Anticipating Compliance Strategies and Forecasts for Satisfying Clean Power Plan Requirements

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1 Anticipating Compliance Strategies and Forecasts for Satisfying Clean Power Plan Requirements By Maggie Shober, Matthew Tanner, and Matt Drews

2 CONTENTS Executive Summary 2 The Clean Power Plan 4 Litigation of the CPP 5 Overview of Methodology and Scenarios 5 Results 6 Coal Retirements 8 Fuel Diversity 9 Impact of Renewables 12 Costs 14 Major Takeaways 15 Energy Efficiency 15 Glidepath 15 Informing Compliance Strategy 15 Appendix: Methodology 16 Portfolio Optimization Model 16 Coal Retirement and Retrofit Forecast Model 16 Major Assumptions 16 CONTACTS» Maggie Shober Managing Consultant Matthew Tanner Associate Director Matt Drews Senior Consultant navigant.com EXECUTIVE SUMMARY In August of this year, the U.S. Environmental Protection Agency (EPA) is expected to release the final Clean Power Plan (CPP) to regulate greenhouse gas (GHG) emissions from existing fossil fuel sources by requiring each individual state meet a carbon dioxide (CO2) emissions target. This regulation will have a significant impact on planning across the entire electric sector. To provide utilities with some insight on how this may impact their business, Navigant modeled a few potential future scenarios. In the proposed CPP (released in June 2014), emissions targets were defined using four building blocks: heat rate improvements, replacing coal generation with gas generation, clean energy, and energy efficiency 1. However, the rule provides significant leeway for states to define their own compliance strategies including but not limited to these building blocks. 1. The term energy efficiency is used in this paper to mean energy efficiency programs and does not include the impact of potential future changes to codes and standards. 2 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

3 Savings in Cumulative System Cost: From Glidepath From Market EE SAVINGS IN CUMULATIVE SYSTEM COST: $216 Billion $247 Billion As the EPA has not yet released the final CPP, there is uncertainty surrounding the specific CO2 targets that states will be required to meet. Navigant conducted a scenario analysis of the impact of the proposed CO2 targets versus the proposed targets with a glidepath an adjustment of interim ( ) targets to be less strict in the early years while approaching the final (2030) target in the later years as well as the impact of the availability of energy efficiency resources. Coal retirements represent the single largest available source of emissions reductions. Since the nation s coal fleet is largely concentrated in the East, this option has a higher impact in those regions. Retiring coal must be replaced by new generation capacity or energy efficiency. New gas generation is necessary to maintain energy and capacity resource adequacy after coal retirements. New gas plants and increasing the use of existing gas plants can be a compliance option in areas where the emission rate targets are higher than the emission rate of the gas plants. Adding renewables is also a cost-effective compliance option in some areas where renewable potential is high, transmission is available or easy to build, and where backup generation capacity is available or can be easily built. This analysis was completed assuming that states cooperate regionally to comply with the policy, using cap and trade to drive unit dispatch to levels that would maintain compliance with emissions targets. The following lists the primary regional compliance mechanisms. REGIONAL LEAST-COST COMPLIANCE OPTIONS Navigant s modeling confirms the rationale for providing states with compliance flexibility: in all scenarios, no single compliance option can reduce emissions in any region sufficiently for compliance. There are significant regional differences in the low-cost compliance strategies, the existing power system, and the potential for energy efficiency and renewable power. Among the compliance options, Navigant found the following: Energy efficiency program expansion represents the lowest cost compliance strategy in almost all areas. It cannot, however, single handedly achieve compliance. Energy efficiency also helps ease the near-term impact of the regulation by reducing the requirement for new capacity in the near term. Northeast Texas Southeast Rest of WECC California MISO+SPP Energy Efficiency Coal Retirement Wind Solar 3 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

4 The Northeast and Southeast primarily comply with the policy through a mixture of energy efficiency and coalgas switching; much of the cost of the policy is in the form of the construction of new gas plants. The Midwest relies on these same compliance strategies and also takes advantage of its wind potential, relying heavily on wind construction for new energy consumption. In Texas, carbon prices also incent heavy wind construction where wind potential is high and transmission relatively easy to access. Western carbon prices are also higher, primarily due to the low dispatch cost of many coal units. Texas sees few coal retirements but a higher carbon allowance price. Its coal units are relatively lower cost than Eastern units and so a higher carbon price is needed to achieve reductions. The West also sees fewer coal retirements and is more reliant on energy efficiency and renewable resources to reduce carbon. California sees the highest carbon prices due to its inability to retire coal and the fact that its target is lower than the emission rate of a combined cycle (CC) unit. As California loses many of its historically cheap coal imports it has to rely on energy efficiency and renewable resources for replacement generation, which command a high carbon price to enter the market. CCs already make up a large share of total California emissions, so the state cannot rely on redispatching to existing CCs, an effective strategy in other areas. Nationally, implementation of the glidepath results in savings of over $200 billion when compared to the non-glidepath scenario. Annual cost savings from the glidepath are higher in initial years, and costs converge with the non-glidepath scenario after The addition of economic procurement of energy efficiency as a supply option raises system costs before the compliance period (by roughly $6.5 billion), as energy efficiency is implemented in phases in anticipation of the policy; upon implementation of the policy, energy efficiency lowers system costs. Navigant s forecast shows that the expansion of energy efficiency programs in response to the CPP can result in overall savings of nearly $250 billion above business-as-usual (BAU) energy efficiency through THE CLEAN POWER PLAN The U.S. Environmental Protection Agency (EPA) proposed the Clean Power Plan (CPP) in June 2014, and has received millions of comments. It is currently in the process of crafting a final rule, which was originally expected in June 2015, but is now delayed until mid-summer likely August. The CPP has two main parts: the EPA s calculation of emissions targets for each individual state and the EPA s guidance to states on implementation plans. Under the direction of section 111(d) of the Clean Air Act, the EPA sets emissions targets and each state develops a State Implementation Plan (SIP) to meet those targets. The EPA s modeling of the proposed CPP shows a reduction in carbon dioxide (CO2) emissions by 30 percent from 2005 levels by Final rule Litigation 2014 Proposed rule Comment period SIPs due Compliance with interim targets Compliance with final targets The EPA used four building blocks to calculate emission rate targets. The first building block is a six percent improvement of heat rates at existing coal-fired power plants relative to 2012 values. The second is a replacement of coal with natural gas in the dispatch up to the point where existing combined cycle (CC) units have an overall capacity factor of 70 percent. The third building block has two parts: the main part is the implementation of renewable standards similar to those achieved or on the books in a state s region, and the secondary part is the continued operation of existing at-risk and under-construction nuclear plants. The fourth building block is ramping up energy efficiency from 2012 levels by 0.2 percent per year of additional savings until the 1.5 percent annual savings level is reached. 4 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

5 The EPA used these building blocks to calculate interim emission rate targets for 2020 through 2029 and final targets for 2030 for each state using the following formula and 2012 data. new sources under section 111(b), as the EPA cannot finalize a rule for existing sources under section 111(d) unless new sources under that same category are regulated under section 111(b). Other legal issues include the EPA s use of outside-the-fence measures in the regulation, the use of state-by-state emissions targets, and the fact that some states have a standard for existing sources that is stricter than the standard for new sources. Heat Rate Improvements 6% Replace Coal with Gas 70% CF for natural gas CCs Clean Energy Regional RPS Keep existing nuclear Energy Efficiency 1.5% annual savings Opinions vary on the likelihood of a stay of the rule as this litigation occurs. Proponents of a stay say it is likely because litigation is expected to take years and because states will need to start submitting implementation plans during that timeframe. Others say a stay is unlikely because compliance does not begin until 2020, and dedication of government resources to plan for compliance is not a strong enough reason to stay the rule. Existing Fossil CO 2 Emissions Existing Fossil Generation - Clean Energy Generation - Energy Efficiency Savings One aspect of the proposed rule that has received much criticism is the stringency of the interim targets and that states and stakeholders do not have enough time to begin complying with such strict standards by 2020, despite the fact that states are allowed to show compliance by an overall average during the 2020 to 2029 timeframe. It is important to note that while the building blocks do represent some compliance options that states could choose to put in their SIPs, they are not prescriptive. States have many options when crafting SIPs, including using a rate- or massbased emissions target, working with other states in regional compliance plans, and even using a cap and trade approach similar to those already in use in California and the Northeast. LITIGATION OF THE CPP Litigation of the CPP is likely to take one to three years, perhaps longer. One issue is the legality of the standard for OVERVIEW OF METHODOLOGY AND SCENARIOS Navigant used the proprietary Portfolio Optimization Model (POM) and the proprietary Coal Retirement and Retrofit Model (CRRM) to solve for the combination of carbon prices and coal retirements that put each region below the EPA target. Compliance costs are calculated by summing the energy dispatch costs imbedded in the redispatch to meet the emissions targets as well as the capacity value needed to replace retiring generation through the rest of its useful life. (For further detail about the models used, see the Appendix.) Navigant modeled four scenarios of the CPP. The first includes both interim and final targets as they were proposed by the EPA last June and uses the energy efficiency assumptions as reported by regional transmission organizations (RTOs)/independent system operators (ISOs) i.e. business-as-usual (BAU) energy efficiency. The second includes a glidepath 2 in place of the proposed interim targets, though the final 2030 target is the same and also assumes BAU energy efficiency. This glidepath eases the 2. A glidepath refers to an adjustment of interim ( ) targets to be less strict in the early years while approaching the final (2030) target in the later years. 5 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

6 25,000 TOTAL ANNUAL EMISSIONS TARGETS 20,000 Million Metric Tons 15,000 10,000 5, As Proposed Scenario Glidepath Scenario steep interim targets that begin in The third and fourth scenarios are the same as the first and second, respectively, except that they allow additional procurement of expanded energy efficiency in response to the CPP. Expanded energy efficiency potential and costs were derived from data from the Electric Power Research Institute (EPRI), Lawrence Berkeley National Laboratory (LBNL), and other sources analyzed by Navigant. Energy efficiency is treated as an available supply resource in modeling capacity expansion. or entities choose to utilize. The regions generally follow interconnections and markets, so some states are split among multiple regions. Limited intra-state trading was allowed in Texas to lower compliance costs, but otherwise each region was independent. REGIONAL ALLOWANCE TRADING GROUPS Scenario 1: EPA s proposed targets, BAU energy efficiency Scenario 2: EPA s targets modified with a glidepath, BAU energy efficiency Scenario 3: EPA s proposed targets, expanded energy efficiency Scenario 4: EPA s targets modified with a glidepath, expanded energy efficiency The assumed compliance option is that states will band together to form six regional trading groups and that each will use a cap and trade system to meet massbased regional targets. Regional targets were calculated by summing the state mass targets calculated by the EPA in their technical support document released in November These assumptions allowed Navigant to model the most economic compliance options instead of being prescriptive with what actions or policies states Northeast Texas Southeast Rest of WECC California MISO+SPP RESULTS The compliance model determines the optimal CPP compliance strategy by calculating the lowest cost mechanism for reducing CO2 emissions to the regional requirements by choosing varying quantities of coal retirements replaced by gas, increased renewable generation, and the development of energy efficiency resources. 6 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

7 Regional differences are driven by the availability of each of these procurement options. Energy efficiency plays a large role in compliance in all regions. Coal retirements are the primary source of reductions in the Northeast and Southeast due to the preponderance of coal generation, while new renewables are expanded more robustly in the West, Midwest, and Texas because of the region s geographical attributes that promote better economics for renewables. Cost of compliance can be split into capacity costs driven by the need to replace retired coal and energy costs influenced by the direct carbon market price to drive redispatch and construction of renewables. The split between these two sources into shares of the total cost of compliance is largely driven by whether there is coal to retire and the cost/quality of renewable resources. The Southeast, for example, has low direct carbon prices and high capacity costs due to coal retirements, while California has high direct carbon prices and no incremental capacity cost. Both the incorporation of expanded energy efficiency resources and the glidepath drive significant overall policy cost savings, although it must be acknowledged that the glidepath cases force lower absolute reductions in CO2 emissions. FIGURE 1: SUMMARY OF RESULTS BY SCENARIO 7 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

8 COAL RETIREMENTS Of all the single compliance options, coal retirements provide the largest emission reduction potential. In all four scenarios Navigant expects significant coal retirements before the CPP compliance period begins. These are principally units whose retirement has been announced or are uneconomic due to regulations or from natural gas competition. Navigant expects a similar magnitude of coal retirements overall, with and without the glidepath, because the final target is the same. With the glidepath those retirements are spread more evenly over the interim compliance period. This trend persists throughout the results and has potential implications for both cost and reliability. For instance, construction costs of replacement generation could increase as demand for skilled labor, materials, turbines, and balance-of-plant components increase; reliability concerns could arise as transmission reinforcement and generation replacement struggles to keep up with retiring coal. Most coal retirements take place in the Eastern Interconnection, where higher coal costs resulting from environmental compliance and lower gas costs make this an attractive compliance option. This shifts the cost of the policy from carbon prices to capacity expansion costs but is economic in oversupplied areas and areas where coal is already marginally economic. Economic coal retirements in the West and Texas are relatively low the lower cost of coal makes coal units relatively more expensive to replace with other resources. This causes other compliance strategies to be more prominent, with correspondingly higher carbon prices and lower gas builds than in the East. The incorporation of expanded energy efficiency supports marginal coal units, as fewer need to be retired in order to FIGURE 2: COAL RETIREMENTS 8 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

9 comply with the policy in the expanded energy efficiency scenarios (3 and 4). Despite the cumulative reduction in the number of retirements, Scenario 3 (no glidepath, expanded energy efficiency) has more retirements prior to 2020 than any other scenario. This is because energy efficiency is assumed to be procured starting in 2015, which reduces the need to build as much replacement capacity and allows many units that had to stay online for reliability in the early 2020s in the BAU energy efficiency scenarios to retire prior to the compliance cliff, making overall compliance easier. FUEL DIVERSITY The CPP is expected to increase reliance on gas in most areas. This increase is heavily mitigated when expanded energy efficiency is considered. New additions of gas CCs follow the coal retirement trend in the BAU energy efficiency scenarios. In the expanded energy efficiency scenarios, new CC additions are roughly half those seen in the BAU scenarios. In addition to the lower demand, the expanded energy efficiency scenarios show fewer coal retirements while remaining in compliance, which, in turn, reduces the number of CCs that need to be built to meet demand. While overall gas supply is expected to keep up with the additional demand in all scenarios, transportation of that gas to where it is needed could be an issue. Under this new regulation it is possible that new natural gas infrastructure cannot keep up with construction of new gas plants, particularly without a large-scale energy efficiency build out and without the glidepath, as new construction skyrockets in the early 2020s in Scenario 1. While this study does not include a formal analysis of reliability, it is a potential concern. FIGURE 3: NATURAL GAS COMBINED CYCLE CAPACITY ADDITIONS 9 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

10 The modeling shows an increase in the capacity factors of all gas CCs (new and existing), particularly in the non-glidepath scenarios again potentially putting pressure on gas infrastructure. California is the only region where gas CCs are used less as the regulation goes on. Their emission rate target is lower than that of a gas CC, so running more gas CCs does not help them meet their target. There is little difference in capacity factors for CCs between the BAU energy efficiency and expanded energy efficiency scenarios. The exception is in California where energy efficiency improves CC capacity factors by reducing effective targets for the remaining thermal generation, similar to how it helps coal units in other areas. FIGURE4: NATURAL GAS COMBINED CYCLE CAPACITY FACTORS 10 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

11 The modeled glidepath allows a number of combustion turbines (CTs) to be delayed, especially in the Southeast, by easing the need for coal capacity to be retired for compliance. Expanded energy efficiency also heavily reduces the need for new peaking capacity by reducing peak demand. CTs tend to be added in areas like Midcontinent Independent System Operator (MISO) territory, Southwest Power Pool (SPP) territory, and the West (including California), which have high levels of renewable additions. These renewables additions limit the need for new high capacity factor CCs but need generation capacity to maintain reserve margins and help balance intermittent renewables. FIGURE 5: NATURAL GAS COMBUSTION TURBINE CAPACITY ADDITIONS 11 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

12 IMPACT OF RENEWABLES Navigant expects the CPP to drive some wind development, particularly in areas with high potential including the Midwest, Texas, and the West. California builds some additional wind but is limited by the fact that the best locations are already taken and construction in California is more expensive. Overall, wind builds are not very different with and without the glidepath. Modification of the regulation to include a glidepath means a more gradual buildup of wind after In all scenarios there is a serious ramp up of wind development starting in the early 2020s. Without expanded energy efficiency, by 2035, wind accounts for 26 percent of generation in the Electric Reliability Council of Texas (ERCOT) and SPP territories, 21 percent in the Rockies, 18 percent in MISO territory, and a meaningful proportion of California, the Pacific Northwest, New England, and other areas. FIGURE 6: WIND CAPACITY ADDITIONS 12 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

13 Navigant s modeling shows the CPP has little impact on solar builds. Most solar continues to be built to meet Renewable Portfolio Standards (RPS), which tend to level off in the mid- 2020s thus, so does solar build out. Most post-2025 solar is built in the West, and even without expanded energy efficiency, California and the Desert Southwest are the only regions with more than five percent of their generation from solar by FIGURE 7: SOLAR CAPACITY ADDITIONS 13 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

14 COSTS The bulk of costs for complying with the CPP can be split into direct carbon price costs through the regional cap and trade markets and the cost of new capacity for replacing retired coal generators. The direct carbon prices for the six regions are shown in Figure 8 (note that the Eastern regions, Texas, and the Western regions have different axes). Carbon allowance costs tend to be lower in the East than the West or Texas, and the ability to trade power leads to some price convergence. Carbon prices are lowest of all regions in the Southeast, which sees the highest level of coal retirements; therefore, FIGURE 8: CO 2 PRICE FORECASTS Note: Axes are higher in Texas and Western regions compliance costs are experienced in replacement capacity costs instead of carbon prices. The Northeast and Midwest tend to have similar prices prior to the 2030s, with Northeastern prices rising above Midwestern prices as wind becomes economic to build: at around $30 per ton. These regions also see lower carbon prices and higher capacity cost due to coal retirements, although the effect is slightly less significant than in the Southeast. ERCOT sees higher prices than the East due to its relatively aggressive targets, low coal dispatch costs, and the fact that it hits wind penetration caps (at 26 percent of total generation by the 2030s). Prices are highest in the West and California where low coal dispatch costs, higher capital costs, and 14 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

15 lower targets ensure that high prices are needed to suppress generation from coal units and California CCs. Assuming a glidepath for the emissions limit eases the costs and potential reliability issues related to the CPP particularly in the early compliance years at the expense of lower overall emissions reductions from the regulation. Major costs of the regulation include new construction of renewable and gas units, implementing energy efficiency programs, and the increased fuel costs of redispatching coal generation to gas. The glidepath results in savings of approximately $55 billion per year for the United States in 2020, compared to the nonglidepath scenario. Annual cost savings from the glidepath decline to approximately $14 billion per year by 2027, after which system costs for each scenario roughly converge. Similar savings are seen with expanded energy efficiency. The addition of expanded energy efficiency raises system costs before the compliance period (by roughly $6.5 billion), as energy efficiency is implemented in phases in anticipation of the policy. Upon implementation of the policy, expanded energy efficiency lowers system costs in 2020 by roughly $5 billion, and the savings rise to about $38 billion per year in 2027 before leveling off in the $20 billion to $30 billion per year range thereafter. MAJOR TAKEAWAYS Energy Efficiency Our modeling of scenarios both with and without expanded energy efficiency in response to the CPP shows that energy efficiency is the first line of defense to bring down the costs of the regulation without sacrificing emissions reductions. Despite building block four (i.e., energy efficiency) only representing approximately 15 percent of the emissions reductions in the EPA s calculation of emission rate targets, energy efficiency programs have the potential to play a much larger role in driving the cost and reliability impacts of the regulation. For instance, when the CPP is allowed to drive expanded energy efficiency, approximately 25 GW to 30 GW of coal remains online through Energy efficiency is a low-cost source of emissions reductions because it offsets the need for supply, has zero emissions, and is not restricted by locational parameters like renewable generation sources. (For more information about energy efficiency under the CPP, see Navigant s paper A Cost-Effective Response to the EPA s Clean Power Plan Focus on Energy Efficiency.) Glidepath There are tradeoffs involved with the implementation of a glidepath similar to that modeled in this white paper. As discussed in the Costs section above, easing into the final 2030 targets reduces overall costs, particularly those that could potentially skyrocket with a frenzy of coal retirements and new generation construction in the early years of compliance. The tradeoff, however, is lower overall emissions reductions. Information Compliance Strategy An entity s compliance strategy will be driven by the state or regional implementation plan or the plans under which it falls. Thus, these strategies will require both expert analysis and stakeholder involvement, will take time to develop, and will likely include a multitude of compliance options. Navigant sees energy efficiency as the most cost-effective 15 Anticipating Compliance:Strategies and Forecasts for Satisfying Clean Power Plan Requirements

16 compliance option across the board and thinks it will likely be a part of most compliance strategies. Navigant believes the retirement of coal plants will be a potential large payoff in terms of emissions reductions if the associated costs can be controlled. Renewables, particularly wind, are also a key compliance option in areas with high potential. It is important to keep in mind that this analysis is all based on a proposed regulation. The final regulation could look very similar to the proposed regulation, could include a glidepath, or could look completely different. Navigant thinks these compliance strategies are universal enough in their impact on emissions reductions, regardless of the final regulation regime, that their significance will not change much with the final regulation. APPENDIX: METHODOLOGY Portfolio Optimization Model Navigant s proprietary POM is a linear optimization model used for capacity expansion. POM simulates economic investment decisions and power plant dispatch on a zonal basis subject to capital costs, reserve margin planning requirements, RPS, fuel costs, fixed and variable operations and maintenance costs, emissions allowance costs, and zonal transmission interface limits. This model incorporates the same generation base, demand forecasts, fuel prices, other operating costs, and plant parameters that are utilized throughout the market simulation modeling process. The model simultaneously performs least-cost optimization of the electric power system expansion and dispatch in multi-decade time horizons. POM can perform multivariate optimization, which can consider value propositions other than cost minimization, including sustainability, technological innovation, or impacts on other sectors, such as natural gas. The generation expansion results from POM are used in Navigant s fundamental energy price forecast. Coal Retirement and Retrofit Forecast Model Navigant s proprietary Coal Retirement and Retrofit Forecast model rapidly estimates the total coal-fired capacity in danger of retirement due to EPA regulations, determines which states require the greatest emissions reductions to be compliant with the Cross-State Air Pollution Rule (CSAPR), and identifies the specific units and plants most at risk of retirement. The tool reviews the historical emissions of all existing coal units, the existing emissions equipment, and unit allocations for nitrogen oxide (NOx) and sulphur oxide (SOx) emissions in order to determine which units are economic to retrofit with pollution control technology and which should be retired. The retirement or retrofit decision is based on the opportunity cost of replacing the coal units with natural gas generation. The Coal Retirement Forecast model summarizes the coal retirements and retrofits by state, ISO, and North American Electric Reliability Corporation (NERC) region, and reports the retirements and retrofits as announced or economically driven. The tool will also estimate how far in or out of the money each unit is to retrofit and the emissions equipment required to be compliant with EPA regulations. Major Assumptions This analysis made several major assumptions that could drive the results; all are listed below. The Production Tax Credit (PTC) and Investment Tax Credit (ITC) are not renewed, which limits the expansion of nearterm wind and solar except in satisfying RPS requirements. RPS requirements are kept at their current levels in all states. Wind penetration is limited to 26 percent. Generating unit capital costs and operating parameters are generally derived from the U.S. Energy Information Administration (EIA) Annual Energy Outlook, with some reductions to the capital costs of wind and solar units to reflect recent trends. Energy efficiency costs are derived principally from data from the LBNL, the American Council for an Energy- Efficient Economy (ACEEE), GEP, EnerNOC, and other sources that been analyzed by Navigant. Energy efficiency costs range from roughly $8 per MWh to $77 per MWh Navigant Consulting, Inc. All rights reserved Navigant Consulting is not a certified public accounting firm and does not provide audit, attest, or public accounting services. See navigant.com/licensing for a complete listing of private investigator licenses. 16 Anticipating Compliance: Strategies and Forecasts for Satisfying Clean Power Plan Requirements

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