emissions fell 1.7% in 2016

April 10, 2017

This TIE article from April breaks down carbon dioxide (CO2) emissions data, from the Monthly Energy Review, from 2005 to 2016 by both emitting fuel and industry, while also introducing carbon intensity as a metric and shows the progress made in reducing energy-related carbon intensity over the previous decade. As climate change heats up as an issue in domestic politics, industry, and foreign affairs, this type of window into U.S. CO2 emission data can prove invaluable.

4. Most U.S. nuclear power plants were built between 1970 and 1990

April 27, 2017

I chose this article because it provides a fascinating chart that shows the initial operating year of utility-scale generation capacity across the United States, broken out by fuel type, to demonstrate the relative age of each source of electricity generation and, in particular, the relative old age of the U.S. nuclear generating capacity, while also showing the explosion of non-hydroelectric renewable generation since the turn of the century.

Source: Energy Information Administration

5. American households use a variety of lightbulbs as CFL and LED consumption increases

May 8, 2017

An example of a TIE article getting into the use of energy inside of U.S. homes, this piece takes information from the 2015 Residential Energy Consumption Survey (RECS) to show how residential lighting choices have been trending in the face of increased regulation and availability of energy-efficient lighting technologies, highlighting the differences depending on renter vs. owner occupied, household income, and whether or not an energy audit has been performed.

6. More than half of small-scale photovoltaic generation comes from residential rooftops

June 1, 2017

Utilizing data from the Electric Power Monthly, this article breaks out the use of small-scale solar power systems based on the geographic location and type of building, highlighting the rapid rise these systems have experienced in the residential sector, as a great example of renewable energy in the residential sector.

7. Dishwashers are among the least-used appliances in American homes

June 19, 2017

Again taking data from RECS, this TIE article provides insights on the frequency that certain appliances are in American homes, how often they go unused in those homes, pervasiveness of ENERGY STAR compliant appliances, and other data regarding residential energy use of appliances. This article also includes a plug for the 2017 EIA Energy Conference that was to be held a week after its publication, again showing how good of a job reading TIE articles daily can do of making sure you know the latest happenings at EIA.

8. Earthquake trends in Oklahoma and other states likely related to wastewater injection

June 22, 2017

A reason I find this TIE article particularly interesting is that it goes beyond just the energy data collected by EIA and synchs with outside data from the Earthquake Catalog to show additional effects of energy production in the environment. This kind of interplay of data sources demonstrates how powerful EIA data collection can be when analyzed in proper context.

9. Monthly renewable electricity generation surpasses nuclear for the first time since 1984

July 6, 2017

I highlight this TIE article for two reasons. First, the graphic below showing the monthly generation of nuclear compared with the cumulative generation of renewable energies—and the highlighting of 2016-17 particular—is really illuminating. This graph is a great demonstration of the power of data visualizations to convey the data and the message of that data. Second, the reason behind that graphic—that monthly renewable generation surpassed nuclear generation for the first time in over three decades—is a remarkable achievement of the renewable energy sector, showing the trending direction of the U.S. fuel mix going forward.

Source: Energy Information Administration

10. California wholesale electricity prices are higher at the beginning and end of the day

July 24, 2017

This TIE article was identified because of how interesting the topic of wholesale electricity prices varying throughout the day can be. As net metering and residential production of electricity increases across the United States, this will be a topic those in the energy fields will want to keep a keen eye on.

11. Among states, Texas consumes the most energy, Vermont the least

August 2, 2017

Grabbing data from the State Energy Data System, this TIE article presents a graphic displaying the most and least overall energy use as well as the most and least energy use per capita among the 50 states and the District of Columbia. Using color to demonstrate the relative consumption and consumption per capita creates a pair of really elegant visuals.

Source: Energy Information Administration

 

12. Solar eclipse on August 21 will affect photovoltaic generators across the country

August 7, 2017

As everyone was scrambling to find their last minute eclipse glasses, this TIE article detailed where, and how much, the total solar eclipse of August 2017 was to diminish solar photovoltaic capacity and an assessment of how local utilities will be able to handle their peak loads during this time (a nice follow up TIE article on this also looked at how California dealt with these issues on the day of the eclipse, increasing electricity imports and natural gas generation).

Source: Energy Information Administration

13. U.S. average retail gasoline prices increase in wake of Hurricane Harvey

September 6, 2017

Another example of TIE addressing energy-related current events, this article not only provides the information and analysis of the effect that Hurricane Harvey had on retail gasoline prices, but it also provides the context of why the effect was being felt, how it compared to previous hurricanes, and what could be expected moving forward.

 

 

If you’ve been sufficiently convinced that Today in Energy articles would be an engaging read to start the day, you can sign up for an email subscription by following this link.

 

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Navigating the Vast EIA Data Sets

The Energy Information Administration (EIA) is an independent arm the Department of Energy (DOE) that is tasked with surveying, analyzing, and disseminating all forms of data regarding energy in the United States. Further, EIA is a politically isolated wing of the DOE– meaning it is there to provide independent and factual data and analysis, completely independent from the partisan decision makers in Washington or the political inclinations of those in charge of at the top of DOE. Because that is the case, you can be confident the data put out by EIA is not driven by any agenda or censored in favor of a desired conclusion.

Thus for anyone with even a passing interest in the national production and use of energy, EIA really is a treasure trove of valuable information. However, those who are unfamiliar with navigating the EIA resources can easily get overwhelmed by the vastness of the data at their fingertips. Additionally, even seasoned veterans of the federal energy landscape might find it difficult to find the exact piece of data for which they are digging within the various reports and data sets made publicly available on the EIA website. So regardless of your experience level, what follows is a brief guide to what type of information is available as well as some advice as to how to make the best use of your time surfing around EIA.gov.



Types of data available

One of the really fabulous things about the EIA data sets is that they cover every kind of energy you can imagine. The energy categories you can focus into include, but are not limited to, the following:

Within these energy categories, you can look at the trends of production, consumption, imports/exports, and carbon dioxide emissions going back years (oftentimes even decades) and also modeled as a forecast into the coming years. Most data sets will have tools to automatically manipulate the data to change between units (e.g., total barrels of oil vs. barrels of oil per day), or even manipulate data trends (e.g., go from weekly data to 4-week moving averages to 10-year seasonal averages). Depending on the type of data, these numbers are regularly updated weekly, monthly, and/or yearly. If there’s a topic of particular interest, there’s a good chance there’s a report with the data on it being released at regular intervals– some of the more prominent reports are highlighted below.

Regularly updated reports

EIA releases a regular stream of reports that serve to update the publicly available data at given intervals. Some of the more prominent reports are listed below, and they are typically used to update all of the energy categories previously mentioned:

  • The Monthly Energy Review (MER) is a fairly comprehensive report on energy statistics, both from the past month and historically back a number of decades. Published during the last week of every month, the MER includes data on national energy production, consumption, and trade across petroleum, natural gas, coal, electricity, nuclear, renewables– as well as energy prices, carbon dioxide emissions, and international petroleum.
  • The Short-Term Energy Outlook (STEO) is another monthly EIA report, this one released on the first Tuesday following the first Thursday of the month. The STEO includes data on much the same topics as the MER, with the inclusion of some international energy data, and it also includes monthly and yearly projections for the rest of the current year and all of  the next year based on EIA’s predictive models. The inclusions of these forecasts makes for particularly useful data sets for anyone who might be trying to stay a step ahead of the energy markets. Also of particular interest for statistically-minded people out there is a regular comparison of numbers between the current STEO forecast and the previous month’s forecast. These comparisons show which way the model shows data to be trending, with the more significant ones called out in the report and noted with reasoning behind the changes.
  • The Annual Energy Outlook (AEO), like the STEO, provides modeled projections of energy markets– though the AEO focuses just on U.S. energy markets, models these annual forecasts long-term through the year 2050, and is released every January. The other aspect of the AEO that makes it particularly interesting is that its modeled forecasts, in addition to a reference case forecast, include different assumptions on economic, political, and technological conditions and calculate how those various assumptions might affect the outlook. For example, the 2017 AEO includes projections based on high economic growth vs. low economic growth, high oil price vs. low oil price, high investment in oil and gas resources and technology vs. low investment, and a projection that assumes a complete roll-back of the Clean Power Plan.
  • The International Energy Outlook (IEO) provides forecast energy market data consistent with the AEO, but regarding the international energy market through 2040.
    • With forecasts in both the STEO and the AEO, an understanding of exactly what is meant by the forecasts is imperative. The forecasts and projections do not necessarily reflect what a human prognosticator within EIA thinks could, should, or will happen– rather it demonstrates what the predictive models calculate given the best possible and unbiased inputs available. This difference is a subtle one, but if you ever find yourself questioning “does the person behind this report really think this is going to happen?”, recognize that some nuance exists and the reason you are skeptical might have not yet been able to be statistically included in the model.
  • The State Energy Data System (SEDS) is published once annually and breaks down national energy use, price, spending, and production by sector and by individual states. Within each of these categories, you can also break down the data by energy type (e.g., coal vs. natural gas) and by primary energy use vs. electric power generation. Having this granularity is useful to further dig into if certain energy trends are regional, restricted to certain climates, or are in response to specific state policies.

While they are not necessarily releasing new and specific data on a regular basis, two other EIA articles of note are worth pointing out because of the interesting stories and analyses they tell:

  • Today in Energy (TIE) comes out every weekday and gives a quick and readable article with energy news, analyses, and updates designed to educate the audience on the relevant energy issues. TIE frequently features graphs and charts that elegantly demonstrate the data in an easy to understand but also vastly elucidating way. One of the real advantages to reading TIE each day, though, is they often include tidbits from all the previously mentioned regularly updated reports, as well as other major releases or EIA conferences, enabling you to keep up with the newest information from EIA (click here for a post on the best TIE articles of 2017 to get you started).
  • This Week in Petroleum (TWIP) is an article that comes out every Wednesday that is very similar to the TIE articles, but focuses on the world of petroleum specifically and provides crucial insights on topics such as drilling, oil company investments, retail prices, inventories, transportation of crude and refined petroleum products, and more.

If any of these regular reports are of interest to you, you can sign up to get email alerts anytime these (or a number of other) reports are released by EIA by visiting this page. If you don’t know which reports you’d want but you want to keep an eye on what EIA is putting out, you can also simply subscribe to the “This Week at EIA” list that will once a week send you an email to notify you of ALL the new EIA productions from that week.

Finding specific data

While keeping up with all the regular reports from EIA is immensely useful, what brings many people to the EIA website is the search for a specific piece of data. You might want to see a history of average gasoline prices in a certain region of the country, find the projection of how much solar capacity is expected to be added in the next few years, track how much petroleum product is being refined in the Gulf Coast, or countless other facts and figures. Below you’ll find a few strategies you can employ to track down the information you seek.

Navigating the menus

EIA.gov has a useful menu interface through which you can usually navigate to your desired dataset easily.

Source: Homepage of EIA.gov
  • The “Sources & Uses” drop down will be where you can navigate to data sets about specific fuel sources and energy use;
  • The “Topics” drop down highlights the analysis on data by EIA as well as economic and environmental data; and
  • The “Geography” drop down is where you can navigate data by state or look at international data.
Source: Homepage of EIA.gov

Navigating from these menus is fairly self-explanatory, but let’s walk through the example of finding the recent history of gasoline prices in the Gulf Coast region of the United States. Gasoline is a petroleum product, so we would click on “Petroleum & Other Liquids” under the “Sources & Uses” menu.

Once on the “Petroleum & Other Liquids” page, the information we’re interested in would be under the data menu with the “Prices” link.

Source: Landing page for EIA.gov/petroleum

You’ll then see a listing of various regular releases of petroleum product price reports and data sets. Since we’re interested in Gulf Coast gasoline prices, we’ll click the third link for “Weekly retail gasoline and on-highway diesel prices.”

Source: EIA’s Petroleum and Other Liquids Prices

Clicking on this report will bring up the below interactive table. The default view will be to show U.S. prices averaged weekly. The time frame can be adjusted to monthly or annual prices (we’ll keep it at weekly). The location of the prices can be changed to allow viewing of data by region of the country or by select states and cities (we’ll change it to the Gulf Coast). The interactive table then displays the most recent week’s data as well as the previous five weeks (note: for ‘gas prices’ as is most often reported in the media and related to people filling up the gas tanks in their cars, we’re interested in the row titled ‘Regular’).

Source: EIA’s Weekly Retail Gasoline and Diesel Prices

If you’re interested in going further back in time then shown in the interactive table, the ‘View History’ links can be clicked to bring up an interactive table and graph going as far back as EIA has data (1992, in this case), shown below. Alternatively, if you want to have the raw data to manipulate yourself in Microsoft Excel, then click the ‘Download Series History’ link in the upper left (I’ll download and keep this data, perhaps handy for later in this post).

Source: EIA’s Weekly Gulf Coast Regular All Formulations Retail Gasoline Prices

Note in the above interactive chart there is the built-in abilities to view history by weekly/monthly/annual data, to download the source data, or the adjust the data to be a moving average or seasonal analysis.

If you find a page with the type of information you’ll want to reference regularly or check in on the data as they update, be sure to bookmark the URL for quick access!

STEO Custom Table Builder

Another useful tool is the STEO Custom Table Builder, which can be found here. The Custom Table Builder allows you to find all of the data that is included in the monthly STEO report (e.g., U.S. and international prices, production, and consumption for petroleum products, natural gas, electricity, coal, and renewable energy; CO2 emission data based on source fuel and sector; imports and exports of energy commodities; U.S. climate and economic data broken down by region; and more). This data can be tracked back to 1997 or projected forward two years on a monthly, quarterly, or annual basis. All you need to do is go to the Custom Table Builder, shown below, and select the options you wish to display.

Source: EIA’s Custom Table Builder

As an example, let’s use the STEO Custom Table Builder to determine the projected of how much solar power capacity in the near term. Solar would fall under the ‘U.S. Renewable Energy’ category, so click to expand that category, then expand the ‘Renewable Energy Capacity,’ and you’ll see the STEO has data for data for the capacity of large-scale solar for power generation, large-scale solar for other sectors, and small-scale solar for other sectors.

Source: EIA’s Custom Table Builder

Select all the data relevant to solar data, select the years you want (we’ll look at 2017 thus far through the end of 2018), and what frequency you want the data (we’ll look at monthly). Then hit submit, and the following will be the custom table built for you.

Source: EIA’s Custom Table Builder

Note: The forecast data is indicated in the Custom Table Builder with the numbers shown in italics. The above data was pulled before the September 2017 STEO was published, so the projections begin with the month of August 2017.

For this example, we’ll want to then download all the data to excel so the total solar capacity can be added up and analyzed. Click the ‘Download to Excel’ button at the upper right to get the raw data, and with a few minutes in Microsoft Excel you can get the below chart:

Source of Data: EIA.gov, pulled on September 10, 2017

This graph, made strictly from STEO Custom Table Builder data, shows the following:

  • As of July 2017, large-scale solar generation capacity was only 0.3 GW outside of the power sector and 23.7 GW, while small-scale solar generation capacity was 14.8 GW.
  • Together, solar power capacity in the United States added up to 39.1 GW as of July 2017.
  • By the end of 2018, total solar power capacity is projected to rise to 53.7 GW (an increase of 14.5 GW, or 37%), according to the EIA’s August 2017 STEO.

Search function

Using a search bar on some websites can be surprisingly frustrating, but luckily the EIA search function is very accurate and useful. So, I have found that, when in doubt, simply doing a search on EIA.gov is the best option.

Perhaps I want to track the amount of petroleum products in production on the Gulf Coast. This information is not in the STEO report, so the Custom Table Builder won’t be of use. And maybe I don’t immediately see how to navigate to this specific information on the menus. I would type into the search bar the data I’m seeking as specific as possible—‘weekly gulf coast refiner gasoline production’:

Source: Homepage of EIA.gov

Doing the above search yields the below results, of which the first one looks like just what we need.

Source: EIA.gov

Click on that first link, and ta-da! We’re taken to the weekly gasoline refinery report for the Gulf Coast (referred to as PADD 3). Again, you see the options here to look at the history back to 1994 both on a weekly and a 4-week average basis, use the chart tools to analyze moving averages or seasonal analyses, or download the data to utilize in your own way.

Source: Weekly Gulf Coast Refiner and Blender Net Production of Conventional Motor Gasoline

Contact experts

As a last resort, the EIA website offers resources to contact should you have questions or issues navigating the data. The people behind the EIA data are civil servants who are intelligent and very dedicated to their job and making sure you get the accurate and relevant information you need. So in a pinch, head to the Contact Us page and find the topic on which you need help from a subject matter expert.

If you want an alternative to going straight to the people at EIA, however, feel free to contact me as well and I’d be happy to try and help you track down information on EIA.gov as well. Use any of the contact methods mentioned in the Contact Page of this site, or leave a comment on this post.

Using the data

I have found that it is not at all an exaggeration to say that the world (of energy data, at least) is at your fingertips with EIA’s publicly available data. To demonstrate, I’ll walk through a quick example of what you can find.

If we take the previously gathered weekly data for Gulf Coast gasoline prices and gasoline production, we can plot them on the same graph:

Source of Data: EIA.gov, pulled on September 10, 2017

By taking advantage of the publicly data on EIA’s website, we can notice some trends on our own. In the above, there is a drastic increase in Gulf Coast gasoline prices, coincident with a large decrease in Gulf Coast refiner production of gasoline that bucks the month-long trend of production generally increasing. This is a curious change and would prompt investigation as to the reason why. Luckily, several of EIA’s Today in Energy articles already points out this trend and offers explanation—all related to the effects of Hurricane Harvey on the Gulf Coast petroleum systems (Article 1, Article 2, Article 3). Just goes to show that one of the best way to stay abreast of trends and information in the energy world is to follow EIA’s various reports and analyses.

 

Updated on September 28, 2017

 

 

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Policy Rulemaking Process for Dummies

Calling this article “for dummies” is tongue-in-cheek, because the inner workings of government and the development of public policy are shrouded in mystery for most people. However this mystery does not persist because the process is too difficult for the average person to understand (my rant about how foolish it is that this part of the policy process is not taught in middle schools or high schools is for another day). In fact, the beauty of the rulemaking process is that it is designed to engage those outside the government world.

After getting personally involved in the rulemaking process to determine energy efficiency standards for various electronic products, I learned what occurred behind the curtains for these federal energy regulations– just how involved the process of determining these regulations were, how many different parties came into play, and how backed in data, testing, analysis, and public feedback these final regulations were. Many resources exist that explain the whole rulemaking process in more detail and completeness than I will, and a few of those resources can be found at the end of this post, but as someone who spent several years on the inside I will provide a brief overview of the process and a few insights I picked up along the way.



What is a Rulemaking?

A rulemaking is the process that is mandated for creating federal regulations, including the analysis of the effects of a potential regulation and the solicitation of public feedback along the way. Rather than having lawmakers themselves create the specific regulations for certain topics, Congress instead authorizes federal agencies to dive into the details and research, analyze, and dictate the final details of those rules. The regulations produced at the end of a rulemaking have all the effect of a law, and all existing federal regulations are listed in the Code of Federal Regulations (CFR). For anyone looking to find out the particulars of any federal regulation, the CFR is the repository to reference. Federal regulations cover a broad range of topics—from energy to telecommunications to patents and more, with these topics being listed in the CFR’s Table of Contents.

The Beginning of the Rulemaking Process

While the federal agencies, such as the Department of Energy (DOE) or the Environmental Protection Agency (EPA), are the main entities that control the rulemaking process, no regulations can be issued without proper statutory authority being first granted. Even though the regulations posted in the Federal Register (FR) are attached to Executive Branch agencies, the authority to issue these regulations comes from Congress. Each regulation proposed and ultimately issued has an authority section somewhere in the beginning so the reader can trace its history and why it was initiated.

Two types of authority—Left is where Congress passed a law to initiate a specific rulemaking proces (DOE’s regulation of the energy efficiency of metal halide lamp fixtures, 79 FR 7746); Right references the broad authority granted by Congress to regulate certain areas (EPA’s regulation of air pollutants, 82 FR 39712)

The Congressional authority for a rulemaking can either come from the law that first created the federal agency and dictated which areas it had jurisdiction to regulate (such as the above right, where EPA references the authority to regulate air pollutants from the general powers granted to EPA by Congress), or Congress can pass a law that specifically directs an existing agency to go through the rulemaking process and set regulations for a particular topic of interest (such as the above left, where DOE references the authority from a law that Congress passed instructing DOE to establish energy conservation standards for certain appliances by a given date).

Stepping Through the Rulemaking Process

Make no mistake about it—the rulemaking process for federal regulations is very long and in depth. Nothing is done haphazardly, with the people behind it conducting extremely extensive factfinding and analysis. The amount of cumulative effort that goes into regulating, for example, the energy efficiency of a lightbulb or ceiling fan is mindboggling. While the process behind each rulemaking could differ depending on the regulation’s history, complexity, urgency, importance, or politics, the generally expected process is outlined as follows:

Notice of Proposed Rulemaking

The Notice of Proposed Rulemaking (abbreviated as either NOPR or NPRM) is often the first official document published that announces the beginning of the rulemaking process. Included in the NOPR is a preamble detailing the goal of the rulemaking, the authority granting the agency the power, and the relevant dates and contact information for the rulemaking; the supplemental information section that discusses the initial framework, background data, preliminary analysis, and merits of the proposal; and a preview of what the regulation language would look like in the CFR. The NOPR is not the final regulation, but rather serves to inform the public about the initial findings of the analysis based on the preliminary information collected and provide the public stakeholders the opportunity to provide feedback on those findings (more on that later).

There do exist a couple of exceptions where the NOPR won’t be the first notice from an agency regarding the rulemaking process:

  • An agency might receive a petition for rulemaking from an interest group or member of the public, making the case for why a specific regulation is needed. The agency might then publish that petition in the FR to solicit comments on whether a rulemaking on that topic should be pursued.
  • Alternatively, an agency may, for particularly complex or critical rulemaking, choose to publish a preliminary document in the FR, such as an Advanced Notice of Proposed Rulemaking (ANOPR) or a Framework Document. The goal of publishing either of these documents would be to solicit public feedback earlier on in the information gathering and analysis to ensure the initial framework set up for analysis is headed in the right direction. Neither of these documents are mandatory, but when a potential regulation might have additional complications then the use of these early publications ensure those issues can be addressed thoroughly.
  • Lastly, there are times where an agency initiates a negotiated rulemaking. When this happens, the agency will invite the stakeholders and major players to meetings to try and reach an agreement on the terms of a proposed rule. These meetings will include representatives from multiple viewpoints on the topic, and if a consensus can be reached then the agency may endorse those terms as a basis for the proposed rule.

Comment Period

After a NOPR (or earlier preliminary document) is published in the FR, the agency will request comments from the public during an official comment period. These comments can be either in agreement or in opposition, and they can pertain to the rulemaking generally or to a specific part of the analysis. The typical comment period will last 30 to 60 days, though it can vary. More complex rules might have longer comment periods to allow stakeholders enough time to digest and respond to the proposed rulemaking, or the public can even request the comment period be extended if there are extenuating circumstances (though if the agency does not find there to be good reason to do so, they do not have to grant this request). Additionally, if the agency finds that comments received were not of the type and quality needed to move forward with the next stage of the analysis, the comment period can be re-opened. The agency might also find that the initial round of comments brought up new and complicated issues that requires further public comment. In these instances, the agency can open a second comment period to allow reply comments on the newly arisen issues, or alternatively the agency might publish a second NOPR instead of moving onto the Final Rule.

What is most important to remember about the comment period is that this is one of the best opportunities for you, as either a private citizen or a member of an organization, to directly impact and influence the regulations that will affect you.

Final Rule

After the completion of the NOPR, the agency will ultimately publish a Final Rule in the FR. The format of the Final Rule will look very similar to that of the NOPR, with the same general sections and analyses. However, the ‘Dates’ section will no longer dictate when the comment period will close—rather it will indicate the date that the new regulation is effective (generally within 30 days of publication).  The Final Rule now represents the new law of the land and will include a section of what changes need to be made to the CFR (as well as the effective date)—these changes can be a whole new section to the CFR, removing existing sections, or piece-by-piece edits to CFR text. This changing of the CFR text is the final step in the rulemaking process.

Congressional Review

In accordance with the Congressional Review Act, all Final Rules are subsequently reviewed by Congress. If both the House and Senate pass a resolution of disapproval of a regulation within 60 days (without Presidential veto), the Final Rule becomes void and cannot be republished in its existing state. Such overturning of Final Rules is typically uncommon, however, as Congress only successfully exerted this power one time from its inception in 1996 through 2016 (though the unique political climate in 2017 led to the Congressional Review Act to be successfully invoked 14 times, leading some to debate the merits of retaining this Congressional power and a bill proposed in the Senate to repeal it).

Despite the Congressional Review Act, the role of Congress in the rulemaking process is typically to simply grant the regulatory powers to the agencies, leaving the details and analysis to the experts employed by the agencies.  It would be naïve to think, however, that the final direction ultimately chosen at the end of a rulemaking was not influenced by politics. After analyzing and presenting all the facts on the table, the final direction resides with the priorities and policy preferences of the leaders of the agency and, by extension, the Executive Branch.

How you can participate

As stated earlier, one of the key components of a federal regulation that separates it from a law is the built-in mechanism to solicit feedback from the public. There are a few different ways this feedback is collected, each with their own advantages.

Public Comments

As mentioned earlier, after each NOPR, private citizens and interest groups alike are engaged to comment on the proposed rule, enabling them to directly affect the final regulations in a way not typical of all public policy. There are several primary goals of collecting these public comments:

  • They give citizens, interest groups, companies, and any other affected group the opportunity voice their position on the potential rule and how it might affect them by providing information the agency might not have been able to gather on its own;
  • They help the agency to improve the final regulations by considering this previously undiscovered information or vetting the information it did gather; and
  • They reduce the likelihood that stakeholders find issue with the regulations and bring those complaints to the courts.

To accomplish these goals, the continued engagement (both formal and informal) of the public is critical. Those who are submitting comments, though, should take note that the process dictated by what position receives the greatest volume of comments. Rather, the content of each comment is added into the public record of the rulemaking along with the data, expert opinions, and other facts. The comments are your opportunity to convince the agency that there is additional data to consider or new arguments to address. These comments can shift the direction of the rulemaking if they are factual, demonstrable, and convincing, as all comments made on the public record are then mentioned and specifically addressed in the subsequent publication stage—either agreeing with them or presenting reason to refute them. Later, I plan on writing a blog post that will give some tips and tricks on how to make public comments as effective as possible at influencing the rulemaking (update: read blog post on how to make effective public comments here).

Interviews

While preparing any of the public notices, the federal analysts might contact stakeholders (interest groups, affected companies, etc.) to be interviewed about the facts behind the regulation. Engaging in these conversations before the publication of the NOPR and Final Rule allows for a constructive and in-depth back-and-forth where the stakeholder can work to convince the analysts about their point-of-view. When these interviews occur, they are often the best opportunity for a stakeholder to convey their arguments and influence the rulemaking.

Public Hearings

Another way these key stakeholders are engaged by the rulemaking process is through public hearings. These hearings often occur after each NOPR or preliminary notice, though they are only required by certain agencies. The agency will specifically invite the key stakeholders to attend, though they are open to the public for anyone with an interest in the rulemaking. Public hearings are another opportunity where back-and-forth discussions can occur, both for the agency to explain the proposal and answer questions about the analysis that has been put forth and for the stakeholders to argue their cases in person. The other unique aspect of these public meetings is they allow for an on-the-record dialogue between the different stakeholders themselves, should there be disagreement among them.

Keeping Informed

If you want to keep up with potential new rulemakings that are of interest to you, the FR allows you to subscribe to customized daily updates. You can have all FR notices from a specific agency emailed to you every day they become available, or you can even subscribe based on keywords—regardless of which agency it comes from. To subscribe, create an account on federalregister.gov and then add subscriptions at this link.

Example of what an email from the Federal Register will look like if you subscribe to DOE notices

Additionally, at least once a year every agency publishes a regulatory agenda. This agenda will outline the planned regulatory and deregulatory actions for the coming season or year. If there is a particular agency whose regulations are of interest to you, follow this link to read the list of current regulatory items on the agenda.

 

Sources and Additional Reading:

A Guide to the Rulemaking Process- Prepared by the Office of the Federal Register

The Federal Rulemaking Process: An Overview– Congressional Research Service

Regulations and Rulemaking Process FAQ- Office of Information and Regulatory Affairs

Learn the Steps in the Federal Rulemaking Process

About the Rulemaking Process- United States Courts

Flowchart of the Federal Rulemaking Process- Citizen.org (this resource is more in depth than the title ‘flowchart’ will make you think—but a great, thorough resource)

From two specific federal agencies of interest to the topics in this blog:

Appliance & Equipment Standards: Department of Energy Regulatory Process

The Basics of the Regulatory Process: United States Environmental Protection Agency

 

Related Posts:

Federal Register Notice: Costs and Benefits of Net Energy Metering: Request for Information

Federal Register Notice: Test Procedure for Distribution Transformers: Request for Information

Article updated on October 10, 2017

 

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.