AES Corporation

New Source Performance Standards

May 13, 2014
•Introduction to AES

•Proposed NSPS for GHGs, Issues for Consideration

•Electrical system need for flexibility

•Market’s need for standardization 

Agenda

May 13, 2014 1
May 13, 2014 2

2

The AES Corporation 

May 13, 2014 2

• Fortune 200 global power 

company

• Operations in 21 countries 

on 5 continents

• 9 Utilities

• 37,761 MW’s of generation

• Serve 11 Million customers

• 25,000 global workforce

Improving lives by delivering safe, reliable and sustainable energy in every market we serve. 
May 13, 2014 3

 2,010 MW of gas fired utility boiler steam 

generation

 ~10% capacity factor and 75% service 

factor

 2013 – 1,340 lb CO2/MWh

Alamitos

 452 MW of gas fired utility boiler steam 

generation

 290 MVAR from synchronous condensers

 ~20% capacity factor and 80% service 

factor

 2013 - 1,290 lb CO2/MWh

- 430 MW + 290 MVAR

Huntington Beach

 1,356 MW of gas fired utility boiler steam 

generation

 ~5% capacity factor and 40% service 

factor

 2013 – 1,650 lb CO2/MWh

Redondo Beach

• 3,818 MW of critical generation in Western Los Angeles Reliability Area

• AES acquired the plants from Southern California Edison in 1998

• Commercial operations commenced between 1942 - 1969

• Once-through ocean cooling compliance date of 2020 for all units

• Phased repowering plan with natural gas fired CCGTs

AES Southland - California
Load following natural gas combined cycle power plants

• “flexible resources with the right operational characteristics in the right 

location”

Consistent rule referenced to standard set of conditions

• Efficiency and output dependent on ambient conditions

• Consideration of environmental constraints

• Turbine degradation and size

Proposed NSPS for GHGs

Issues for Consideration

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Regional and Local Electricity Markets and Systems are Fundamentally 

Changing as States and Utilities Move to Low Carbon Energy Systems

May 13, 2014 5

 Mandates Affecting Generation, Transmission and Distribution:

 33% RPS requirement by 2020; Legislators discussing increases up to 40% - 50%

 CO21990 levels by 2020  80% of 1990 levels by 2050

 Utility restrictions on out of State coal fired generation contracts “coal by wire”

 Ocean water cooling policy / Once-Through Cooling (OTC) phase-out

 Mandates for distributed generation, energy efficiency, demand response

 Electrification of transportation and goods movement

California’s Green Energy Objectives

 Increase in renewable resources and other loading order products changing system dynamics

 Transmission constrained densely populated coastal regions

 OTC replacement generation required to support local reliability

 End of nuclear: SONGS (2,250 MW) 2012, Diablo Canyon (2,200) 2025??

 Load characteristics shifting from industrial demandto residential and transportation

Need for System and Local Reliability

In California long-term power generation requirements can be characterized by tension 

between green energy goals and objectives and the need for system reliability

Existing infrastructure will not support or enable the desired future resource mix and demand
California’s Need for Generation Flexibility Starts in 2015

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Source: California Independent System Operator, 2013
CAISO Actual Net Load May 12, 2014

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• Fast start/stop capability

• Fast upward or downward ramp

• Maintain heat rate across wide operating capacity

• Start and stop multiple times per day

• Air cooled, limited water consumption

• Noise mitigation in densely populated area

AES CCGT Technology Solution:

Managing a low-carbon intensive grid

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Steam cycle design to access flexibility 

inherent in gas turbine

Simple single 

pressure design

330 MW in 10 

minutes

Ramp up: 110 

MW/minute with 

entire plant in service

Ramp down: 250 

MW/minute from full 

load

Shutdown: 5 

minutes from any 

condition 

Sacrifice heat rate 

to optimize flexibility
CCGT designed for operational objective

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FP-10 vs 3x1 MSG vs LMS 100

7,000

7,500

8,000

8,500

9,000

9,500

0 100,000 200,000 300,000 400,000 500,000 600,000

Net Site Output, kW

N

et Site

H

e

at R

ate (L

H

V), B

T

U/k

W-hr

FP-10

3x1 MSG

LMS 100

Projected Dispatch Range

1

ISO Conditions

New and clean

1,000 lb CO2/MWh
• Flexible and state-of-the art natural gas combined cycle power stations best fit 

for future grid

• Heat rate impacted by:

• Multiple starts/stops per day

• Need for voltage regulation and where unit is “parked” by ISO

• Turbine degradation

• Cooling technology

• Ambient conditions

• AES Huntington Beach CCGT net GHG emission rate 1,054 lb CO2/MWh

for projected operating profile under site specific conditions

• Smaller and more nimble CCGTs will be the foundation for greater RPS 

resulting in less total carbon mass emissions

• California, Oregon and Washington have set performance standard at 1,100 

lb/MWh for plants operating at greater than 60% capacity

NSPS should recognize paradigm shift

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 Exempt intermediate load-following natural gas combined cycle 

generation below an annual capacity factor less than 60%

 In the alternative, set the performance standard at 1,100 lb CO2/MWh

 Performance standard referenced to standard conditions

• Cooling technology

• Site constraints impacting heat rate

• Correction for ambient conditions

Recommendations for a revised NSPS

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