Power Market Prices, Nuclear Generation & Greenhouse Gas Policy

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Power Market Prices, Nuclear Generation & Greenhouse Gas Policy PRESENTED TO EUEC 2014 Conference PREPARED BY Marc Chupka Metin Celebi Frank Graves February 4, 2014 Copyright 2013 The Brattle Group, Inc.

Introduction & Overview Recently, merchant baseload plants have had their profits eroded by low natural gas prices, entry of renewables, and depressed demand growth Reduced coal generation = lower average CO 2 emissions from generation Coal generation down because of gas price/renewables/demand Coal retirements from the above + EPA regulations Surviving coal generation capacity factor remains low, could grow (esp. offpeak) Continued market conditions are now affecting merchant nuclear generation Average all hours energy price in PJM was $34/MWh in 2012 and $38/MWh in 2013; capacity prices also low in most sub regions Nuclear plants typically need $30 45/MWh to cover fuel, fixed O&M and CapEx Forward prices of power through 2015 not much more favorable If nuclear plants shut down due to a few years of cash flow shortfalls, the longterm consequences to CO 2 emissions raise significant concerns In the near term, generation shortfall made up with dispatchable coal/gas Regret if CO 2 policy enacted and resulting market would support nuclear Assuming no coal long term, a smaller nuclear fleet would require all gas baseload Absent a CO 2 price, retaining some marginal nuclear plants may require a modest uplift type of payment, a green RMR policy to prevent retirements and resultant CO 2 emissions 1 brattle.com

Recent Merchant Nuclear Plant Retirements Vermont Yankee Kewaunee Operator and Plant Location Entergy; Vernon, VT Dominion; Carlton, WI Installed Capacity 628 MW 574 MW Annual Output (2012) 4,989 GWh (90% CF) 4,516 GWh (90% CF) Marginal Generation Fuels 80% Gas/20% Coal 30% Gas/70% Coal CO 2 avoided 2.7 MMtons/yr 3.78 MMtons/yr Vehicle Equivalent 400,000 Vehicles 550,000 Vehicles 2 brattle.com

Recent Nuclear Operating Margins 2009 2012 annual average margins (energy & capacity revenues less operating cost) against wholesale spot prices were negative for 5 merchant nuclear plants (4 GW) and only marginally positive for 2 plants (2 GW) During the same period, 11 regulated nuclear plants also had operating and CapEx costs higher than revenues they would have earned from wholesale markets. Energy + Capacity Revenues ($/MWh) 2009-12 Avg. Performance $100 Non profitable profitable Revenues = 1.1*Costs Regulated $80 Costs = Revenues $60 $40 $20 $0 $0 $20 $40 $60 $80 $100 Operating Cost + CapEx ($/MWh) Merchant Nuclear Plants (GW) 2009 2012 Regulated 52 4 2 39 3 brattle.com

Merchant Nuclear Margins by 2015 6 GW out of the 45 GW merchant nuclear fleet (13%) would not have been profitable or only marginally profitable at spot prices during 2009 2012 Forward prices and cost trends for 2015 imply that 23 GW of merchant nuclear capacity (51%) are at risk of not fully recovering fixed operating costs (depends on protection from market exposure via PPAs). Market forwards for 2015 are similar to 2009 2012 average spot prices Over the last 5 years, O&M increased by 5% per year and CapEx increased by 17% per year (nominal, average over the entire nuclear fleet) 2009 2012 Average 2015 Trended Costs 4 2 20 23 39 2 4 brattle.com

Potential Economic Improvements Eliminating growth in fixed costs, higher gas prices, or economy wide carbon price would increase the profitability of merchant nuclear units: No Cost Increase 2015 Trended Costs $20/ton CO2 35 9 0 20 23 33 8 4 Zero growth in O&M and CapEx would support an additional 15 GW 2 21 2 21 Gas Price + $1/mmBtu Gas price increase of $1/mmBtu above current forwards supports 2 GW $20/ton supports 15 GW $75/ton supports 23 GW $20/ton with no cost increase supports 22 GW 5 brattle.com

Nuclear - CO 2 Emissions & Avoided Cost 1 GW nuclear avoids 3.4 MMtons/yr of CO 2 relative to gas combined cycle, equivalent to 500,000 gasoline cars @ 15,000 miles/yr and 20 mpg About twice as large a CO 2 benefit vs. coal only generation 1 GW of lost nuclear output at (90% capacity factor) would require large amounts of alternative carbon free resources 2,600 MW of wind @35% CF (about 4 5 Cape Wind projects) More than the entire U.S. solar fleet in 2013 (4,500 MW @17% CF) Levelized cost of avoided CO 2 for NEW wind & solar can be quite high Solar PV about $286 563/ton Wind about $74 165/ton Levelized cost of avoided CO2 for NEW nuclear is also $100+/ton Key public policy questions become: If existing nuclear is threatened, what would it cost to avoid retirement? Overall cost and $/ton CO 2 emissions avoided If preserving existing nuclear is a relatively cheap way of avoiding CO 2, what kind of policy could work? 6 brattle.com

Cost of Sustaining Merchant Nuclear Plants The potential shortfall in spot operating margins for merchant nuclear threatened (23 GW) under the trended cost/market forward price scenario provides an estimate of the cost of retaining the capacity: Cumulative Annual Payments Needed to Sustain Merchant Nuclear Plants $/MWh Equivalent Needed to Sustain Merchant Nuclear Plants Cumulative Annual Payments ($Billion) $3.0 $2.5 $2.0 $1.5 $1.0 $0.5 $0.0 0 5 10 15 20 25 Supported GW Plant Specific Annual Payments ($/MWh) $70 $60 $50 $40 $30 $20 $10 $0 0 5 10 15 20 25 Supported GW 7 brattle.com

CO 2 Impact of Sustaining Merchant Nuclear Plants Supporting all 23 GW of threatened merchant nuclear plants would cost about $2.7 annually and avoid over 130 million metric tons of CO 2 emissions per year, based on the regional fuel mix (gas v. coal) that would replace it in the near term: Cost and Avoided CO 2 From Retaining Merchant Nuclear Plants $3.0 Cumulative Annual Payments ($Billion) $2.5 $2.0 $1.5 $1.0 $0.5 $0.0 0 20 40 60 80 100 120 140 Annual CO2 Avoided (Million Tons) 8 brattle.com

Marginal and Average Cost of CO 2 Avoided About half of the threatened nuclear fleet could be supported with an average cost per ton of CO 2 avoided below $10/ton; while the most expensive reductions would be about $75/ton, the average cost would be $20/ton: Costs of Avoided CO 2 From Retaining Merchant Nuclear Plants $80 $70 CO2 Avoided Cost ($/Ton) $60 $50 $40 $30 $20 $10 $0 Marginal Cost Average Cost 0 5 10 15 20 25 Supported GW 9 brattle.com

Policy Design An inexpensive, plant specific green long term capacity payment or green RMR program could sustain the GHG benefits of merchant nuclear plants that are at risk of not recovering their fixed costs. Ideally, this would comprise only the payment necessary to maintain the capacity Merchant units most at risk when their PPAs expire may provide the opportunity for public support Reliability Must Run (RMR) contracts used to preserve units that were needed for grid reliability but were stranded under deregulation provide an example Unit specific, cost of service Controversial and litigious No national, or all generation, carbon price would be required Payments could be adjusted downward, or even paid back, if energy market prices increase and support is no longer needed, and phased out if an actual carbon price is introduced In addition, pending EPA rules on existing coal under CAA 111(d) might create a state or regional solution for uplift or other market support for zero emission resource deployment or retention 10 brattle.com

The Authors The Brattle Group provides consulting and expert testimony in economics, finance, and regulation to corporations, law firms, and governments around the world. The Principals involved in asset retirement studies are: Marc Chupka Phone: +1.202.955.5050 Principal Email: Marc.Chupka@brattle.com Mr. Chupka provides expertise on the market impacts of both domestic and international energy and environmental policy. He assists energy market clients and counsel in a broad span of management analysis, regulatory proceedings, and litigation support. Mr. Chupka has focused on integrated resource planning, electricity and fuel procurement policies, renewable energy policy design, and climate change policies. Metin Celebi Phone: +1.617.864.7900 Principal Email: Metin.Celebi@brattle.com Dr. Celebi provides expertise in electricity markets and analysis of environmental and climate policy. He has consulted primarily in the areas of electricity spot pricing and market design, and has experience in developing and analyzing climate policies, assessing generation market power, LMP modeling, and merger analysis. Frank Graves Phone: +1.617.864.7900 Principal Email: Frank.Graves@brattle.com Mr. Graves provides expertise is in finance and regulatory economics. He assists clients in investment planning, risk management issues, regulatory reviews and contract disputes. His industry focus is primarily in electric power, where he has advised utilities for over 30 years on such matters as capacity expansion, network modeling, investment and contract prudence, service design and pricing, financial performance evaluation, and asset and contract valuation. 11 brattle.com