BL England (Upper Township)

February 28, 2019 update: RC Cape May Holdings has announced that it will withdraw its proposal for this project!  See the article in NJ Spotlight.

The state has issued a draft air permit for a new 447-megawatt natural-gas power plant at the B.L. Eng­land generating station, which would replace an exist­ing coal-fired unit at the facility in Upper Township. The owner of the plant, which was once viewed as one of the dirtiest in the state, agreed to shut down the coal unit in an administrative consent order several years ago with the state Department of Environmental Pro­tection that would resolve a series of air pollution vio­lations at the facility. The closing has been repeatedly extended by the state, the most recent occurring in 2014.

The $90 million project is awash in controversy and litigation, mostly because the plant will get its fuel from a new 22-mile natural gas pipeline (SJG – South Jersey Gas pipeline) through parts of the Pinelands, a route opposed by four former gover­nors and conservationists.

Assuming a 6,500Btu/KWh heat rate, a 447 MW com­bined cycle facility will burn approximately 69,700 Dth or approximately 67,224 Mcf (thousand cubic feet) of natural gas per day when operating at 100%. This amount is slightly more than just half the 125,000 Mcf per day (“Mcfd”) Daily Contract Quantity of the SA with SJG.

Comments from Pinelands Preservation Association members include the following information demon­strating that it is unnecessary to repower BL England:

  • B.L. England is not needed for reliable electrical service in the Pinelands
  • South Jersey Gas relies principally on a report by en­gineering consultants PowerGEM as evidence that the majority of electricity generated by a repowered B.L. England would be consumed in the Pinelands. Not only does the report rely on obsolete models of New Jersey’s electrical grid, but also the only way it can reach its conclusions is to make demonstrably false assumptions about the structure of New Jer­sey’s power grid, the manner in which system op­erators dispatch electricity over it, and (incredibly) the laws of physics.
  • In fact, five of B.L. England’s seven generat­ing units have been deactivated entirely and, for the past three years, one of the remaining units has been operating at approximately 60% of its capacity, while the other is operated less than 50% of the time, mostly on high demand days and only during the summer.
  • Nevertheless, the regional transmission operator PJM has not identified a single reliability issue for the Pinelands that is associated with this phasing out of B.L. England’s capacity.
  • While South Jersey Gas claims that electricity from B.L. England is particularly critical given the retire­ment of the Oyster Creek nuclear plant, PJM Inter­connection (PJM) acknowledged as early as 2014 that deactivating both Oyster Creek and B.L. Eng­land poses no reliability issues because “the mar­ket had already responded to the planned retire­ment of Oyster Creek by driving the construction of new natural gas plants in the service territory.”
  • In addition to more than 2,000 MW of new natural gas generation from plants built in West Deptford and Woodbridge, nearly 750 MW of new, cleaner generating capacity have come online in the service territory since the last time South Jersey Gas ana­lyzed the issue.
  • In fact, South Jersey Gas has repeatedly mischarac­terized reliability violations it claims are attributed to B.L. England’s retirement, in some cases even characterizing as reliability concerns violations that PJM determined would only occur should B.L. Eng­land NOT retire.
  • In other cases, the company presented violations of PJM’s “Generator Deliverability Test” as reliability concerns even though PJM itself admits that this test evaluates the system’s ability to operate at optimal economic efficiency and does not identify required reliability upgrades.

South Jersey Gas justifies the need to repower B.L. Eng­land in part on the basis of network upgrades that PJM identified in July, 2014 and which the company continues to mischaracterize as necessary to avoid reliability viola­tions caused by the plant’s retirement. In fact, PJM indicat­ed that many of the upgrades South Jersey Gas identified (which are now planned, funded or in construction) were required because of aging infrastructure issues that had nothing to do with B.L. England. Moreover, Atlantic City Electric acknowledged in testimony before the New Jer­sey Board of Public Utilities that the identified upgrades would be necessary even if B.L. England is repowered, “to maintain reliability during the process when the facility is offline” being retrofitted with new gas turbines.

It is also important to note, as Oil Change International has stated, that producing electricity from gas is cur­rently dirtier than coal-fired power because methane leakage along the gas supply chain more than doubles the lifecycle emissions of gas compared to just count­ing emissions from gas combustion. Repowering the plant with gas is worse for the climate than leaving it to burn coal.

It is estimated that this plant will emit about 1.3 MMt of CO2 per year and will leak/emit about 500 tons of methane. This will result in total GHG emissions of 1.34 MMt of CO2e annually. (These estimates are based on a comparison with the proposed Meadow­lands power plant as no information on the specific gas power technology to be used by BL England has been found.)

The Murphy Administration can stop this plant by using its authority to regulate and limit GHG’s and end the prac­tice of allowing applicants to purchase ozone credits.