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Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance
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DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014 Ungraded Jason Symonds, DNV GL-Energy October 1 st , 2015 Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance 1
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Transcript of Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance
DNV GL © 2014 SAFER, SMARTER, GREENER1 DNV GL © 2014 SAFER, SMARTER, GREENERDNV GL © 2014
Ungraded
Jason Symonds, DNV GL-EnergyOctober 1st, 2015
Learning to Walk Before Learning to Run:
First Steps Toward EPA’s Clean Power Plan Compliance
DNV GL © 20142
Agenda
Overview of finalized
Clean Power Plan (CPP)
rule
First steps toward CPP compliance
State compliance
plans
Clean energy incentive program (CEIP)
Proposed EM&V
guidelines
DNV GL © 20143
CPP interim and final targets
EIA forecast, table 18: http://www.eia.gov/forecasts/aeo/tables_ref.cfm
DNV GL © 20144
Final building blocks in CPP111(d) planning
EPA used three building blocks to determine state emission goals
Heat rate improvements
Increased NGCC dispatch
Renewables
EE removed from building blocks, but not from discussion
DNV GL © 20145
Mont
ana
North
Dak
ota
Wes
t Virg
inia
Wyo
ming
Nebr
aska
Kans
asMa
rylan
dKe
ntuc
kyIow
aMi
ssou
riIlli
nois
India
naMi
nnes
ota
Tenn
esse
eOh
ioUt
ahW
iscon
sinCo
lorad
oMi
chiga
nSo
uth
Dako
taSo
uth
Caro
lina
New
Mexic
oNo
rth C
aroli
naAr
kans
asLo
uisian
aPe
nnsy
lvania
Oklah
oma
Geor
giaTe
xas
Arizo
naAla
bam
aW
ashin
gton
Miss
issipp
iVir
ginia
Florid
aNe
w Yo
rkDe
lawar
eOr
egon
New
Ham
pshir
eNe
vada
Califo
rnia
Mass
achu
setts
New
Jerse
yCo
nnec
ticut
Maine
Idah
oRh
ode I
sland
-
200
400
600
800
1,000
1,200
1,400
1,600
1,800
2,000
Goa
l (lb
s./M
Wh)
State-by-state rate-based compliance targets
Mont
ana
North
Dak
ota
Wes
t Virg
inia
Wyo
ming
Nebr
aska
Kans
asMa
rylan
dKe
ntuc
kyIow
aMi
ssou
riIlli
nois
India
naMi
nnes
ota
Tenn
esse
eOh
ioUt
ahW
iscon
sinCo
lorad
oMi
chiga
nSo
uth
Dako
taSo
uth
Caro
lina
New
Mexic
oNo
rth C
aroli
naAr
kans
asLo
uisian
aPe
nnsy
lvania
Oklah
oma
Geor
giaTe
xas
Arizo
naAla
bam
aW
ashin
gton
Miss
issipp
iVir
ginia
Florid
aNe
w Yo
rkDe
lawar
eOr
egon
New
Ham
pshir
eNe
vada
Califo
rnia
Mass
achu
setts
New
Jerse
yCo
nnec
ticut
Maine
Idah
oRh
ode I
sland
-
200
400
600
800
1,000
1,200
1,400
1,600
1,800
2,000
Goa
l (lb
s./M
Wh)
DNV GL © 20146
First steps
Develop state compliance plans
Pursue CEIP
Review EM&V guidelines in context of current methodologies
DNV GL © 20147
State compliance plan timeline
Extension submission requirements:1. An identification of final plan approach(es) under consideration, including a description of
progress made to date 2. An appropriate explanation for why the state requires additional time to submit a final
plan by September 6, 2018 3. Demonstration or description of opportunity for public comment on the initial submittal
and meaningful engagement with stakeholders
State Compliance PlanTimeline20
16
10/1/2015WEEC Conference
2017
2018
2019
9/26/2018Final plan submittal deadline.
DNV GL © 20148
State compliance plan approaches
Emission Standards Approach
State Measures Approach
Rate-based
Mass-based
Mass-based
Single-state
Multi-state
Single-state
Multi-state
Single-state
Multi-state
Rate-based
Regan, Susan
Jason: in this picture, please change the hyphen on "single-state" to be on the line with "single" instead of on the second line with "state"
DNV GL © 20149
State compliance plans: Framework
Emission standards approach
Pro• Streamlined approach laid out by
EPA• Can use either rate-based or
mass-based target
Con• Not as flexible
State measures approach
Pro• Flexibility to include non-EGU
focused approaches (i.e., RPS, EERS, and utility and DSM incentive programs)
Con• More paperwork to demonstrate federal backstop
• Have to meet mass-based goals• State must pass laws in support
DNV GL © 201410
State compliance plans: Case study What are states doing around you? Regional greenhouse gas initiative– State-measures approach,
mass-based, multi-state Existing CO2 emission trading market Will new states join?– NJ was once in; may be back– VA has Dem. governor; recent Acadia
study gives green light– PA considering RGGI
http://www.sightline.org/research/graphics/north-american-carbon-pricing-started-with-rggi/
Examples already exist for multi-state carbon markets, but is it for everyone?
DNV GL © 201411
Clean energy incentive program (CEIP)
CEIP will provide opportunities for investments in renewable energy and demand-side energy efficiency that deliver results in 2020 or 2021.
In order for a state to participate in the program, it must include in its initial submittal, if applicable, a non-binding statement of intent to participate in the CEIP.
DNV GL © 201412
Clean energy incentive program (CEIP)
Renewables• For every two MWh generated, the project
will receive one early-action ERC from the state, and the EPA will provide one matching ERC
Energy efficiency• For every two MWh in end-use demand
savings achieved, the project will receive two early-action ERCs from the state, and the EPA will provide two matching ERCs
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CEIP: State/regional responsesArizona• 24% interim goal / 34% final goal
Southwest Power Pool• Leveraging potential regional scale
Pennsylvania• “We’re listening”
Michigan• “Policy make local”
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Energy efficiency and EM&V
Ratepayer-funded
programs• Rebates & loans• Technical
assistance• Education
Building energy codes
• Establish efficiency requirements for new/renovated buildings
State appliance standards
• Establish efficiency requirements for products not covered by federal government
Energy services
performance contracting
• Projects delivered by ESCOs and repaid through consumer bill savings
Volt/VAR optimizatio
n
• Efforts to improve grid efficiency
DNV GL © 201415
Energy efficiency and EM&V guidelines: Framework
EM&V guidelines
1. Methods 2. Metrics
and baselines
3. Reporting
4. Deemed savings
5. Independent
factors
6. Accuracy
7. Double counting
8. Effective useful life
9. Savings cycle
10. T&D adders
11. Interactive
effects
12. EM&V protocols
EM&V draft guidelines: http://www2.epa.gov/sites/production/files/2015-08/documents/cpp_emv_guidance_for_demand-side_ee_-_080315.pdf
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Energy efficiency EM&V guidelines: Case studyUtility clients wonder how current EM&V practices compare to draft guidelines
How much will states/utilities need to change EM&V approach to align with CPP?
Deemed savings and TRMs
Approx. 20 states developed TRMs
What about the rest?
Baselines
How will “common
practice baseline” impact programs?
Create “market average” for
baseline?
Timeframe & cycles for persistence/verification studies & reporting
savings
How does this line up with what utilities do currently?
DNV GL © 201417
Source: EIA, “Electricity Data Browser”
States that aren’t taking the first step
Electric sector annual CO2 emissions
16 states currently
suing EPA
Expect federal plan to begin implementation in 2018, if states do not submit plan
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Summarizing first steps
State compliance
plans
• If a state is not going to meet 9/26/2016 compliance plan deadline, extension is not a cake walk
CEIP
• Pursuing early-action credits gives states leg up toward compliance
EM&V proposed guidelines
• Guidelines won’t make or break CPP• May cause states/utilities to rethink EM&V
processes
DNV GL © 201419
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Thank you
Jason [email protected]
