The Clean Power Plan and Reliability

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1 The Clean Power Plan and Reliability PRESENTED TO National Governors Association Jurgen Weiss May 6, 2015 Copyright 2015 The Brattle Group, Inc.

2 Disclaimers and Caveats The views expressed in this presentation (and any errors) are entirely mine and NOT those of The Brattle Group. I am an economist, not a lawyer and none of my remarks are addressing the legal aspects of the CPP The presentation is intended to stimulate discussion and the phrasing may be a bit provocative on purpose Yogi Berra: It's tough to make predictions, especially about the future. In other words, it is easy to criticize, much harder to get it right! 1 brattle.com

3 An overly simplistic summary of NERC s Phase 1 analysis (and IRR) NERC has a difficult job, modeling the evolution of a rapidly changing system without knowing the final rule or what set of compliance options will be used. NERC must make assumptions and there is likely no right model. States will only start acting once state plans are finalized and approved, which could be as late as 2018/19 Bulk generation retirements need to be replaced with bulk generation A lot of coal (and perhaps older gas/oil) generation is at risk and is assumed to retire (even though it could provide reserves and A/S at lower capacity factors with corresponding incentives) CPP compliance becomes essentially a story of coal to gas switching with corresponding infrastructure needs (power plants, gas pipelines, transmission) Timing may be too short to get the necessary infrastructure built Challenges related to integrating renewables will worsen States will (at best) choose to collaborate with electrically connected neighbors 2 brattle.com

4 The CPP comes on top of a fundamental transformation of the power system The electric system is in a relatively early stage of a fundamental transformation (largely unrelated to the CPP) Dash to gas with corresponding coal plant retirements is NOT primarily the result of the CPP, but of expectation of abundant cheap (shale) gas Renewables mandates at state level and declining costs are leading to an increasing penetration of VERs Partially technology enabled revolution of the demand side is well underway and will continue (smart meters, Nest, Tesla, SolarCity, etc.) These trends will continue with and without the CPP 3 brattle.com

5 Adapting to the new world will likely be challenging, but the CPP is not the primary driver The power sector landscape will likely already look quite different by 2018 (when NERC assumes action begins) and even more so by 2020/2030, with or without the CPP Maintaining reliability in the transition and in the new end state represents many challenges (including a different type of infrastructure) Many of the underlying operational and infrastructure changes already underway and don t have to wait until 2018 Many of these are no regret policies that should be implemented no matter what The pace of finding solutions (technical and non technical) will likely increase as attention shifts more towards solving the new challenges NERC has an important role to play in ensuring that the transition happens in a way that maintains high levels of reliability But should also recognize that change is unavoidable and should incorporate change into its analyses (to help understand the incremental impact of the CPP) 4 brattle.com

6 In that context the vision of bulk coal being replaced with bulk gas seems at least questionable Emphasis on EE is leading to much lower load growth Explosion of DG, partially based on incentives, but also partially based on true economics and consumer choice Both will likely lead to less demand for bulk power Wind and utility scale solar are approaching the cost of wholesale power (unsubsidized), so it is a distinct possibility that ITC/PTC expiration will not be a cliff for VER development as assumed by NERC In some cases, the case for coal to RE switching becomes equally or more compelling than coal to gas switching. NERC should develop a deeper understanding of how reliability changes under scenarios that reflect much larger changes in the above resource types 5 brattle.com

7 Choice of compliance path part of a complicated game NERC is supposed to be conservative, so assuming states will not take advantage of some of the more unusual compliance options may well be realistically conservative Proposed CPP flexibility options would make overall compliance (much) cheaper and likely mitigate many potential reliability concerns States could join RGGI or form RGGI like constructs, which completely disassociates CPP compliance from local/state level emissions reduction options Cross state cooperation means wealth transfers Interstate commerce is nothing new (the Northeast has been sending money south for oil/gas for many decades, to the Midwest and West for food, to the Midwest for cars, and all those have been sending money to the Northeast for education, etc.) Likely that future electricity landscape will have a different state by state mix Should the EPA push states to jump over their own shadow? Climate risk delivers solid argument for acting faster rather than slower Acting a bit slower only makes sense if we skip switching to gas altogether, i.e. don t end up on a higher cumulative emissions path 6 brattle.com

8 Author Information JURGEN WEISS Principal Cambridge, MA Dr. Weiss, head of The Brattle Group s climate change practice, is an energy economist with 20 years of consulting experience. He specializes in issues broadly motivated by climate change concerns, such as renewable energy, energy efficiency, energy storage, the interaction between electricity, gas and transportation, and carbon pricing and the impact these changes have on existing assets, market structures, and long term planning needs for electric utilities in North America, Europe, and the Middle East. His consulting and expert testimony experience have focused on the impact of changing regulatory and incentive frameworks for lowcarbon technologies, on the economics of both renewable generation sources and existing generation assets, and on the design of efficient incentive mechanisms for renewable energy, energy efficiency, energy storage, and climate change measures. Jürgen has advised clients and authored reports on the design of incentives for renewable energy, the impact of renewable energy on existing wholesale markets, the role energy storage might play in future energy systems characterized by an increasing share of renewable energy, the optimal choice of alternative approaches to lowering energy consumption and/or GHG emissions, and the implications of a changing energy system on wholesale market design. He has also been active in determining the value of electric power assets in a quickly changing market environment. Jürgen was born in Germany, received an undergraduate degree in European Business Administration from the European Partnership of Business Schools, an MBA from Columbia University and a PhD. in Business Economics from Harvard University. He has lived, studied and worked in Germany, France and the United States. The views expressed in this presentation are strictly those of the presenter(s) and do not necessarily state or reflect the views of The Brattle Group, Inc. 7 brattle.com

9 About The Brattle Group The Brattle Group provides consulting and expert testimony in economics, finance, and regulation to corporations, law firms, and governmental agencies worldwide. We combine in depth industry experience, rigorous analyses, and principled techniques to help clients answer complex economic and financial questions in litigation and regulation, develop strategies for changing markets, and make critical business decisions. Our services to the electric power industry include: Climate Change Policy and Planning Cost of Capital & Regulatory Finance Demand Forecasting & Weather Normalization Demand Response & Energy Efficiency Electricity Market Modeling Energy Asset Valuation & Risk Management Energy Contract Litigation Environmental Compliance Fuel & Power Procurement Incentive Regulation Market Design & Competitive Analysis Mergers & Acquisitions Rate Design, Cost Allocation, & Rate Structure Regulatory Compliance & Enforcement Regulatory Strategy & Litigation Support Renewables Resource Planning Retail Access & Restructuring Strategic Planning Transmission 8 brattle.com

10 About the Brattle Group Our Offices NORTH AMERICA Cambridge New York San Francisco Washington, DC EUROPE London Madrid Rome brattle.com

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