PJM Economic Analysis of EPA s Proposed Clean Power Plan: State-Level Detail

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1 EPA s Proposed Clean Power Plan: State-Level Detail PJM Interconnection March 2, 2015

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3 Contents Purpose 7 Overview of Information Provided in Tables 7 State Load and Energy Cost... 7 Generation Output and Emissions... 8 Total Generation... 8 New Source Performance Standard 111(b) Resources... 8 Clean Power Plan 111(d) Resources... 8 Renewable Portfolio Standards and Energy Efficiency... 8 Emissions Rate Performance... 8 General Observations 9 Wholesale Energy Market and Load Energy Payments... 9 Regional versus Individual State Compliance... 9 Renewable Resource and Energy Efficiency Implications... 9 LMP and Load Energy Payments as a Proxy for Compliance Cost by State Delaware 10 Observations from the Emissions Rate Calculation Summary of Compliance Impacts to Delaware Illinois 18 Observations from the Emissions Rate Calculation Summary of Compliance Impacts to Illinois Indiana 26 Observations from the Emissions Rate Calculation Summary of Compliance Impacts to Indiana PJM P age

4 Kentucky 34 Observations from the Emissions Rate Calculation Summary of Compliance Impacts to Kentucky Maryland 41 Observations from the Emissions Rate Calculation Summary of Impacts to Maryland General Observations Michigan 49 Observations from the Emissions Rate Calculation Summary of Compliance Impacts to Michigan New Jersey 56 Observations from the Emissions Rate Calculation Summary of Impacts to New Jersey North Carolina 63 Observations from the Emissions Rate Calculation Summary of Impacts to North Carolina Ohio 70 Observations from the Emissions Target Calculation PJM Page

5 Summary of Impacts to Ohio Pennsylvania 78 Observations from the Emissions Rate Calculation Summary of Impacts to Pennsylvania Virginia 86 Observations from the Emissions Target Calculation Summary of Impacts to Virginia General Observations: West Virginia 94 Observations from the Emissions Target Calculation Summary of Impacts to West Virginia General Observations PJM P age

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7 Purpose This appendix to the PJM Economic Analysis of the EPA Clean Power Plan Proposal provides more granular information regarding the wholesale energy market impacts from the Clean Power Plan for the scenarios requested by the Organization of PJM States, Inc. Tables are provided for each state for each simulation year (2020, 2025 and 2029). The tables provide effects regarding 1) wholesale energy prices, 2) load energy payments, 3) in-state generation identified by major resource type, 4) load and modeled energy efficiency, 5) net carbon dioxide emissions position relative to the mass target and the value of that position based on implied prices for carbon dioxide emissions, and 6) resulting emissions rates from the mass-based simulations under different assumptions. The aforementioned effects are compared relative to the case based on assumptions used in the 2014 transmission planning case, for which we use the shorthand RTEP, in the tables below. The wholesale energy market effects from the OPSI requested scenarios are, by definition, going to be driven by the underlying assumptions in each scenario as well as the effects of the Clean Power Plan. Moreover, PJM did not examine the additional costs related to capital expenditure on renewable resources, energy efficiency or new combined-cycle gas resources. Consequently, the wholesale energy market impacts discussed below do not account for these capital costs, which may appear in retail electricity rates as determined by state commissions, nor do the results attempt to draw any conclusions on wholesale capacity market outcomes as they would affect wholesale costs and by extension retail rates. This appendix starts by providing an overview of the information in the tables to assist readers in locating and understanding the information in the tables. Next, general observations that apply to all states and across all scenarios are provided to highlight common results and themes. Finally, tables and general state-specific observations are outlined. Overview of Information Provided in Tables Each table by state and simulation year is separated into sections that are designed to make the data more accessible and grouped by themes. State Load and Energy Cost The first section in each table provides the total load across all OPSI-requested scenarios and for the 2014 transmission planning case for the indicated simulation year, absent any energy efficiency. The load-weighted average locational marginal price (LMP) by state and for the entire PJM region is shown to provide a comparison of the state LMP against the PJM LMP. Finally, load wholesale energy prices are provided, which are a function of the state load, energy efficiency and state level load-weighted average LMP. PJM P age

8 Generation Output and Emissions Total Generation This subsection provides total in-state generation across all OPS-requested scenarios and the 2014 transmission planning case and breaks down generation output by category: coal steam, natural gas combustion turbine and combined cycle, nuclear, renewable resources and other resources which include oil and gas steam units and hydroelectric resources. New Source Performance Standard 111(b) Resources This subsection breaks out gas-fired combined-cycle resources that are modeled as being subject to section 111(b) New Source Performance Standards and not subject to Clean Power Plan Compliance. This information shows how generation and associated emissions from these resources affect total generation and emissions compliance. This information provides the capacity factor for these resources to show how much they run relative to existing resources. Clean Power Plan 111(d) Resources This section of the table shows the generation output of resources subject to 111(d) compliance, total emissions from these resources compared to the mass target calculated for the state in that year, the net emissions position, CO 2 prices, and the implied value of the net emissions position at the implied price of CO 2. Resources subject to 111(b) and generation or emissions from natural gas combustion turbines are not a part of this calculation. For the regional, mass-based scenarios, the implied value of the net emissions position is an indication of potential gains from exchanging emissions reductions in a regional compliance framework. Also, oil and gas steam resources categorized under other resources are also included under the Clean Power Plan. Renewable Portfolio Standards and Energy Efficiency This section of the table shows the renewable portfolio standards targets for each state, where applicable, as well as energy efficiency totals and implied credit. This information is used to show the implied emissions rates from the mass-based regional compliance scenarios. The energy efficiency credit is based on the formula EPA used to calculate the emissions rate targets in the proposed Clean Power Plan. However, this method should not be taken as the only way in which the energy efficiency credit could be determined. Emissions Rate Performance This section of the table is informational only as PJM did not run any rate-based simulations for the OPSI-requested scenarios. It provides information on the implied emissions rates under different assumptions on how renewable resources, energy efficiency, and the inclusion of resources under 111(b) would affect the resulting emissions rates. This section shows the target emissions rate, the implied rate from just resources subject to the Clean Power Plan PJM P age

9 under 111(d), the implied rate if new resources under 111(b) were included, and finally the implied rate if both 111(b) resources and RPS targets were also included. General Observations Wholesale Energy Market and Load Energy Payments Relative to the 2014 transmission planning case in the absence of the Clean Power Plan, load-weighted average LMP and load energy payments are lower in the OPSI 2a, 2b.1, and 2b.2 scenarios. The main drivers behind this result are the assumptions of higher energy efficiency and renewable resource levels relative to the 2014 transmission planning case and are not necessarily directly a function of the Clean Power Plan. In contrast, the OPSI scenarios with 50 percent higher gas prices (2b.3) and a 50 percent reduction in nuclear output (2b.4) exhibit higher wholesale energy market prices and load energy payments than the RTEP cases as these assumptions alone would increase wholesale energy prices, but these assumptions also lead to an increase in CO 2 prices that flow through into LMP. Regional versus Individual State Compliance The comparison is OPSI scenarios 2a (regional) and 2c (individual state) compliance. Even for states whose emissions do not exceed their targets (or bind) and have an individual state CO 2 price of zero, because of regional dispatch, their load weighted average LMP and load energy payments may increase because other states bind on their emission targets and have positive CO 2 prices. The implication is that even though the OPSI 2a regional compliance scenario resulted in a CO 2 price of zero, and some states on an individual basis also have a CO 2 price of zero, there is still a cost in the form of higher LMP and load energy payments to all states by choosing individual state compliance. Renewable Resource and Energy Efficiency Implications For this analysis PJM did not assume allocation of the renewable attributes of any states renewable resources to other states, but only accounted for renewable resources within state boundaries. Not knowing how renewable energy credits (RECs) would be allocated or the strategies states may employ to retain or acquire RECs significantly increases the complexity of modeling. Regionally, it is easier to account for renewable resources in compliance since the attributes of renewable resources, regardless of location, are included in the region. The analysis assumes all renewables in the PJM region can be used for regional compliance within PJM. 1 1 PJM acknowledges generators physically located within the PJM foot-print could sell their renewable attributes and/or physical energy to load serving entities outside of PJM. Today, wind resources within PJM already dynamically schedule their energy out of PJM to satisfy long-term power purchase contracts with entities outside of the RTO. These arrangements can go both ways and are likely to continue because not all regions have the same technical potential to develop resources in-state. PJM P age

10 As a part of the EPA calculation of target emissions rates the energy efficiency credit is based upon the ratio of generation-to-load within the state. For net-importing states energy efficiency programs were credited only for the load served by in-state generation which has the effect of calculating a higher emission rate target than counting the entirety of energy efficiency in the rate target calculation. Net exporting states are credited at 100 percent of the energy efficiency as the energy efficiency is based on the load which is considered served by in-state generation. The nature of an interconnected power system in which the dispatch of resources is coordinated across state borders, regardless of whether compliance with the Clean Power Plan is done regionally or on an individual state basis, does not result in an equivalent reduction of fossil generation within the state for every megawatt-hour of renewable generation or energy efficiency within the same state. Furthermore, the displacement value, from a compliance perspective, of renewable resources depends on whether the marginal resource is coal, natural gas or oil-fired. And, by extension, the emissions reductions in a state due to the deployment of energy efficiency or renewable resources is also not on a one-to-one basis as renewable resources and energy efficiency in one state may lead to reductions in fossil generation, and emissions, in another state. Under regional compliance, the location of energy efficiency renewable resources is not crucial as efficiency and renewable resources would go toward reducing the emission rate or total tons across the region. However, on an individual state compliance basis, the location does matter as it will affect the regional dispatch and the ability of individual states to meet their targets in isolation. LMP and Load Energy Payments as a Proxy for Compliance Cost by State Variable compliance cost in the regional assessment was defined as the change in fuel and O&M expense due to complying with either the emissions rate or mass target. Because PJM was modeled as a closed system, meaning no energy or emissions reductions were assumed to be exchanged between PJM and other entities, changes in production costs could easily be assessed. Determining compliance costs at a state level is difficult to discern give the nature of regional dispatch, and is beyond the scope of this analysis. However, changes in wholesale energy prices and load energy payments provide a proxy for such state level compliance impacts whether on a regional basis or and individual state basis. Delaware Delaware currently participates in the Regional Greenhouse Gas Initiative, or RGGI. However, to evaluate compliance with the Clean Power Plan, PJM s economic analysis assumed the EPA proposed Clean Power Plan was the only CO 2 emissions regulation applicable to Delaware and, thus, did not make adjustments to factor in effects of RGGI or to discern RGGI effects separately from Clean Power Plan effects. The wholesale energy market impacts discussed below do not account for capital costs associated with renewable resources, energy efficiency, or new combined-cycle gas resources. Such costs may appear in retail electricity rates as determined by state commissions, but such determinations are beyond the scope of this analysis. Moreover, the simulation results discussed below do not attempt to draw any conclusions on wholesale capacity market outcomes. PJM P age

11 Observations from the Emissions Rate Calculation As part of the analysis, PJM calculated the emissions rate target and a corresponding mass target for each state using EPA s guidance. Below are observations from PJM s calculation for Delaware. Of the 4.8 million tons of CO 2 emissions included in Delaware s 2012 baseline, about 287 thousand tons, or 6 percent are from resources that will not be in service by When these resources retire, the output formerly produced by them will be replaced by any combination of resources within the PJM region as a function of regional dispatch to meet load, and not necessarily by resources in Delaware. PJM included 1,193 MW of existing natural gas combined-cycle capacity. Under the proposed Clean Power Plan, combined-cycle resources considered under construction by January 8, 2014 are considered existing resources. Based on the PJM definition of under-construction which includes resources that have an executed Construction Service Agreement (CSA), PJM modeled 309 MW of under-construction capacity to re-dispatch coal to natural gas. By adding the additional capacity, the rate target calculated is lower than the calculated rate provided by the EPA. In 2012, existing natural gas combined-cycles located in Delaware operated at around a 49 percent capacity factor. The EPA assumed 70 percent capacity factor used in calculating the rate targets leaves margin for combined-cycle output to increase if necessary to achieve the target. Independent of other drivers, unless natural gas prices were to fall below 2012 levels, getting from 49 percent to 70 percent would come at increased fuel and maintenance expense. There are no nuclear resources within Delaware, thus PJM included no credit for nuclear in calculating Delaware s emissions rate target. The amount of renewables driving Delaware s emission rate reduction range from 9.3 percent to 29.2 percent of the RPS requirement calculated for the state across scenarios and years. The combination of EPA assumed levels of energy efficiency and renewable energy ranges from 13 percent to 52.3 percent of the state RPS requirement. Delaware was a net-importer of generation and, therefore, only 65 percent of the assumed level of energy efficiency was applied towards the target emission rate. Summary of Compliance Impacts to Delaware PJM evaluated the impacts to Delaware under all the OPSI requested scenarios and in the 2014 transmission planning case. Below is a summary of Delaware impacts observed in the scenarios: PJM P age

12 2020 When evaluated for regional compliance, the regional CO 2 constraint was binding only in the high gas (OPSI 2b.3) and high nuclear retirement (OPSI 2b.4) scenarios. These scenarios have significantly higher cost energy prices and load wholesale energy prices, than the 2014 transmission planning cases. The other regional compliance scenarios modeled result in lowering Delaware s energy prices and load wholesale energy prices, relative to the 2014 transmission planning case, driven by higher levels of assumed energy efficiency and renewable resources rather than the Clean Power Plan itself. wholesale energy price In the state-by-state compliance analysis (OPSI 2c), Delaware s emissions remained under the state mass emissions target. However, because other states were binding on their mass-based targets in the PJM region, the modeled state wholesale energy prices increased relative to the regional compliance (OPSI 2a) scenario by approximately 1 percent. In addition, modeling results shows Delaware s resources were dispatched approximately 7 percent more which led to an approximate 10 percent increase in state emissions. The total generation output in Delaware for the modeled compliance scenarios is greater than the 2014 transmission planning case. In the Clean Power Plan Regional compliance scenarios Delaware s resources face the same CO 2 price as other PJM resources in the regional dispatch. In contrast the 2014 transmission planning case dispatches Delaware resources at a higher cost than comparable resources in other states due to Delaware s participation in the Regional Greenhouse Gas Initiative. In all scenarios Delaware remained under its mass target. While PJM did not study the scenario for rate compliance, the emissions rates from regulated sources were in excess of the target. The renewable attributes of resources outside of Delaware are eligible for inclusion to be counted towards Delaware s RPS; therefore, within a state compliance framework Delaware could also achieve its rate targets by meeting a greater share of its RPS with in-state resources, if EPA does not allow renewable attributes from outside Delaware to count toward compliance. Table 1: Delaware Scenario Results in 2020 DE in 2020 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 OPSI 2c State Load Energy Cost Total Load (MWh) 13,990,372 13,990,372 13,990,372 13,990,372 13,990,372 13,990,372 13,990,372 State LMP ($/MWh) $40.1 $36.9 $37.1 $37.4 $56.9 $49.9 $37.2 PJM Load LMP $38.3 $35.8 $36.0 $36.4 $54.5 $50.5 $36.7 Load Energy Cost ($ Millions) $560 $512 $515 $522 $790 $692 $517 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) Total Generation 2,687,337 6,976,266 7,287,133 7,284,926 8,165,382 11,814,722 7,476,834 PJM P age

13 DE in 2020 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 OPSI 2c ST Coal 319,086 2,013,334 2,150,245 2,139,552 2,854,038 1,539,693 2,258,680 Natural Gas 2,211,425 4,494,067 4,701,341 4,663,565 4,102,736 8,953,653 4,735,575 Natural Gas CC 1,796,237 4,048,174 4,242,880 4,219,039 3,636,387 7,977,303 4,281,113 Natural Gas CT 408, , , , , , ,235 Natural Gas ST 6,703 8,253 10,505 8,070 3,982 35,558 8,228 Nuclear Renewables 83, , , , , , ,728 Other 72, , , ,786 1,053,675 1,166, ,851 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 13.3% 30.8% 32.3% 31.9% 36.9% 61.0% 32.4% Generation (MWh) 1,062,901 2,456,468 2,575,855 2,549,331 2,944,607 4,872,494 2,588,685 Emissions (Short Tons) 426, ,535 1,033,433 1,022,791 1,181,376 1,954,845 1,038,580 Clean Power Plan 111(d) Resources: Generation (MWh) 1,043,418 3,558,136 3,771,933 3,761,598 3,477,282 4,592,529 3,902,281 Emissions (Short Tons) 645,331 2,629,076 2,803,265 2,784,409 3,005,490 2,880,748 2,898,890 Mass Target (Short Tons) 4,348,321 4,348,321 4,348,321 4,348,321 4,348,321 4,348,321 4,348,321 CO2 Price ($/Short Ton) $0.0 $0.0 $0.0 $0.0 $12.7 $13.1 $0.0 Net CO2 Position (Short Tons) 3,702,990 1,719,245 1,545,056 1,563,912 1,342,831 1,467,573 1,449,431 Net CO2 Position Value ($Millions) $0.0 $0.0 $0.0 $0.0 $17.0 $19.2 $0.0 Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates Energy Efficiency (MWh) 26, , ,471 52, , , ,471 EE Credit (%) 19% 50% 52% 52% 58% 84% 53% EE Credit (MWh) 5,126 52,094 54,415 27,199 60,974 88,224 55,832 RPS Goal (MWh) 2,658,171 2,658,171 2,658,171 2,658,171 2,658,171 2,658,171 2,658,171 Emissions Rate Performance (lbs/mwh) CPP Rate Target (lbs/mwh) (d) CO2 rate 1,140 1,397 1,425 1,412 1,628 1,191 1,410 Including 111(b) 976 1,162 1,179 1,173 1, ,175 Achieve RPS Goals (b) and RPS Goals By 2025, each of the modeled compliance scenarios exceeds the regional CO 2 target. Although OPSI 2a (RPS/100% EE), OPSI 2b.1 (Queue Renewable/100% EE) and OPSI 2b.2 (RPS/50% EE) all have PJM Page

14 compliance costs associated with the Clean Power Plan, they still have lower wholesale energy prices and load payments than the 2014 transmission planning case driven by the modeled assumptions on renewable resources and energy efficiency. These reductions, in spite of Clean Power Plan compliance, are driven by the fact there are still more renewable resources and energy efficiency in this modeled scenario than in the 2014 transmission planning case. Because the CO 2 targets become more stringent in 2025, the high gas and nuclear retirement sensitivities have an even greater impact on wholesale energy prices. Compared to the 2014 transmission planning case, the modeled wholesale energy prices are approximately 35 and 29 percent higher, respectively. In each of the regional compliance scenarios, resources regulated under the Clean Power Plan face a CO 2 price for each unit of energy production. PJM observes that in the OPSI 2a modeled scenario, both coal and natural gas generation decline relative to 2020 levels. Gas generation falls in this scenario most likely due to energy efficiency growing between 2020 and Across all modeled regional compliance scenarios, coal generation in the state declined by as much as 14 percent from 2020 levels. On the other hand, gas generation in the modeled scenarios increased about 4 percent on average relative to Relative to 2020, the share of gas generation from unregulated new sources grew approximately 7 percent. In the high nuclear retirement scenario (OPSI 2b.4) gas generation in Delaware fell due to tighter emission targets which caused some of the more expensive existing gas resources in Delaware to be dispatched down. Total gas generation in this scenario is still however nearly twice that of the other modeled scenarios. In each scenario, on a mass basis Delaware is still well under its target emissions level offsetting emissions in other PJM states that exceed their mass targets to meet the regional target. If reductions could be exchanged between resources across state lines, there is a positive net value to Delaware. Based on the modeled scenarios, the valuation of the net emissions position ranges between $8 and $43 million, increasing with the CO 2 price. Table 2: Delaware Scenario Results in 2025 DE in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 State Load Energy Cost Total Load (MWh) 14,136,567 14,136,567 14,136,567 14,136,567 14,136,567 14,136,567 State LMP ($/MWh) $53.8 $48.7 $51.0 $52.6 $72.8 $69.2 PJM Load LMP $51.9 $47.3 $49.9 $51.8 $70.6 $71.0 Load Energy Cost ($ Millions) $759 $662 $693 $729 $990 $941 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) PJM P age

15 DE in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 Total Generation 4,424,006 7,320,475 7,951,320 8,409,086 8,137,168 11,638,994 ST Coal 1,270,099 2,007,005 1,847,838 1,986,022 2,602,510 1,443,702 Natural Gas 2,740,557 4,335,933 5,055,498 5,242,405 4,294,949 8,785,180 Natural Gas CC 2,320,099 3,883,168 4,557,138 4,731,444 3,782,526 7,629,155 Natural Gas CT 418, , , , ,871 1,116,189 Natural Gas ST 2, ,836 Nuclear Renewables 83, , , , , ,596 Other 329, , ,111 1,002,768 1,065,294 1,235,517 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 16.4% 35.3% 41.3% 42.9% 39.2% 64.4% Generation (MWh) 1,307,845 2,812,259 3,289,187 3,414,933 3,117,907 5,131,092 Emissions (Short Tons) 524,707 1,128,278 1,319,622 1,370,071 1,250,904 2,058,594 Clean Power Plan 111(d) Resources: Generation (MWh) 2,251,198 3,016,684 3,050,941 3,235,530 3,197,982 3,891,160 Emissions (Short Tons) 1,684,129 2,392,434 2,308,779 2,455,745 2,766,281 2,486,855 Mass Target (Short Tons) 4,043,678 4,043,678 4,043,678 4,043,678 4,043,678 4,043,678 CO2 Price ($/Short Ton) $0.0 $4.9 $8.9 $10.3 $25.7 $27.5 Net CO2 Position (Short Tons) Net CO2 Position Value ($Millions) 2,359,549 1,651,244 1,734,899 1,587,933 1,277,397 1,556,823 $0.0 $8.1 $15.5 $16.4 $32.9 $42.8 Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates Energy Efficiency (MWh) 26, , , , , ,399 EE Credit (%) 31% 52% 56% 59% 58% 82% EE Credit (MWh) 8, , , , , ,041 RPS Goal (MWh) 3,392,776 3,392,776 3,392,776 3,392,776 3,392,776 3,392,776 Emissions Rate Performance (lbs/mwh) CPP Rate Target (lbs/mwh) (d) CO2 rate 1,437 1,378 1,332 1,374 1,501 1,102 Including 111(b) 1,210 1,120 1,074 1,095 1, PJM P age

16 DE in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 Achieve RPS Goals (b) and RPS Goals Under the modeled scenarios and assumptions, under-achieving the energy efficiency goal (OPSI 2b.2) used in the emissions rate calculation leads to slightly higher wholesale energy prices as compared to the 2014 transmission planning case. The high gas and high nuclear retirement scenarios have the highest energy prices of all modeled scenarios. Compared to the 2014 transmission planning case, their energy prices are approximately 42 and 30 percent higher respectively. If either energy efficiency or renewables did not grow at as fast a rate through 2029, the impact of higher gas prices or nuclear retirements would be even more significant. Coal generation observed in the modeled regional compliance scenarios declines between about 12 and 29 percent relative to 2025 levels as a result of much lower emissions targets in PJM. Gas generation on the other hand grows between 3 and 8 percent relative to 2025 levels in the modeled scenarios. The share of gas generation from unregulated new sources only grows less than 1 percent from 2025 levels. Delaware remains well under its CO 2 mass target in each of the scenarios offsetting emissions in other PJM states that exceed their mass targets to meet the regional target. On average, the net positive emissions position grows about 5 percent across all scenarios, relative to PJM P age

17 Table 3: Delaware Scenario Results in 2029 DE in 2029 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 State Load Energy Cost Total Load (MWh) 14,208,802 14,208,802 14,208,802 14,208,802 14,208,802 14,208,802 State LMP ($/MWh) $63.1 $56.1 $60.3 $63.2 $89.6 $81.8 PJM Load LMP $61.0 $55.2 $59.7 $62.9 $88.0 $84.0 Load Energy Cost ($ Millions) $895 $749 $804 $870 $1,195 $1,091 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) Total Generation 4,908,062 7,455,881 8,016,600 8,353,135 8,064,837 11,483,070 ST Coal 1,386,412 1,677,089 1,592,016 1,410,689 2,299,884 1,061,656 Natural Gas 2,938,455 4,626,103 5,271,030 5,634,227 4,537,360 9,015,643 Natural Gas CC 2,495,901 4,112,462 4,687,587 5,050,322 3,947,801 7,683,147 Natural Gas CT 423, , , , ,335 1,294,985 Natural Gas ST 19,536 3,594 10,390 3,221 2,224 37,511 Nuclear Renewables 83, , , , , ,394 Other 499, ,217 1,045,740 1,123,289 1,047,737 1,225,377 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 18.6% 39.1% 42.8% 46.2% 41.3% 67.0% Generation (MWh) 1,483,721 3,111,839 3,405,431 3,682,134 3,286,822 5,334,730 Emissions (Short Tons) 595,269 1,248,470 1,366,259 1,477,272 1,318,673 2,140,294 Clean Power Plan 111(d) Resources: Generation (MWh) 2,375,513 2,618,432 2,816,943 2,715,950 2,896,898 3,358,817 Emissions (Short Tons) 1,801,383 2,043,402 2,071,038 1,904,267 2,464,815 2,041,537 Mass Target (Short Tons) 3,752,081 3,752,081 3,752,081 3,752,081 3,752,081 3,752,081 CO2 Price ($/Short Ton) $0.0 $13.2 $17.4 $20.0 $42.3 $38.6 Net CO2 Position (Short Tons) 1,950,698 1,708,679 1,681,043 1,847,814 1,287,266 1,710,544 Net CO2 Position Value ($Millions) $0.0 $22.6 $29.3 $36.9 $54.4 $66.0 Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates Energy Efficiency (MWh) 26, , , , , ,102 EE Credit (%) 35% 52% 56% 59% 57% 81% EE Credit (MWh) 9, , , , , ,995 RPS Goal (MWh) 3,552,200 3,552,200 3,552,200 3,552,200 3,552,200 3,552,200 PJM P age

18 DE in 2029 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 Emissions Rate Performance (lbs/mwh) CPP Rate Target (lbs/mwh) (d) CO2 rate 1,459 1,256 1,212 1,206 1, Including 111(b) 1,213 1,034 1, , Achieve RPS Goals (b) and RPS Goals Illinois Illinois is the fourth largest coal power producing state within PJM and is a net exporter of energy to the region. However, unlike the three larger coal-fired power producing states, coal represents a much smaller portion of the state electrical load, which is served primarily from nuclear resources. Also, unlike the other large coal producing states, Illinois has a more aggressive Renewable Portfolio Standard (RPS) that strongly favors in-state development. 2 The wholesale energy market impacts discussed below do not account for capital costs associated with renewable resources, energy efficiency, or new combined-cycle gas resources. Such costs may appear in retail electricity rates as determined by state commissions, but such determinations are beyond the scope of this analysis. Moreover, the simulation results discussed below do not attempt to draw any conclusions on wholesale capacity market outcomes. Observations from the Emissions Rate Calculation As part of the analysis, PJM calculated the emissions rate target and a corresponding mass target for each state using EPA s guidance. Below are observations from PJM s calculation for Illinois. The 2012 baseline emissions included just over 4 million tons of emissions, 10 percent of the total 111(d) covered emissions, from resources that are expected to retire before the start of the compliance period in Within a regional dispatch the load previously served by these resources will continue to be served by a mix of resources located throughout the PJM footprint. In 2012 Natural Gas Combined Cycles sited in Illinois operated at 31 percent utilization (capacity factor) compared to 55 percent and 59 percent in Ohio and Pennsylvania. However, a 70 percent capacity factor which is built into the EPA-proposed goals would require a much more significant change in the operation of existing natural gas combined-cycle resources within Illinois than for natural gas combined-cycle resources sited in other states with comparable load levels. 2 PJM Environmental Information Services, PJM P age

19 Based on the PJM definition of under-construction which includes resources that have an executed Construction Service Agreement (CSA), and EPA s definition of existing resources as those under construction prior to January 8, 2014, an additional 600 MW of under-construction natural gas combined cycle capacity 3 was used to re-dispatch coal to natural gas. Because other states in the same region of Illinois have less aggressive RPS policies, the renewables built into the EPA proposed goals range between 32 percent and 37 percent of the calculated state RPS requirement across scenarios and years. That is Illinois has more existing and planned renewable resources than EPA assumes in calculating the target emissions rate. Holding natural gas prices constant, achieving the current state RPS would help mitigate the variable compliance cost in any given compliance year. Because the generation-to-load ratio (PJM) in Illinois is greater than 1, Illinois target emission rate reflects the full 100 percent of energy efficiency anticipated by the EPA in setting the target rates. The combination of the energy efficiency and renewable resources assumed in Illinois emission targets range between 61 percent and 75 percent of the state RPS requirement. Illinois was the largest producer of nuclear energy within PJM in percent of the output was counted towards the state s emissions rate reduction goals per EPA s emissions rate goal calculation. Summary of Compliance Impacts to Illinois PJM evaluated the impacts to Illinois under all the OPSI requested scenarios and in the 2014 transmission planning case. Below is a summary of Illinois impacts observed in the scenarios: 2020 Absent nuclear retirements and significantly higher gas prices, wholesale energy market prices in Illinois will be lower under the Clean Power Plan than under the 2014 transmission planning case driven by the assumption that investments in renewables are made at a rate consistent with the aggregate of the PJM state RPS goals and energy efficiency achieves EPA s assumed target levels rather than the Clean Power Plan itself., wholesale energy price Illinois is one of four states that bind on its mass target when studied for individual state compliance (OPSI 2c). Reducing the generation in these states to satisfy their individual CO 2 emissions goals results in higher wholesale energy prices for all of PJM load relative to regional compliance. Specifically Illinois wholesale energy prices rise by $1.16 / MWh or just over 3 percent in the modeled state compliance scenario relative to the regional compliance (OPSI 2a) scenario that shares the same economic and generation assumptions. 3 PJM added the Nelson Energy Center (Queue Project #: R33) to the emission rate goal calculation PJM P age

20 Because Illinois bound on its state mass target, and due to limited gas-fired generation, it cannot produce additional megawatt-hours from sources regulated under the Clean Power Plan. To satisfy the emissions target coal generation was dispatched down by about 8 percent and gas generation was dispatched upward by nearly the same percentage relative to the regional compliance scenario. Most of the additional gas fired generation comes from unregulated combustion turbines. The net reduction in state generation due to state compliance was nearly 2 percent which led to an 8.5 percent CO 2 emissions reduction. Illinois on average (regional scenarios) has negative net allowance position of just over 2.5 million tons, meaning it emits above its target, but this can be offset by states that have a positive net emissions position, meaning they emit below their targets. The value of the net emissions position indicates the purchase cost of additional reductions if such reductions were allowed to be exchanged across states and resources. PJM P age

21 Table 4: Illinois Scenario Results in 2020 IL in 2020 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 OPSI 2c State Load Energy Cost Total Load (MWh) 115,563, ,563, ,563, ,563, ,563, ,563, ,563,045 State LMP ($/MWh) $35.9 $33.6 $33.7 $34.2 $51.0 $51.9 $34.8 PJM Load LMP $38.3 $35.8 $36.0 $36.4 $54.5 $50.5 $36.7 Load Energy Cost ($ Millions) $4,103 $3,736 $3,749 $3,880 $5,669 $5,765 $3,865 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) Total Generation 135,994, ,261, ,162, ,889, ,193,433 89,726, ,894,549 ST Coal 31,572,649 29,476,515 29,356,688 29,961,258 29,571,000 26,726,671 27,014,045 Natural Gas 1,812,525 1,036,166 1,084,870 1,168, ,079 13,039,083 1,122,119 Natural Gas CC 1,393, , , , ,960 9,206, ,671 Natural Gas CT 419, , , , ,119 3,832, ,448 Natural Gas ST Nuclear 87,427,401 87,422,700 87,422,071 87,424,910 87,427,644 30,543,230 87,421,534 Renewables 15,000,677 19,147,989 19,120,593 19,156,102 19,172,190 19,171,869 19,154,384 Other 181, , , , , , ,466 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Generation (MWh) Emissions (Short Tons) Clean Power Plan 111(d) Resources: Generation (MWh) 32,966,070 30,228,910 30,141,034 30,829,681 30,109,960 35,933,181 27,788,716 Emissions (Short Tons) 36,190,906 33,574,956 33,446,859 34,147,815 33,645,049 34,065,818 30,715,004 Mass Target (Short Tons) 30,654,962 30,654,962 30,654,962 30,654,962 30,654,962 30,654,962 30,654,962 CO2 Price ($/Short Ton) $0.0 $0.0 $0.0 $0.0 $12.7 $13.1 $2.2 Net CO2 Position (Short Tons) Net CO2 Position Value ($Millions) (5,535,944) (2,919,994) (2,791,897) (3,492,853) (2,990,087) (3,410,856) (60,042) $0.0 $0.0 $0.0 $0.0 ($37.9) ($44.6) ($0.1) Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates Energy Efficiency (MWh) 1,190,000 4,410,000 4,410,000 2,205,000 4,410,000 4,410,000 4,410,000 EE Credit (%) 100% 100% 100% 100% 100% 78% 100% EE Credit (MWh) 1,190,000 4,410,000 4,410,000 2,205,000 4,410,000 3,424,069 4,410,000 RPS Goal (MWh) 18,490,087 18,490,087 18,490,087 18,490,087 18,490,087 18,490,087 18,490,087 Emissions Rate Performance (lbs/mwh) PJM P age

22 IL in 2020 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 OPSI 2c CPP Rate Target (lbs/mwh) 1,214 1,214 1,214 1,214 1,214 1,214 1, (d) CO2 rate 1,335 1,141 1,139 1,193 1,145 1,130 1,089 Including 111(b) 1,335 1,141 1,139 1,193 1,145 1,130 1,089 Achieve RPS Goals 1,254 1,141 1,139 1,193 1,145 1,130 1, (b) and RPS Goals ,254 1,141 1,139 1,193 1,145 1,130 1,089 By 2025, because of more stringent emissions goals across PJM, under-achieving the EPA assumed energy efficiency target used in the goal computation by 50 percent (OPSI 2b.2) leads to Illinois wholesale energy prices increasing by $0.10/MWh relative to the 2014 transmission planning case. This small increase, in spite of Clean Power Plan compliance, is driven by the fact that there are still more renewable resources and energy efficiency in this modeled scenario than in the 2014 transmission planning case. Although resources in the OPSI 2a and OPSI 2b.1 face a CO 2 price for each short ton of emissions produced, wholesale energy prices are still below the 2014 transmission planning case driven by the assumed additional energy efficiency and renewable resources in the modeled scenarios.. The state s wholesale energy prices relative to the 2014 transmission planning case are considerably higher in the high gas scenario (2b.3) and in the high nuclear retirement (2b.4) scenario. Between 2020 and 2025 coal generation observed in the modeled scenarios declines between 11 and 22 percent across scenarios. Over the same time-frame natural gas generation increases between 16 and 72 percent across all modeled compliance scenarios, rising the most in the high nuclear retirement scenario. Across each of the modeled scenarios the total state generation declined nearly 1 percent on average between 2020 and Illinois remains a net-exporter of generation except in the high nuclear retirement scenario. This result makes intuitive sense given this scenario reduces nuclear by 50 percent and nuclear is the dominant fuel source in Illinois. Under modeled scenarios with higher levels of energy efficiency, Illinois has a negative net emissions position which can be offset by states that emit below their targets. Under the low energy efficiency, high gas, and low nuclear model scenarios Illinois has a net positive emissions position as coal generation declines in these scenarios relative to their 2020 levels. Table 5: Illinois Scenario Results in 2025 IL in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 PJM P age

23 IL in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 State Load Energy Cost Total Load (MWh) 120,706, ,706, ,706, ,706, ,706, ,706,660 State LMP ($/MWh) $48.6 $43.9 $47.0 $48.7 $65.9 $74.2 PJM Load LMP $51.9 $47.3 $49.9 $51.8 $70.6 $71.0 Load Energy Cost ($ Millions) $5,805 $4,889 $5,229 $5,647 $7,332 $8,264 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) Total Generation 138,881, ,216, ,370, ,049, ,561,210 89,330,219 ST Coal 33,117,327 26,285,762 24,805,050 23,647,557 23,697,460 20,879,884 Natural Gas 2,722,584 1,352,872 1,626,863 2,007,268 1,324,885 15,109,522 Natural Gas CC 1,979, ,850 1,033,551 1,281, ,239 9,183,167 Natural Gas CT 742, , , , ,646 5,926,355 Natural Gas ST Nuclear 87,883,489 87,868,240 87,868,254 87,869,720 87,870,012 30,461,378 Renewables 14,971,349 22,528,286 18,884,965 23,335,967 22,482,276 22,599,276 Other 186, , , , , ,159 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Generation (MWh) Emissions (Short Tons) Clean Power Plan 111(d) Resources: Generation (MWh) 35,097,001 27,117,612 25,838,600 24,929,286 24,418,699 30,063,051 Emissions (Short Tons) 38,233,152 30,115,560 28,469,568 27,233,704 27,119,688 27,469,494 Mass Target (Short Tons) 27,971,723 27,971,723 27,971,723 27,971,723 27,971,723 27,971,723 CO2 Price ($/Short Ton) $0.0 $4.9 $8.9 $10.4 $25.7 $27.5 Net CO2 Position (Short Tons) Net CO2 Position Value ($Millions) (10,261,429) (2,143,837) (497,845) 738, , ,229 $0.0 ($10.5) ($4.4) $7.6 $21.9 $13.8 Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates PJM P age

24 IL in 2025 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 Energy Efficiency (MWh) 1,190,000 9,363,000 9,363,000 4,681,500 9,363,000 9,363,000 EE Credit (%) 100% 100% 100% 100% 100% 74% EE Credit (MWh) 1,190,000 9,363,000 9,363,000 4,681,500 9,363,000 6,929,186 RPS Goal (MWh) 28,366,065 28,366,065 28,366,065 28,366,065 28,366,065 28,366,065 Emissions Rate Performance (lbs/mwh) CPP Rate Target (lbs/mwh) 1,072 1,072 1,072 1,072 1,072 1, (d) CO2 rate 1, Including 111(b) 1, Achieve RPS Goals 1, (b) and RPS Goals 1, By 2029, the assumed growth in renewables and/or energy efficiency is sufficient to keep wholesale energy prices in the modeled OPSI 2a and OPSI 2b.1 scenarios lower than the 2014 transmission planning case, despite these scenarios having implied regional CO 2 prices of $13.2 and $17.4/ton. Reducing energy efficiency by half (OPSI 2b.2) causes the CO 2 price to rise $6.8/ton in this modeled scenario relative to the OPSI 2a scenario for a total price of $20/ton. The increase in the CO 2 price results in the state s wholesale energy price rising by over $2/MWh relative to the 2014 transmission planning case and rising nearly $8/MWh relative to the OPSI 2a scenario in which energy efficiency is modeled at 100 percent of the EPA assumed achieved target. Modeled scenarios with higher gas prices or 50 percent reduced nuclear generation result in an approximate 50 percent rise in wholesale energy prices relative to the wholesale energy price in the 2014 transmission planning case. The modeled compliance scenarios show that in-state coal generation in 2029 declines between 12 and 15 percent from 2025 levels. Gas-fired generation increases between 26 and 40 percent from 2025 levels in the modeled scenarios. The net change in generation state-wide ranged from a decrease of 2.5 percent in the OPSI 2b.1 modeled scenario to an increase of 1.7 percent in the OPSI 2b.4 modeled scenario with a 50 percent reduction in nuclear output.. Illinois has a net positive emissions position in all scenarios, but for the high renewable and energy efficiency scenario (2a). This means that under most modeled scenarios, Illinois can help offset other states PJM P age

25 that exceed their emissions targets. The implied value of the positive net emissions position ranges from $21 to $104 million depending on the scenario. Table 6: Illinois Scenario Results in 2029 IL in 2029 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 State Load Energy Cost Total Load (MWh) 124,877, ,877, ,877, ,877, ,877, ,877,152 State LMP ($/MWh) $57.9 $52.3 $57.1 $60.3 $83.8 $89.2 PJM Load LMP $61.0 $55.2 $59.7 $62.9 $88.0 $84.0 Load Energy Cost ($ Millions) $7,158 $5,921 $6,462 $7,173 $9,482 $10,092 Generation Output (MWh), Emissions (Tons) and Net Emissions Value ($) Total Generation 139,082, ,170, ,066, ,547, ,133,571 90,855,818 ST Coal 33,339,132 23,118,666 21,811,446 20,191,736 20,901,412 17,795,075 Natural Gas 3,401,979 1,742,044 2,282,645 2,685,488 1,675,988 18,996,541 Natural Gas CC 2,422,343 1,003,651 1,330,322 1,590, ,862 10,272,146 Natural Gas CT 979, , ,323 1,094, ,126 8,724,395 Natural Gas ST Nuclear 87,229,515 87,191,751 87,198,182 87,207,852 87,197,112 30,460,539 Renewables 14,921,885 22,928,479 18,578,497 24,265,227 23,159,604 23,277,956 Other 190, , , , , ,707 New Source Performance Standard 111(b) Resources: Capacity Factor (%) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Generation (MWh) Emissions (Short Tons) Clean Power Plan 111(d) Resources: Generation (MWh) 35,761,476 24,122,317 23,141,767 21,782,730 21,688,274 28,067,221 Emissions (Short Tons) 38,660,008 26,590,847 25,180,822 23,430,818 23,917,055 24,431,827 Mass Target (Short Tons) 26,374,315 26,374,315 26,374,315 26,374,315 26,374,315 26,374,315 CO2 Price ($/Short Ton) $0.0 $13.2 $17.4 $20.0 $42.3 $38.6 Net CO2 Position (Short Tons) (12,285,693) (216,532) 1,193,493 2,943,497 2,457,260 1,942,488 Net CO2 Position Value $0.0 ($2.9) $20.8 $58.7 $103.9 $75.0 PJM P age

26 IL in 2029 RTEP OPSI 2a OPSI 2b.1 OPSI 2b.2 OPSI 2b.3 OPSI 2b.4 ($Millions) Renewable Portfolio Standard and Energy Efficiency Credit for Computing Resulting Emissions Rates Energy Efficiency (MWh) 1,190,000 11,765,000 11,765,000 5,882,500 11,765,000 11,765,000 EE Credit (%) 100% 100% 100% 100% 100% 73% EE Credit (MWh) 1,190,000 11,765,000 11,765,000 5,882,500 11,765,000 8,559,762 RPS Goal (MWh) 31,219,288 31,219,288 31,219,288 31,219,288 31,219,288 31,219,288 Emissions Rate Performance (lbs/mwh) CPP Rate Target (lbs/mwh) (d) CO2 rate 1, Including 111(b) 1, Achieve RPS Goals 1, (b) and RPS Goals 1, Indiana Indiana is one of six states with PJM whose load is split between PJM and a neighboring control region. Indiana s 2012 generation committed within the PJM market was significantly greater than the PJM load served within the state. Coal generation within the state accounted for 7.5 percent of the total coal generation produced in PJM, while Indiana s load accounted for only 3 percent of PJM s total 2012 load. Within the PJM footprint Indiana is therefore a net-exporting state. The wholesale energy market impacts discussed below do not account for capital costs associated with renewable resources, energy efficiency, or new combined-cycle gas resources. Such costs may appear in retail electricity rates as determined by state commissions, but such determinations are beyond the scope of this analysis. Moreover, the simulation results discussed below do not attempt to draw any conclusions on wholesale capacity market outcomes. Observations from the Emissions Rate Calculation As part of the analysis, PJM calculated the emissions rate target and a corresponding mass target for each state using EPA s guidance. Below are observations from PJM s calculation for Indiana. Indiana doesn t have any nuclear generation, nor does it have a significant amount of natural gas combinedcycle generation within PJM. PJM P age

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