Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance
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Jason Symonds, DNV GL
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Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance
- 1. DNV GL © 2014 SAFER, SMARTER, GREENERDNV GL © 2014 SAFER, SMARTER, GREENERDNV GL © 2014 Ungraded Jason Symonds, DNV GL-Energy October 1st, 2015 Learning to Walk Before Learning to Run: First Steps Toward EPA’s Clean Power Plan Compliance 1
- 2. DNV GL © 2014 Agenda 2 Overview of finalized Clean Power Plan (CPP) rule First steps toward CPP compliance State compliance plans Clean energy incentive program (CEIP) Proposed EM&V guidelines
- 3. DNV GL © 2014 CPP interim and final targets 3 EIA forecast, table 18: http://www.eia.gov/forecasts/aeo/tables_ref.cfm
- 4. DNV GL © 2014 Final building blocks in CPP 4 111(d) planning EPA used three building blocks to determine state emission goals Heat rate improvements Increased NGCC dispatch Renewables EE removed from building blocks, but not from discussion
- 5. DNV GL © 2014 - 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000 Goal(lbs./MWh) State-by-state rate-based compliance targets - 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000 Goal(lbs./MWh) 5
- 6. DNV GL © 2014 First steps 6 Develop state compliance plans Pursue CEIP Review EM&V guidelines in context of current methodologies
- 7. DNV GL © 2014 State compliance plan timeline Extension submission requirements: 1. An identification of final plan approach(es) under consideration, including a description of progress made to date 2. An appropriate explanation for why the state requires additional time to submit a final plan by September 6, 2018 3. Demonstration or description of opportunity for public comment on the initial submittal and meaningful engagement with stakeholders 7 State Compliance Plan Timeline 2016 10/1/2015 WEEC Conference 2017 2018 2019 9/26/2018 Final plan submittal deadline.
- 8. DNV GL © 2014 State compliance plan approaches Emission Standards Approach State Measures Approach Rate- based Mass- based Mass- based Single -state Multi- state Single -state Multi- state Single -state Multi- state Rate- based 8
- 9. DNV GL © 2014 State compliance plans: Framework Emission standards approach Pro •Streamlined approach laid out by EPA •Can use either rate-based or mass-based target Con •Not as flexible State measures approach Pro •Flexibility to include non-EGU focused approaches (i.e., RPS, EERS, and utility and DSM incentive programs) Con •More paperwork to demonstrate federal backstop •Have to meet mass-based goals •State must pass laws in support 9
- 10. DNV GL © 2014 State compliance plans: Case study What are states doing around you? Regional greenhouse gas initiative – State-measures approach, mass-based, multi-state Existing CO2 emission trading market Will new states join? – NJ was once in; may be back – VA has Dem. governor; recent Acadia study gives green light – PA considering RGGI 10 http://www.sightline.org/research/graphics/north-american-carbon- pricing-started-with-rggi/ Examples already exist for multi-state carbon markets, but is it for everyone?
- 11. DNV GL © 2014 Clean energy incentive program (CEIP) CEIP will provide opportunities for investments in renewable energy and demand-side energy efficiency that deliver results in 2020 or 2021. In order for a state to participate in the program, it must include in its initial submittal, if applicable, a non-binding statement of intent to participate in the CEIP. 11
- 12. DNV GL © 2014 Clean energy incentive program (CEIP) 12 Renewables • For every two MWh generated, the project will receive one early-action ERC from the state, and the EPA will provide one matching ERC Energy efficiency • For every two MWh in end-use demand savings achieved, the project will receive two early-action ERCs from the state, and the EPA will provide two matching ERCs
- 13. DNV GL © 2014 CEIP: State/regional responses 13 Arizona • 24% interim goal / 34% final goal Southwest Power Pool • Leveraging potential regional scale Pennsylvania • “We’re listening” Michigan • “Policy make local”
- 14. DNV GL © 2014 Energy efficiency and EM&V 14 Ratepayer- funded programs • Rebates & loans • Technical assistance • Education Building energy codes • Establish efficiency requirements for new/renovated buildings State appliance standards • Establish efficiency requirements for products not covered by federal government Energy services performance contracting • Projects delivered by ESCOs and repaid through consumer bill savings Volt/VAR optimization • Efforts to improve grid efficiency
- 15. DNV GL © 2014 Energy efficiency and EM&V guidelines: Framework EM&V guidelines 1. Methods 2. Metrics and baselines 3. Reporting 4. Deemed savings 5. Independent factors 6. Accuracy 7. Double counting 8. Effective useful life 9. Savings cycle 10. T&D adders 11. Interactive effects 12. EM&V protocols 15 EM&V draft guidelines: http://www2.epa.gov/sites/production/files/2015- 08/documents/cpp_emv_guidance_for_demand-side_ee_-_080315.pdf
- 16. DNV GL © 2014 Energy efficiency EM&V guidelines: Case study Utility clients wonder how current EM&V practices compare to draft guidelines 16 How much will states/utilities need to change EM&V approach to align with CPP? Deemed savings and TRMs Approx. 20 states developed TRMs What about the rest? Baselines How will “common practice baseline” impact programs? Create “market average” for baseline? Timeframe & cycles for persistence/verification studies & reporting savings How does this line up with what utilities do currently?
- 17. DNV GL © 2014 Source: EIA, “Electricity Data Browser” States that aren’t taking the first step 17 Electric sector annual CO2 emissions 16 states currently suing EPA Expect federal plan to begin implementation in 2018, if states do not submit plan
- 18. DNV GL © 2014 Summarizing first steps 18 State compliance plans • If a state is not going to meet 9/26/2016 compliance plan deadline, extension is not a cake walk CEIP • Pursuing early-action credits gives states leg up toward compliance EM&V proposed guidelines • Guidelines won’t make or break CPP • May cause states/utilities to rethink EM&V processes
- 19. DNV GL © 2014 SAFER, SMARTER, GREENER www.dnvgl.com SAFER, SMARTER, GREENER www.dnvgl.com Thank you 19 Jason Symonds jason.symonds@dnvgl.com 703-678-2819
Hinweis der Redaktion
- Slide a minute, 30 min presentation TED talk style, less words the better. Introduce my home in SUS…policy background,….We do implementation work and evaluation work. Most of my work is on the evaluation side of the business. give background on EM&V and Potential studies…policy. I’m an Evaluator. Talking about implementation and evaluation.
- Get a feel for audience: -who has heard of the Clean Power Plan? -Does 111(d) mean anything to anyone? Think about the forego the agenda slide. Provide a brief overview…
- BAU- Business As Usual
- In the nomenclature, even though EE removed, still terribly relevant, and I’ll be talking about that later
- Is rate-based, vs mass-based
- States can go it alone, or states can collaborate. It’s anticipated that states will work together. ISO/RTO are reflections of this.
- “State measures” refer to measures that the state adopts and implements as a matter of state law. Such measures are enforceable only per state law, and are not included in and codified as part of the federally enforceable state plan. Mass-based world: power outside the state? How is that counted?
- Get the list of RGGI states? Get map of RGGI? Portland General Electric: just announced that they will participate in CalISO, (i.e. a West Coast ISO). Big trend in the industry
- Low-income aspect of the EE
- Low-income aspect of the EE
- Jim to provide some perspective. Arizona-Arizona State Department of Environmental Quality beginning to develop detailed analysis of New rulemaking with initial stakeholder meetings (public forums) and early consideration of some of the Clean Energy Incentive Program Mechanisms including: Low Income EE programs (and the amplified benefit of these)….Early Action 2020-2021 on Metered Wind or Solar. Regionalization: Jason, I’ll let you talk about REGI, but another Regionalization example is the Southwest Power Pool. An ISO type operator for 14 SW states that convened a meeting with all of the Air Regulators in its 14 state Region last week to begin discussions of how the REGION might approach compliance with CPP….they suggested REGIONAL approach could save 40%. Southwest Power Pool provides services the following services to members in 14 states (Reliability Coordination begins for the Integrated Systems in June, with full membership in October): Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas and Wyoming. CEIP pathways could provide a potential on ramp to compliance. Pennsylvania-More than a dozen “listening sessions” and 2 month comment period chaired by PA Department of Environmental Protection. DEP is soliciting comments on the Clean Energy Incentive Program component of the CPP and on the EPA-proposed Federal Plan that serves as a model rule for states developing their state plans. 4) Michigan Seeking to avoid placing the state's future in the hads of Washington "bureaucrats," Michigan Gov. Rick Snyder (R) has announced that his state will develop a plan to comply with the Obama administration's Clean Power Plan. “The best way to protect Michigan is to develop a state plan that reflects Michigan’s priorities of adaptability, affordability, reliability and protection of the environment,” Gov. Snyder said in a statement. “We need to seize the opportunity to make Michigan’s energy decisions in Lansing, not leave them in the hands of bureaucrats in Washington, D.C.” The state said it will "soon" announce details of the stakeholder process expected to begin by the end of the year, but the administration has obviously done extensive work getting groups on board. Alongside a statement from Snyder, the governor released commentsfrom more than two dozen groups supporting the decision to develop a plan. Elements of CEIP will be key to MI plan. With much of state’s fossil fuel generation expected to be retired in coming years and current growth in renewables.....CEIP elements will be important to state compliance. Most utilities have low-income programs already. Within our company that low-income programs aren’t big enough to merit our attention. But now, people are asking how they can participate. EPA is creating a carrot to serve under-served communities.
- Framing this: most relevant One might argue that if a state hits is massed-based target through state measures approach, want evidence to see how you got there. Need standards and protocols to rely upon…and this is what EM&V is attempting Any body an EM&V person for utilities? How does this impact your world.
- Third route: utilities that we work with are really thinking hard about this issues. Here’s what we’re doing today, and how will CPP and EM&V protocols going to impact our world. Rich history of EM&V standards that have been developed as part of utility admin, state-funded programs. They don’t all line up, but they’re close enough. States are thinking “what do we have already”, and what are public utilities thinking as well? Mimi: EPA just wants to get this rolling. That’s the big picture. Any
- Highly politicized. Interesting that they put in the new ruling, they put a model plan in. Don’t touch issue of litigation. From our business interest, we’re not well served about making bets around that happening.