www.energyinnovation.org
98 Battery Street; San Francisco, CA 94111
policy@energyinnovation.org

REWIRING THE U.S. FOR ECONOMICRECOVERYBY SONIA AGGARWAL AND MIKE O’BOYLE1 ● JUNE 2020

The results of the 2035 Report: Plummeting Solar, Wind, and Battery Costs Can Accelerate ourClean Energy Future (The 2035 Report) are dramatic. Given the plummeting costs of clean energy
technologies, the United States could reach 90 percent zero-carbon electricity by 2035, maintainreliability, while lowering customer electricity bills from today’s levels, on the path to 100
percent zero-carbon by 2045. To reach 90 percent, this infrastructure build-out would
productively put about $1.7 trillion dollars in investment to use over the next 15 years,
supporting about 530,000 more jobs each year and avoiding at least $1.2 trillion in cumulative
health and environmental damages. And it would reduce economy-wide greenhouse gas
emissions (GHGs) by 27 percent by 2035.
Building a reliable 90 percent zero carbon electricity system2 is a huge opportunity for economic
recovery—a fantastic way to invest in a healthier economy and support new jobs, without raising
electricity bills. But America’s current electricity policy framework is not on track to deliver thiseconomic opportunity.
To realize the promise of this affordable, reliable, clean power system, the U.S. would need to
double solar and wind annual deployments through the 2020s, and then triple historicalmaximums in the 2030s.3 We have done this before, with natural gas power plant deployment
rates in 2002.4 Storage deployment would need to grow 25 percent each year, from 523
megawatts (MW) in 2019 to 20,000 MW in 2035. We would need some new transmission lines
1 The authors would like to thank Mark Ahlstrom (Energy Systems Integration Group); Allison Clements (Energy Foundation); Eric

Gimon, Silvio Marcacci, Bruce Nilles, and Robbie Orvis (Energy Innovation); Bracken Hendricks (Evergreen and Roosevelt
Institute); Sam Ricketts (Evergreen and Center for American Progress); Betony Jones (Inclusive Economics); Taylor McNair(GridLab); Courtney St. John and Phoebe Sweet (Climate Nexus); and David Wooley (University of California, Berkeley) for theirhelpful feedback on this report. Any remaining errors are the responsibility of the authors.
2 Modeling allowed for all known zero-carbon electricity options, including wind, solar, biomass, geothermal, large hydro,

nuclear, and fossil generation with carbon capture and sequestration (CCS). Least cost optimizations eschewed new nuclear or
CCS in the final mix, due to cost. All generation sources are supported by transmission, storage, demand response, and flexible
grid operations.
3 15.1 GW of solar was installed in 2016 and 13.1 GW of wind was installed in 2012. See Bolinger, Mark and Seel, Joachim et al.

“Utility-Scale Solar: Empirical Trends in Project Technology, Cost, Performance, and PPA Pricing in the United States - 2019
Edition.” Lawrence Berkeley National Laboratory 2019. URL: https://emp.lbl.gov/utility-scale-solar; “Wiser, Ryan and Bolinger,
Mark. “2018 Wind Technologies Market Report.” Office of Energy Efficiency and Renewable Energy, Department of Energy August
2019. URL: https://emp.lbl.gov/sites/default/files/wtmr_final_for_posting_8-9-19.pdf.
4 65 GW of new gas power plants were built in 2002. See “Electric Power Annual 2002.” Office of Coal, Nuclear, Electric andAlternate Fuels, Energy Information Administration December 2003. URL: www.eia.gov/electricity/annual/archive/03482002.pdf.

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to interconnect new generation, but relatively few interregional lines. All coal plants could retire,
and we would need no new gas plants. Most of the existing gas fleet would be maintained but
run infrequently, providing 70 percent less energy than today, and helping to balance thesystem.5
Without the addition of new policies, we are not on track to deliver the most cost-effective
electricity system explored in the 2035 Report, nor will we maximize societal benefits like publichealth and climate impacts. Policies, utility regulation, and power market structures will need an
upgrade. Luckily, policymakers and regulators can take promising actions to remedy this. The
technology-neutral policies laid out in this paper are no-regrets actions to get us to 90 percent
zero carbon electricity while reducing wholesale electricity costs 10 percent. These policies
enable all technologies to compete to achieve a clean, affordable, reliable grid.
We emphasize that the list below represents an optimal set of policies to first get the U.S. to a 90
percent, and ultimately 100 percent zero-emission electric power system. Success, however,does not depend on all adopting all of these policies at once, and most progress can be madewith a federal clean energy standard that builds on and complements state policy leadership.
Importantly, either Congress or the U.S. Environmental Protection Agency under its existing
Clean Air Act authority could put the CES building blocks in place.
In brief, top policy actions include:
•

•

•

•
•
•

Adopt a federal clean electricity standard reaching 55 percent clean (carbon free) by
2025, 75 percent by 2030, 90 percent by 2035, and 100 percent by 2045. Increased
ambition on state clean energy standards is an important complement to this action.
Extend federal clean energy investment and production tax credits and conversion tomore liquid incentives, and extend these incentives to battery storage. These are more
important in the absence of a clean energy standard.
Support coal-dependent communities by shoring up underfunded pension andhealthcare benefits, providing stopgap funding for local services, and providing pathwaysfor employment in the clean energy economy through local investment and training
programs.
Use utility- and government-backed refinancing of retired coal equity and debt to lessen
the customer and utility burden of the coal-to-clean transition.
Support a national effort to streamline renewable energy and transmission siting toaccelerate responsible clean energy deployment.
Strengthen federal authority to improve regional transmission planning, allocatetransmission costs, and reduce unfair interconnection costs.

5 The 90% Clean case saw a maximum gas dispatch of 361 GW in 2035, with an additional 90 GW of gas capacity in reserves tomeet reliability standards. This is about 80% of the 540 GW of gas capacity currently operating in the U.S. Because little to no
new gas capacity is needed to meet this need, this strategy creates significant cost-savings in moving to a clean energy future.
The remaining natural gas fleet provides an important role meeting demand in low solar and wind periods, but it experiences
annual capacity factors under 10 percent.

2

•
•

•

Invest in R&D to develop the technologies needed to get to 100 percent clean electricity
by 2045.
Reform wholesale markets to reward flexibility, be compatible with federal and stateclean energy targets, and support investment in a least-cost, technology-neutral portfolioof supply and demand-side resources.
Reform utility business models to incent demand-side management and create fair rules
for utility investment decisions.

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CONTENTS
Contents ................................................................................................................................................ 4
A Clean Energy Standard Would Drive Success ................................................................................... 5
Supporting Clean Energy Deployment at Speed and Scale................................................................. 7
Tax Credits ......................................................................................................................................... 7
Bolstering U.S. Manufacturing of Clean Energy .............................................................................. 8
Dealing With Stranded Assets .......................................................................................................... 9
Permitting and Siting ......................................................................................................................12
Interconnection and Transmission Planning reform .....................................................................13
Support for an Equitable and Fair Transition.....................................................................................16
Addressing Market Failures in Wholesale Markets ...........................................................................18
Principles .........................................................................................................................................19
Required Market Reforms ..............................................................................................................20
Public Participation in Wholesale Market Governance ............................................................20
Expose the Value of Flexibility....................................................................................................20
Require All Generators and Imports to Participate in Economic Dispatch ..............................21
Minimize Restrictions on Resource Participation .....................................................................22
Pay for Uncompensated Reliability Services .............................................................................22
Remaking Utility Regulation for the Modern Grid ............................................................................24
Performance-Based Regulation and New Utility Business Models ..............................................24
Competitive All-Source Procurement ............................................................................................25
R&D to Support the Pathway to 100 Percent Clean Electricity ........................................................27
Long-Duration Storage....................................................................................................................27
New Resource Adequacy Frameworks ..........................................................................................27
Inadequacy of Dispatch and Planning Models ..............................................................................28
Voltage, Frequency, and Stability Control Technologies ..............................................................28
Conclusion ...........................................................................................................................................29

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A CLEAN ENERGY STANDARD WOULD DRIVE SUCCESS
A clean energy standard sets a clear goal for the share of total electricity that will come fromzero-carbon sources in a future year. A technology-neutral clean energy standard for theelectricity sector should include all sources of zero-carbon electricity (solar, wind, biomass,hydro, geothermal, nuclear, carbon capture and storage, and any other proven source of zerocarbon electricity). It should require retail utilities to hit interim targets at least every five years(ideally every three), building up from the existing share of clean energy in the nation’s electricity
mix (approximately 40 percent today).
Setting a national clean energy standard of 55 percent by 2025, 75 percent by 2030, 90 percent
by 2035, and 100 percent by 2045 would be ambitious and achievable, giving America the clean
energy backbone it needs to decarbonize other sectors on the path to net zero economy-wide
emissions by 2050.6 Getting underway now to build the clean energy needed to reach 90 percent
by 2035 gives engineers and developers time to evaluate the best technologies and pathways to
get us to 100 percent carbon-free electricity at least cost by 2045.
Congress or the U.S. EPA could require states to submit plans laying out their path to meet theclean electricity standard, and to update those plans every three years. Legislation should
require retail utilities to develop scenarios complying with this pathway as part of utility resource
planning, and demonstrate compliance by procuring clean electricity certificates. The federal
government could direct funds to the U.S. Department of Energy (DOE) and national labs to track
and report state-by-state progress while providing customized technical assistance for statepolicymakers on how to reach the goal.
States will start from different clean electricity baselines. But given dramatic cost declines for key
electricity generation technologies the cleanest electricity available today is usually the cheapest
electricity, and the 2035 Report makes it clear that 90 percent zero carbon electricity isachievable while lowering customer electricity bills.7 The availability of low-cost zero carbon
electricity generation options puts us in a fundamentally different situation than even just a few
years ago. Moreover, a just and equitable transition to clean energy sources will spur substantial
economic development.

6 According to the Intergovernmental Panel on Climate Change, global emissions must reach net zero by 2050 for a reasonablechance of keeping global temperature rise less than 1.5 degrees Celsius. See “Summary for Policymakers of IPCC Special Reporton Global Warming of 1.5° C.” The Intergovernmental Panel on Climate Change October 2018. URL:
https://www.ipcc.ch/2018/10/08/summary-for-policymakers-of-ipcc-special-report-on-global-warming-of-1-5c-approved-bygovernments/; Energy Innovation’s “Net Zero Scenario,” reaches economy-wide net-zero emissions while employing a 100
percent clean electricity standard by 2050. See “Net Zero Scenario” Energy Innovation: Policy and Technology, LLC. November
2019. URL: https://us.energypolicy.solutions/scenarios/home.
7 Gimon, Eric and O’Boyle, Mike. “The Coal Cost Crossover: Economic Viability of Existing Coal Compared to New Local Wind andSolar Resources.” Energy Innovation: Policy and Technology, LLC. March 2019. URL:
https://energyinnovation.org/publication/the-coal-cost-crossover/; Teplin, Charles and Dyson, Mark et al. “The Growing Market
for Clean Energy Portfolios.” Rocky Mountain Institute 2019. URL: https://rmi.org/insight/clean-energy-portfolios-pipelines-andplants/; Dyson, Mark and Glazer, Grant et al. “Prospects for Gas Pipelines in the Era of Clean Energy.” Rocky Mountain Institute2019. URL: https://rmi.org/insight/clean-energy-portfolios-pipelines-and-plants/.

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States (generally via their public utilities commissions) should require regulated utilities toprocure these resources in a technology-neutral way (i.e., via all-source procurement8), allowing
all zero-carbon resources (including energy efficiency, storage, demand response, and other
distributed energy resources) to participate. Second, the all-source procurement should becompetitive, meaning the utility or other buyer would have to structure the solicitation as anopen request for offers that adheres to a set of standards to accommodate wide participation.
Third, it would treat uneconomic assets and the remaining balances on them as sunk costs, whileproviding for some combination of ratepayer and U.S.-backed securitization of those balances.
These actions could make the clean electricity transition very affordable in states that arestarting from a lower share of renewables.
A federal clean energy standard enacted by Congress, or an EPA successor to the Clean Power
Plan should ensure no state lags too far behind. EPA has significant authority to regulate GHGs
from new and existing power plants under Clean Air Act Section 111. Given the rapid decline intechnology costs demonstrated by the 2035 report and real-world contract prices, EPA should
consider requiring states to create implementation plans for rapid decarbonization of theirelectricity systems under a similar but more ambitious structure than the Clean Power Plan. Suchplans could require reductions GHGs from coal and gas plants given available, lower-cost
alternatives that avoid pollution, or plans could take a fleet-wide approach to meet the standard.
This includes carbon pollution limits for new gas plants. In the absence of a legislative clean
energy standard, an administrative standard becomes essential to a cost-effective, rapid
decarbonization of the U.S. electricity system.
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Pass a federal Clean Energy Standard with the following
schedule: 55 percent by 2025, 75 percent by 2030, 90
percent by 2035, 100 percent by 2045

Governors, state legislatures,
public utilities commissions

Pass Clean Energy Standards of 90 percent by 2035 (orearlier), 100 percent by 2045 (or earlier)

U.S. Environmental Protection Under Clean Air Act authority, require states to create
Agencyimplementation plans for rapid decarbonization of theirelectricity systems given the availability of lower-cost andlower-pollution alternatives, and limit carbon pollution fromnew gas-fired power plants.

8 Wilson, John D. and O’Boyle, Mike et al. “Making the Most of the Power Plant Market: Best Practices for All-Source Electric

Generation Procurement. Energy Innovation: Policy and Technology, LLC. and Southern Alliance for Clean Energy April 2020. URL:
https://energyinnovation.org/wp-content/uploads/2020/04/All-Source-Utility-Electricity-Generation-Procurement-BestPractices.pdf.

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SUPPORTING CLEAN ENERGY DEPLOYMENT AT SPEED AND SCALE
Beyond a clean energy standard, a suite of complementary policies can help clear the way forbuilding low-cost new clean energy at speed and scale.
TAX CREDITS
Right now, wind and solar projects equivalent to about half of the entire U.S. electric grid
capacity are waiting for approval from grid operators.9 But like many industries, the renewableenergy industry has been affected by the current COVID-19 pandemic and related economiccrisis. Some projects that were underway before widespread stay-at-home orders areexperiencing significant delays. In the first two months of COVID-19 hitting the U.S., more than
600,000 workers in the clean energy industry filed for unemployment.10 This is a critical time tosupport these industries that can provide good jobs for Americans across the country, once it issafe to return to development sites.
Thus, it will be important to extend11 the lifetime of the production tax credit for wind, and theinvestment tax credit for solar and solar-paired storage, following the Internal Revenue Service’s
rationale for increasing construction and safe harbor deadlines of these credits from four to five
years to accommodate the slowdowns in wind and solar projects due to COVID-19.12 This policy
is much more important in the absence of a federal clean energy standard – the 2035 Reportdemonstrates a 90 percent clean energy standard could drive rapid decarbonization and costdeclines without extending federal tax incentives.
It will also help to convert those tax credits to direct payments: Today, because of illiquidity, thegovernment only provides about 60 cents worth of incentive for every dollar it spends.13 Section
1603 of the American Recovery and Reinvestment Act (ARRA) converted tax credits to direct
payments, and Congress could adopt this provision again. An alternative accomplishing the same
goal is a refundable tax credit, wherein developers can receive the full value of the tax credit,
regardless of their tax liability14. Lawrence Berkeley National Lab found that Section 1603

9 544 GW Interconnection queues in the United States currently include 544 GW of wind, solar, and stand-alone battery storage,

roughly half of the 1,100 GW required. See Bolinger, Mark and Seel, Joachim et al. “Utility-Scale Solar: Empirical Trends in ProjectTechnology, Cost, Performance, and PPA Pricing in the United States - 2019 Edition Slides.” Lawrence Berkeley National
Laboratory 2019. URL: https://emp.lbl.gov/sites/default/files/lbnl_utility-scale_solar_2019_edition_slides_final.pdf.
10 “Clean Energy Unemployment Claims in COVID-19 Aftermath, April 2020.” E2 May 13, 2020. URL: https://e2.org/reports/clean-jobs-covid-economic-crisis-april-2020/.
11 Extend the “start of construction” and “placed in service” deadlines, as well as the program end-dates.
12 “COVID 19 Impacts on American Wind Industry and Mitigation Proposals.” American Wind Energy Association March 18, 2020.

URL: https://www.awea.org/Awea/media/Resources/COVID-19ImpactsonWindIndustryandMitigationProposalsforHill.pdf.
13 Varadarajan, Uday and Pierpoint, Brende, et al. “Supporting Renewables while Saving Taxpayers Money.” Climate Policy

Initiative September 2012. URL: https://climatepolicyinitiative.org/wp-content/uploads/2012/09/Supporting-Renewables-whileSaving-Taxpayers-Money.pdf.
14 Bhattacharyya, Bidisha. “Renewable Energy Tax Credits: The Case for Refundability.” Center for American Progress May 28,

2020. URL: https://www.americanprogress.org/issues/green/reports/2020/05/28/485411/renewable-energy-tax-credits-caserefundability/.

7

produced more than 51,000 short-term jobs last time, so this adjustment to program structure isgood for workers and good for the clean energy industry.15
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Extend existing tax credits for all zero-carbon electricity
sources, as well as electricity storage projects. Convert themto direct payments, or make them refundable.

BOLSTERING U.S. MANUFACTURING OF CLEAN ENERGY
Reaching 90 percent clean electricity by 2035 would require deploying an average of about 35
gigawatts (GW) of new solar each year, 36 GW of new wind each year, and 10 GW of new fourhour batteries each year.16 America’s current annual manufacturing capacity for solar is 7 GW17,
and wind is 9 GW.18 Manufacturing capacity for lithium ion batteries (the dominant grid-scalestorage technology solution today) will scale with demand for a much larger electric vehicle
market. A federal clean energy standard would provide a strong domestic demand for thesetechnologies, and could be designed to provide a guaranteed market for a substantiallyexpanded American manufacturing base for these technologies.
Direct financial support is a tried-and-true way to scale up American manufacturing. The ARRA
authorized a 30 percent tax credit for investments in advanced energy manufacturing projects,
which ended up totaling more than $2 billion in support. In the power generation business, forexample, this funding helped increase the share of domestically-produced wind turbine
components from 25 percent in 2006-2007 to 72 percent in 2012.19 The program wasoversubscribed and capped at $2.3 billion – future use of this tax credit should greatly increaseor remove caps in order to truly scale American clean energy manufacturing.
In the transport sector, the Advanced Technology Vehicles Manufacturing loan program helped
the American auto industry retool with $8 billion in loans and commitments to projects that
supported the production of more than four million fuel-efficient cars. The program saved
15 Bolinger, Mark and Wiser, Ryan et al. “Preliminary Evaluation of the Impact of the Section 1603 Treasury Grant Program on

Renewable Energy Deployment.” Lawrence Berkeley National Laboratory April 2010. URL: https://etapublications.lbl.gov/sites/default/files/report-lbnl-3188e.pdf.
16 In total, 518 GW of new solar by 2035, 540 GW of new wind, and 147 GW of total batteries. In particular, since the battery

industry is quite nascent, the real deployment schedule would likely start quite a bit lower than 10 GW in the early years, andramp up more in the later years.
17 Pickerel, Kelly. “The Largest Solar Panel Manufacturers in the United States by Capacity.” Solar Power World November 25,

2019. URL: https://www.solarpowerworldonline.com/2019/11/the-largest-solar-panel-manufacturers-in-the-united-states-bycapacity/.
18 “Wiser, Ryan and Bolinger, Mark. “2018 Wind Technologies Market Report.” Office of Energy Efficiency and Renewable Energy,

Department of Energy August 9, 2019. URL: https://emp.lbl.gov/sites/default/files/wtmr_final_for_posting_8-9-19.pdf.
19 “The Recovery Act Made the Largest Single Investment in Clean Energy in History, Driving the Deployment of Clean Energy,

Promoting Energy Efficiency, and Supporting Manufacturing.” Office of the Press Secretary, The White House February 25, 2016.
URL: https://obamawhitehouse.archives.gov/the-press-office/2016/02/25/fact-sheet-recovery-act-made-largest-singleinvestment-clean-energy.

833,000 jobs and boosted Tesla, which now employs more than 10,000 people at its Fremont,
California factory.20 Support for advanced manufacturing would come at a critical time as othermajor manufacturing nations in Europe and Asia are providing such transition support as part oftheir recovery packages.
Direct loans and loan guarantees leverage side-by-side funding from the private sector. Theylower the cost of advanced technologies as new business ventures always face higher interest
rates when seeking financing. DOE’s Loan Programs Office estimated $39 billion loan and loan
guarantee authority could leverage as much as $100 billion of private investments in innovative
approaches to modernizing energy infrastructures across all energy sectors. Congress should
accelerate access to this lending authority by allowing state and local governments to accessfederal financing, and empowering state and local actors to deliver project finance. These loan
programs are very cost effective for government; the Loan Programs Office had yielded theTreasury net receipts of more than $2 billion by 2015.21
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Reinstate the manufacturing tax credit used during theAmerican Recovery and Reinvestment Act to support
domestic manufacturing of clean energy technologies.

U.S. Congress; DOE

Fund a large increase in DOE’s capacity to provide low-cost
capital to companies with proven experience willing to
expand manufacturing capacity of solar, grid-scale storage,
and wind in the U.S.

DEALING WITH STRANDED ASSETS
Retiring coal has demonstrably positive economic and environmental impacts, but retiring power
plants can cause financial disruption for utilities22, due to the fact that utilities have continued toinvest in aging power plants and such capital costs are paid off over decades, usually at least 30
years. Under conventional state regulation, monopoly utilities have the right to charge

20 “Project Summary.” Department of Energy. Accessed June 5, 2020. URL:

https://www.energy.gov/lpo/ford#:~:text=ECONOMIC%20IMPACT,2009%20through%20Model%20Year%202013; Project
Summary.” Department of Energy Accessed June 5, 2020. URL: https://www.energy.gov/lpo/tesla; “Tesla Factory.” Tesla
Accessed June 5, 2020. URL: https://www.tesla.com/factory.
21 A report from the Government Accountability Office found program costs of $2.2 billion. The report notes “LPO-supported

companies have made approximately $4.4 billion in principal and interest payments to the US Treasury,” implying the programprovided net cash flow benefits of $2.2 billion through 2020. See “DOE Loan Programs Current Estimated Net Costs Include $2.2
Billion in Credit Subsidy, Plus Administrative Expenses.” Government Accountability Office April 2015. URL:
https://www.gao.gov/assets/670/669847.pdf.
22 Note this should not be considered a problem for power plants in restructured competitive power markets, because privatecompanies entered those markets to sell power, taking on the risk of resource changes over time. This is different than theregulated utility situation, because captive customers are left with the bill for undepreciated balances unless policymakers or
regulators step in to alleviate this.

9customers the full cost of paying off the remaining power plant balance, including risk-adjusted
returns for shareholders and creditors. Rural cooperatives and municipalities face similar credit
risks when unpaid coal debt remains long after the plant retires. The result: When new, cheap
renewables replace expensive, dirty generation, customers can get stuck with the bill for old
power plants, even when they’re no longer in use – unless policymakers step in to address this.
The 90 Percent Clean case in the 2035 Report retires the remainder of the U.S. coal fleet andreplaces it with clean power that is cheaper to build and operate than continuing to run theexisting coal plants. Coal capacity drops from over 200 GW in 2018 to zero by the end of 2035.
According to Carbon Tracker, over $200 billion is “owed” just to monopoly utilities (who own
more than half the existing fleet) on these power plants.23
Some of these costs will be repaid while coal plants operate less and less over the next 15 years,
while significant undepreciated capital costs could remain after retirement absent action by
regulators. In cases where capital owed on retired assets is significant, customers could realize
even greater savings from the clean energy transition by using cheap capital. Very low-interest
government-backed and rate-payer backed bonds can be used to pay the undepreciated bookvalue of early-retired coal plants. For government-backed bonds, the federal government could
consider buying retired coal assets for their remaining book value, socializing the costs thatwould otherwise be borne by customers of the monopoly utility. Using ratepayer-backed bonds
to buy down utility-owned retired coal plants would achieve similar savings on financing, but theremaining lower costs would be socialized only by those specific utility customers (at a much
lower interest rate).
In reality, the end of the coal fleet could be much faster; the marginal economics of coal get
exponentially worse as these plants run less and less.24 The COVID-19 crisis, for example, has laidbare the vulnerability of coal-fired power plants to market forces: Collapsing demand has mostly
resulted in running existing coal plants fewer hours, hastening the trend of renewables
generating more power on average than coal-fired generation.25 As the 2035 Report shows, wedon’t need these plants around for reliability, and as renewables and storage currently andincreasingly are the more cost-effective source of energy and other grid services, the justification
for keeping these plants around evaporates.
Government-backed or ratepayer-backed bonds can be important tools to reduce the cost of
retiring uneconomic coal-fired plants. Selling the undepreciated balances to bond-holders iscommonly referred to as “securitization.” Whether state legislation is needed for securitization
varies – about half of states already have authorizing legislation on the books, as the tool was

23 Gray, Matt and Watson, Laurence. “No Country for Coal Gen – Below 2°C and Regulatory Risk for U.S. Coal Power Owners.”

Carbon Tracker September 2017. URL: https://carbontracker.org/reports/no-country-for-coal-gen-below-2c-and-regulatory-riskfor-us-coal-power-owners/.
24 “The Coal Cost Crossover: Economic Viability of Existing Coal Compared to New Local Wind and Solar Resources.” Energy

Innovation March 2019.
25 Plumer, Brad. “In a First Renewable Energy is Poised to Eclipse Coal in the U.S.” New York Times May 13, 2020. URL:

https://www.nytimes.com/2020/05/13/climate/coronavirus-coal-electricity-renewables.html

10used during utility restructuring in the late 1990s, and to pay for large unforeseen capital
investments like storm recovery. Legislators can consider Colorado's legislation authorizing coaldebt securitization as a model in achieving a balance between ratepayer, public, impacted
community, and utility interests.26
Our modeling also shows we don’t need to build any new natural gas-fired power plants to meeta 90 percent clean energy standard. Current utility plans to spend over $100 billion to build atleast 88 GW of natural gas27 capacity would exacerbate stranded asset risk for both generationand supporting pipeline infrastructure, conflicting with many of the same utilities’ plans (andclimate plans on their host states) to reach net-zero emissions by 2050.28 In general, theeconomics of these projects are inferior to portfolios of clean energy resources explored in the2035 Report, and described in further detail by the Rocky Mountain Institute (RMI).29
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Offer federal debt financing for utilities where compliancewith clean energy standards leads to coal and gas closures,and regulated utilities have reasonable outstanding unpaidbalances on those plants.

State Public Utility
Commissions

Prohibit regulated utility investment in new natural gas, unlessthere is a clear, demonstrated need with no reasonable clean
alternative; require explanation of how such investments
would benefit customers, coexist with rapid clean energy
deployment, and remain useful over the lifetime of the asset.

State Legislatures

Authorize public utility commissions to create ratepayerbacked bonds that securitize uneconomic coal and gas units,
relieving utility customers of the obligation to pay high costsof capital, while making utilities whole for their reasonable
investments. Include funding for supporting workers andcommunities in these financial plans.

26 “Colorado Energy Impact Assistance Act.” HB19-1037. 2019 Regular Session. URL: https://leg.colorado.gov/bills/hb19-

1037#:~:text=The%20bill%2C%20known%20as%20the,the%20cost%20to%20electric%20utility.
27 “A Bridge Backward? The Financial Risks of the ‘Rush to Gas’ in the U.S. Power Sector” Rocky Mountain Institute URL:

https://rmi.org/wp-content/uploads/2019/09/clean-energy-portfolio-two-pager.pdf.
28 Holzman, Lila and O’Boyle, Mike. “Natural Gas: A Bridge to Climate Breakdown” As You Sow and Energy Innovation, LLC. March

2020. URL: https://energyinnovation.org/wp-content/uploads/2020/03/Natural-Gas_A-Bridge-to-Climate-Breakdown.pdf.
29 “The Growing Market for Clean Energy Portfolios.” Rocky Mountain Institute 2019 and “Prospects for Gas Pipelines in the Era of

Clean Energy.” Rocky Mountain Institute 2019.

11

PERMITTING AND SITINGWind and solar plants require significant but manageable land area. In the 90 Percent Clean casein the 2035 Report, we anticipate that 515 GW of ground-mounted solar generation30 would
occupy 13,200 square kilometers (km2) of land.31 The additional 596 GW of wind capacity would
require 149,000 km2 of land, though only 10 percent of this space would be unusable, with theother 90 percent continuing to allow farming and grazing between the turbines. Thus, 596 GW ofwind would occupy about 15,000 km2 of land, sited on 149,000 km2 of farmland. This combined
amount of occupied land for new wind and solar installations, 28,200 km2, is about triple theland currently devoted to golf courses, and equivalent to about half the land owned by the
Department of Defense.32
Reducing permitting and siting conflicts by pre-screening federal and state lands for suitability is
crucial to enable this rapid buildout of new renewable resources and associated transmission.
This is already ongoing in the Western U.S., through the federal West-wide Energy Corridors33
planning process. The planning process identifies continuous strips of federal land acrossjurisdictional boundaries suitable for transmission development. Federal agencies have alsoprescreened areas of ideal development for solar energy in six Western states (Solar Energy
Zones)34 and offshore wind energy off the Atlantic Coast (Wind Energy Zones).35 Texas also
provides a model with a history of pre-approving and building out transmission to “Competitive
Renewable Energy Zones” where clean energy resources are abundant.
Robust stakeholder engagement minimizes environmental, cultural and other stakeholder
conflicts. Eventually, these processes streamline federal siting, review, and permitting processes
for developers. Each site receives streamlined approval because it undergoes National
Environmental Policy Act review and responds to local stakeholder concerns before it is leased todevelopers. Efforts to engage with private landowners are crucial to completing many of thecorridors will increase the likelihood of success.

30 About 60 GW of solar is on rooftops in the 90 percent Clean case.
31 Ong, Sean and Campbell, Clinton et al. “Land-Use Requirements for Solar Power Plants in the United States.” National

Renewable Energy Laboratory. June 2013. URL: https://www.nrel.gov/docs/fy13osti/56290.pdf.
32 654 million acres are dedicated to grazing. See Merrill, Dave and Leatherby, Lauren. “Here’s How America Uses Its Land.”

Bloomberg July 31, 2018. URL: https://www.bloomberg.com/graphics/2018-us-land-use/.
33 “West-wide Energy Corridor Information Center.” Bureau of Land Management, National Forest Service, and Department ofEnergy. Accessed June 5, 2020. URL: http://corridoreis.anl.gov/.
34 “Approved Resource Manage Plan Amendments/Record of Decision (ROD) for Solar Energy Development in Six SouthwesternStates” Bureau of Land Management October 2012. URL: http://blmsolar.anl.gov/documents/docs/peis/Solar_PEIS_ROD.pdf.
35 “Wind Planning Areas.” Bureau of Ocean Management. Accessed June 5, 2020. URL:

https://www.boem.gov/sites/default/files/renewable-energy-program/Mapping-andData/BOEM_Wind_Planning_Areas_12_15_2016_metadata.pdf.

12Data is also key to pre-screening renewable resource and transmission areas. The WesternElectricity Coordination Council has developed the Environment Data Viewer,36 a tool that should
be expanded for the rest of the U.S. to enable smart infrastructure development. The tool uses
Geographic Information Systems data for different land conflicts, enabling users to create mapsof low-conflict land. For example, existing rights of way are the lowest conflict (green), while lowconflict undeveloped land is yellow, and land with explicit environmental, infrastructure, or
cultural conflicts ranges from orange to red. The tool uses professional judgment of transmission
planners, Bureau of Land Management and U.S. Forest Service, environmental leaders and evenarchaeologists to build the classifications in the tool.
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Require the Department of Energy and Department ofInterior to develop and update national energy corridors andrenewable energy zones, and publish a national database ofland conflicts to facilitate development and responsible siting.

INTERCONNECTION AND TRANSMISSION PLANNING REFORM
Today’s grid operator and state regulatory approaches to transmission planning and generationinterconnection are not up to the task of delivering a low-carbon grid at speed and scale. While544 GW of renewable generation lies in wait to interconnect to high-voltage transmission
systems37 – nearly half of the capacity needed to meet a 90 percent clean energy standard –these projects face unreasonably high barriers due to conventional interconnection rules. Rather
than investing in transmission planning that would more efficiently serve society’s economic andpolicy goals, today’s rules typically require every new generation resource to separately pay grid
upgrade costs to interconnect their power plant the system, when there would be far greater
societal benefit to view transmission planning and upgrades with a more holistic regional
perspective. The Federal Energy Regulatory Commission (FERC) should exercise its authority andexpand its capacity to require regional transmission expansion and simplified interconnection
rules that support the realities of society’s policy goals and a 90 percent by 2035 clean energy
standard.
Transmission networks can be planned in advance to accommodate a sensible mix of very lowcost renewable resources, creating net benefits for customers, and Congress should reform
FERC’s electric transmission authority to support the changing electricity system in a costeffective manner. To begin, cost-allocation should be driven by analysis of the benefits38 and36 “Environmental Data Viewer.” Western Electricity Coordinating Council. Accessed June 5, 2020.

https://ecosystems.azurewebsites.net/WECC/Environmental/.
37 These include both RTO and non-RTO transmission systems. See “Utility-Scale Solar: Empirical Trends in Project Technology,

Cost, Performance, and PPA Pricing in the United States - 2019 Edition.” Lawrence Berkeley National Laboratory 2019.
38 Benefits should include quantifiable environmental, resilience, and public policy benefits, in addition to direct economic
benefits. The basic idea is to codify the lax suggestions of FERC Order 1000. The Midcontinent Independent System Operator

13

balanced by a consideration of the negative factors beyond direct cost (e.g., land-use impact,
landscape degradation, habitat disruption). Congress could give FERC a clearer mandate toenforce and expand Order 1000 (FERC’s regional transmission planning order), by requiring
timely plans, accounting for public policy in planning, and allocating regional costs tobeneficiaries where regions fall short.39
The Midcontinent Independent System Operator (MISO) Multi-Value Project (MVP) transmission
expansion plan (submitted to FERC for approval in 2011) provides an example of regional costallocation that benefits all electricity customers. The MVP portfolio proactively identified
regional transmission solutions, or MVPs, that meet one or more of three goals. These lines:•••

Reliably and economically enable regional public policy needs,
Provide multiple types of regional economic value, and/or
Provide a combination of regional reliability and economic value.

The costs of this MVP portfolio were allocated across the region, rather than only to specificdevelopers, utilities, states or market participants. The results from the most recent review ofthe program speak for themselves:•••

Benefits in excess of its costs, with a benefit-to-cost ratio ranging from 2.2 to 3.4;
$12.1 to $52.6 billion in net benefits over the next 20 to 40 years;
Enabling 52.8 million megawatt-hours of wind energy to meet renewable energy
mandates and goals through year 203140.

Duplicating MISO’s cost allocation and adopting a more comprehensive, proactive regional
planning approach in the rest of the country could reduce interconnection queue waiting times
and improve the risk for developers, while benefiting all electricity customers throughout aregion. Such planning processes could build on the intent of Order 1000 but strengthen its
requirements to account for public policies, allocate costs, and submit meaningful regional plans.
This should also apply to FERC-jurisdictional transmission outside the nation’s independent
system operators (ISOs) and regional transmission organizations (RTOs).
Congress could also push FERC to act on cost-allocation for new multi-state transmission lines.
Though these lines do not feature prominently in the 2035 Report, their benefits are clear fromother modeling exercises.41 For example, FERC should encourage high voltage inter-regional(MISO) Multi-Value Projects methodology is a model to consider building upon. See “Multi-Value Projects (MVPs).” Midcontinent
Independent System Operator, Inc. URL: https://www.misoenergy.org/planning/planning/multi-value-projects-mvps.
39 See Holden, Emily. “State Regulators, Clean Energy Advocates Square Off on Bill Pre-empting Power Line Siting Authority.” E&E

News April 22, 2015. URL: https://governorswindenergycoalition.org/state-regulators-clean-energy-advocates-square-off-on-billpre-empting-power-line-siting-authority/.
40 “A 2017 Review of the Public Policy Economic, and Qualitative Benefits of the Multi-Value Project Portfolio.” Midcontinent

Independent System Operator, Inc. September 2017. URL:
https://cdn.misoenergy.org/MTEP17%20MVP%20Triennial%20Review%20Report117065.pdf.
41 Bloom, Aaron. “Interconnections Seam Study.” National Renewable Energy Lab 2018. URL:

https://www.terrawatts.com/seams-transgridx-2018.pdf.; MacDonald, Alexander E. and Clack, Christopher T.M. et al. “Future
Cost-Competitive Electricity Systems and Their Impact on U.S. CO2 Emissions.” Nature Climate Change January 2016. URL:
https://research.noaa.gov/article/ArtMID/587/ArticleID/542/Rapid-affordable-energy-transformation-possible.

14

transmission to access least-cost (and clean) resources, by requiring regional Order 1000
Planning Authorities to develop compatible models (incorporating state energy resource plans)
and pursue interregional transmission where benefits exceed costs. Alternatively, Congress could
vest DOE with authority to plan large interregional lines, reducing complexity of coordinatingplanning between regions. A more holistic cost benefit analysis of this nature can also help
address the most common reason many important transmission lines have failed: disagreements
between states over how to fairly allocate costs. For multistate lines, FERC could require states
denying a regionally beneficial line to demonstrate certain criteria are met to justify denial,similar to the rate design structure used in the Public Utility Regulatory Policy Act.
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Affirm FERC’s authority for transmission cost allocation andplanning for public policy impacts to the grid, including regions
outside of ISOs/RTOs. Give particular attention to the federal
clean energy standard, or in its absence state and utility clean
electricity goals. Make clear the intention to reduce
interconnection queue times and require beneficiary
customers to pay their fair share.

U.S. Congress

Provide states with matching funds to pay for interstatetransmission lines with demonstrable reliability, cost, andrenewable integration benefits. Consider vesting DOE withauthority to plan for and site interregional transmission lines
to streamline development of the nation’s most crucial andbeneficial long-distance transmission projects.

FERC

Exercise authority to require regional transmission expansion
and simplified interconnection rules that support the realities
of society’s policy goals and a 90% by 2035 clean energy
standard.

FERC

Require regional Planning Authorities to develop compatiblemodels (incorporating state energy resource plans) andpursue transmission where benefits exceed costs. Require
states denying a regionally beneficial line to demonstratecertain criteria are met to justify denial.

FERC

Require regional transmission planning bodies created under
FERC Order 1000 to propose to FERC multi-value transmission
projects, accounting for state and federal clean energy
policies, with Federal authority to promulgate a costallocation methodology where regions fail to act.

15

SUPPORT FOR AN EQUITABLE AND FAIR TRANSITION
The 90 Percent Clean case in the 2035 Report results in a net increase of 8.5 million job-years by
2035, or approximately 530,000 total jobs annually, as employment from expanding renewableenergy and battery storage more than replaces jobs previously supported by the extraction,transport, and burning of coal and gas. Americans as a whole will have more jobs, but jobs lost incoal will be particularly acute, approaching zero in 2035 and geographically concentrated aroundplants and mines. Coal-fired electric power generation employed a total of 86,000 U.S. workers
in 2018, alongside 75,000 workers in coal fuels.42 Policy must ensure these communities are notleft behind, but rather strengthened by a federal clean energy standard.
Coal’s decline is already impacting communities and the need for supporting these communities
is abundantly clear. Three kinds of policies can help overcome these negative community
impacts: transition assistance to assure basic services and community income do not collapse,
reinvestment in clean energy and environmental restoration in these communities, and job
retraining to provide new economic opportunity for anyone who wants to join the clean energy
transition workforce.
Communities currently involved in fossil fuel extraction often rely heavily on current tax revenue
to sustain municipal services; pensions also provide economic security to workers who have inmany cases endangered themselves to earn a decent living and provide energy powering
America’s prosperity. With the coal industry’s collapse, federal programs must shore up both,
ensuring these communities and workers can transition to a sustainable economic future.
The first step is providing stopgap funding to supplement the tax base provided by retired coalinfrastructure. Colorado provides one model for this – new legislation created a “Just Transition
Office,” empowering it to submit a plan to the legislature to establish benefits including
supplementing tax revenue and healthcare benefits to coal transition communities.43 The next
step is to shore up federal programs that sustain pensions owed to coal workers: The Black Lung
Disability Trust Fund is currently $6 billion in debt,44 while the Pension Benefits Corporation
faced a $53.9 billion deficit in 2018 and is on a path to insolvency by 2025.45
Policy can also create new employment opportunities in these communities and ensure the newjobs are family-supporting careers. The first is environmental remediation, as coal plant
retirements leave ash ponds and mine reclamation as major public works to restore the land andensure community health. This fund could build on and expand the 2019 RECLAIM Act, which

42 “2019 U.S. Energy & Employment Report.” Energy Futures Initiative and National Association of State Energy Officials URL:

https://static1.squarespace.com/static/5a98cf80ec4eb7c5cd928c61/t/5c7f3708fa0d6036d7120d8f/1551849054549/USEER+201
9+US+Energy+Employment+Report.pdf.
43 “Just Transition from Coal-Based Electrical Energy Economy.” Colorado HB19-1314. 2019 Regular Session URL:
https://leg.colorado.gov/bills/hb19-1314.
44 “Black Lung Benefits Program: Options for Improving Trust Fund Finances.” Government Accountability Office May 2018. URL:
https://www.gao.gov/assets/700/692103.pdf.
45 Manganaro, John. “PBGC Fiscal Year 2018 Report Highlights.” Plan Sponsor November 16, 2018. URL:
https://www.plansponsor.com/pbgc-fiscal-year-2018-report-highlights/.

16

had more than a dozen Republican co-sponsors, and proposed appropriating $1 billion for the
Abandoned Mine Reclamation Fund to revitalize communities hardest hit by the downturn of thecoal industry. The Center for American Progress estimates that a $2 billion investment in orphan
oil and gas well clean-up has the potential to create 14,000 to 24,000 jobs in energy producing
states.46 Providing universal broadband access is another force multiplier for economic
opportunity in rural coal communities.
Thankfully, more than two thirds of coal power used in America has high-quality renewable
resources and suitable land within 35 miles, such that wind or solar can replace these plants at
immediate savings to customers;47 that share grows to 86 percent by 2025. New wind and solar
built near these old plants could put people in the same community to work, and would also takeadvantage of transmission freed up by retiring coal, obviating the need for new and costly lines.
However, while clean energy workers earn higher and more equitable wages when compared to
all workers nationally,48 coal plant operators tend to earn substantially more on average thanclean energy production workers.49
Congress should increase tax incentives (or more liquid cash grants) for wind and solar
developers if projects are sited near coal communities. To support job quality, access to the
incentives can be conditioned on offering training programs for workers from these communities
to work on construction and maintenance of new facilities, as well as meeting certain labor
standards such as ensuring high-quality benefits, living wages, rights to organize, andapprenticeship opportunities.50 Coal workers are not going to be enough to fill the national needfor a renewable workforce however, federal funds must address the need for job training tosupport the rapid growth of these industries under a 90 percent clean energy standard.

46 Kelly, Kate and Rowland-Shea, Jenny. “How Congress Can Help Energy States Weather the Oil Bust During the Coronavirus

Pandemic.” Center for American Progress April 29, 2020. URL:
https://www.americanprogress.org/issues/green/reports/2020/04/29/484158/congress-can-help-energy-states-weather-oilbust-coronavirus-pandemic/
47 “The Coal Cost Crossover: Economic Viability of Existing Coal Compared to New Local Wind and Solar Resources.” Energy

Innovation March 2019.
48 Muro, Mark and Tomer, Adie et al. “Advancing Inclusion Through Clean Energy Jobs.” Brookings Metropolitan Policy Program

April 2019. https://www.brookings.edu/wp-content/uploads/2019/04/2019.04_metro_Clean-Energy-Jobs_Report_Muro-TomerShivaran-Kane.pdf.
49 Coal power plant workers earn $36/26/hour on average, while clean energy production workers earn $28.41. See “2019 U.S.

Energy & Employment Report.” Energy Futures Initiative and National Association of State Energy Officials URL:
https://static1.squarespace.com/static/5a98cf80ec4eb7c5cd928c61/t/5c7f3708fa0d6036d7120d8f/1551849054549/USEER+201
9+US+Energy+Employment+Report.pdf; For clean wage see “Advancing Inclusion Through Clean Energy Jobs.” Brookings
Metropolitan Policy Program April 2019.
50 “Good Jobs for 21st Century Energy Act.” S.2185. 116th Congress URL: https://www.merkley.senate.gov/news/press-

releases/merkley-trumka-senate-democrats-announce-major-new-legislation-to-create-good-paying-jobs-in-the-transition-toclean-energy-2019.

17

Who Can Get It Done

Decision-maker

PolicyU.S. Congress; State
Legislatures

Provide stopgap funding to supplement the tax base provided
by retired coal infrastructure. Consider setting up a national
Just Transition Office with state satellite offices.

U.S. Congress

Shore up federal programs that sustain pensions for coal
workers: including the Black Lung Disability Trust Fund andPension Benefits Corporation.

U.S. Congress

Build on and expand the 2019 RECLAIM Act, which proposed
appropriating $1 billion for the Abandoned Mine Reclamation
Fund to revitalize communities hardest hit by the downturnof the coal industry.

U.S. Congress

Increase tax incentives (or more liquid cash grants) for windand solar developers if sited near coal communities. Condition
incentives on training and employing workers from thesecommunities to work on construction and maintenance of
new facilities, as well as increased labor standards.

U.S. Congress; Dept. of Labor

Address the need for job training to support the rapid growthof these industries under a 90 percent clean energy standard.

ADDRESSING MARKET FAILURES IN WHOLESALE MARKETSIn the 2035 Report, variable renewables dominate new additions to the power supply withcomplementary gas, storage, and hydro resources providing needed flexibility. But even though
the resulting resource mix is lower cost than today’s system, current market structures are not
likely to support the required investment to deliver this resource mix – existing market
structures are more likely to stand in the way by skewing investment toward uneconomic fossil
resources.
When they were first created, competitive markets for electricity, or RTOs/ISOs, were designed
around the technical elements of the grid at the time. Grid operators dispatched large central
station power plants to follow inflexible load, with power flowing in one direction from thesecentral generators out to customers. RTOs/ISOs managed the scheduling and dispatch of thesepower plants, ensuring they had enough to meet relatively predictable demand. While thissystem and its concomitant rules, procedures, and definitions seemed reasonable when it was
designed 20 years ago, it is increasingly strained as the grid modernizes and zero-carbon
electricity makes up a greater share of the total. These markets need an upgrade to ensure they
are finding the least-cost, reliable solution for customers as new technologies become available
and the resource mix changes.

18

The system no longer generates the majority of its energy from large baseload power plants, andis transitioning to a highly flexible system made up of many smaller, more modular resources.
New carbon- and fuel-free resources are available that have different characteristics. Low-costbattery storage is a flexible source of grid services and creates new opportunities to shift supply
and demand. New demand-side technologies enable grid operators to send price signals that, forthe first time, can allow supply and demand to be truly co-optimized. It is an exciting time of new
options for grid managers, but the market structure has not adequately adjusted to thesechanges.
The keys will be truly allowing all technologies that can provide reliable service to compete on
equal footing and exposing the value of grid flexibility.
In particular, the 2035 Report shows the importance of flexible resources to complement a leastcost, renewables dominant system. While 450 GW of natural gas (down from 537 GW in 201851)
operational in the scenario with 90 percent zero-carbon electricity, that gas operates at around a
10 percent capacity factor, providing flexibility and energy when wind and solar are in occasional
short supply. But other resources not modeled (e.g. demand-side resources), or notcommercialized today (e.g. long-duration storage), could provide similar services. New markets
will have to pay for these services – the modeling suggests that keeping natural gas plants
around but idle most of the time is a conservative solution against which other new technologies
should compete to provide these flexibility and energy services in a technology-neutral market
structure.
PRINCIPLES
The set of ten principles below are intended to ensure technology neutrality and achievement of
power system goals at least cost in the RTO/ISO construct.52 Wholesale electricity markets
should:
•

•
•
•

•

Accommodate rapid decarbonization, including the elimination of barriers toparticipation of zero carbon resources.
Support grid reliability, up to the amount that customers would knowingly be willing topay.
Facilitate demand-side participation and grid flexibility.
Keep costs affordable for customers by promoting short-run economic efficiency throughoptimized dispatch of the lowest-cost resource mix, and the use of both existing andemerging technologies that can manage reliability and congestion.
Keep costs affordable for customers by promoting long-run economic efficiency—
including efficient, competitive entry to and exit from the market—under conditions ofsignificant uncertainty.

51 “Table 4.3 Existing Capacity by Energy Source, 2018.” Electric Power Annual. Energy Information Administration October 18,

2019. URL: https://www.eia.gov/electricity/annual/html/epa_04_03.html.
52 Aggarwal, Sonia and Corneli, Steven et al. “Wholesale Electricity Market Design for Rapid Decarbonization.” Energy Innovation:

Policy and Technology, LLC. June 2019. URL: https://energyinnovation.org/wp-content/uploads/2019/07/Wholesale-ElectricityMarket-Design-For-Rapid-Decarbonization.pdf.

19

•
•

•

•
•

Minimize the exercise of market power and manipulation.
Minimize the potential for distortions and interventions that would prevent or limit
markets’ ability to achieve efficient outcomes, consistent with the public interest(including overarching public interest in a sustainable environment and economy).
Enable adequate financing of resources needed to deliver cost-effective reliability, basedon an efficient allocation of risk (i.e., those that can best mitigate risk should bear it).
Customers should not be on the hook for poor investment decisions made by private
investors.
Be capable of integrating new technology as electricity needs evolve, and adapting astechnology changes.
Have designs that are readily and realistically implementable.

REQUIRED MARKET REFORMS
Public participation in wholesale market governance
The RTOs/ISOs that run the U.S. regional wholesale electricity markets are, in large part,
captured by the incumbent transmission owners and generators they regulate.53 RTO/ISO
governance structures are not prescribed by FERC, so each regional wholesale market’s
governance structure is unique. But governance ultimately impacts how responsive these
entities are to different perspectives, and RTO/ISO governance structures create an outsized rolefor regulated transmission and generation owners to influence market rule changes and RTO/ISO
proposals.
By contrast, consumer, state, clean technology, and environmental stakeholders in many
wholesale markets have limited opportunity to participate in market rule changes and proposals
and vastly fewer resources to support their participation. As a result, RTO/ISO proposals tend tofavor incumbents, stifle innovation, and lack upfront input from state, consumer, andenvironmental interests that have to then battle bad proposals in FERC-regulated dockets.54
Court decisions have prevented FERC from fixing flawed governance.
Congress could introduce legislation clarifying FERC’s authority to direct or modify RTO/ISO
governance, and providing a framework for evaluating stakeholder and state regulator access todecision-making.
Expose the Value of Flexibility
The transformation of the resource mix both benefits from an increasing amount of flexibility
and provides the means of providing such flexibility. For example, as solar makes up a higher
share of electricity generation in the California Independent System Operator region, grid
operators need more ramping capability to allow full use of the solar electricity and other clean
energy resources. Flexibility comes in many forms, but is not something market operators have

53 Simeone, Christina. “PJM Governance: Can Reforms Improve Outcomes?” Kleinman Center for Energy Policy May 19, 2017.

URL: https://kleinmanenergy.upenn.edu/sites/default/files/proceedingsreports/PJM%20Governance%20Reforms.pdf
54 Simeone, Christina. “PJM Governance: Can Reforms Improve Outcomes?” Kleinman Center for Energy Policy May 19, 2017.

20

traditionally considered when designing products or procuring new resources. In fact, several
RTOs/ISOs rely heavily on markets for capacity, which is typically defined as megawatts of power
available year-round. As the grid evolves and more wind and solar come online, capacity
becomes too blunt an instrument. A focus on flexibility is more prescient.
The best way to create value for flexibility is to enhance price signals in the energy markets
themselves, to ensure they are rewarding flexible resources. Examples include reducing or
eliminating dependence on capacity markets; raising or removing the price caps, which would
incent resources to be available and have the flexibility to produce during times of system need;adopting reserve shortage adders like operating reserve demand curves, which better reflect thevalue of resources to the system as it approaches a shortage; and creating specific market
products that pay for and obtain the type of flexibility needed by grid operators. RTOs/ISOsshould test and demonstrate how demand-side and clean energy resources can participate as
aggregated resources, and provide these services reliably through pilots (see also “all-source
procurement” recommendations, below).
Require All Generators and Imports to Participate in Economic Dispatch
In wholesale electricity markets, some amount of self-scheduling occurs where power plant
operators, for a range of reasons, choose to run their plants regardless of the real-time market
price of electricity. Valid reasons sometimes exist for choosing to self-schedule. For example, ahydro plant may not be able to reduce its output if doing so means that it will overflow or violate
environmental constraints.
Though valid instances do exist, in practice self-scheduling is often the product of contract terms
benefitting the utility while shifting risk to customers, rather than the presence of technicallimitations on a resource.55 When self-scheduling makes up a significant share of the total
amount of electricity available to market operators, it can introduce challenges to operating thegrid flexibly. The challenge is in the fact that if power plants are price-takers (i.e. they will
dispatch at any price) then they are not responsive to changes in the market prices that reflect
the constraints of the electric grid at any given time and would otherwise elicit flexibility. Selfscheduling decisions can also squeeze out renewables from providing zero-marginal-cost power
and thereby increase customer costs.
All FERC-jurisdictional utilities and generators, including imports and renewables, should be
required to participate in economic dispatch. Enforcing this in organized wholesale markets
requires only a rule change from FERC or the RTOs/ISOs, but in vertically integrated markets, theshift would be more significant. Even in vertically integrated markets, wholesale power isavailable from other utilities; utility efforts to dispatch their own generation prejudicesindependent power producers and excess power from neighboring utilities, resulting in higher
customer costs. FERC should explore the relationship between vertical utilities’ self-dispatch andthe ability for wholesale entities to access new markets with cheaper power, and consider
55 Daniel, Joseph. “The Billion-Dollar Coal Bailout Nobody is Talking About: Self-Committing in Power Markets.” Union ofConcerned Scientists June 3, 2019. URL: https://blog.ucsusa.org/joseph-daniel/billion-dollar-coal-bailout-nobody-is-talking-about.

21

limiting uneconomic dispatch within vertically integrated non-RTO/ISO utilities to achieve justand reasonable wholesale rates.
Minimize Restrictions on Resource Participation
As new technologies emerge and request to participate in the market, RTOs/ISOs have often
reacted by imposing restrictions on the types of connections and services those technologies canoffer. The emphasis should be on approaches that allow any resource, including aggregations or
subsystems of smaller demand-side resources, to participate in providing any services that they
are technically capable of providing in a performance-based, technology-agnostic way.
For example, wind and solar can also provide flexibility to the grid, but are often restricted fromdoing so effectively. Under a more open participation model, wind, solar, storage, and demandside resources could offer many flexibility services currently provided by fossil plants. One
analysis found that allowing solar to pre-curtail and provide ramping services in the California
market counterintuitively resulted in less involuntary curtailment, less gas burn, and greater
flexibility.56 Inconsistent responses to FERC Order 841, which requires each RTO/ISO to define
participation models for energy storage, and FERC’s responsive review of proposals prejudicial tostorage, exemplify this issue and an appropriate regulatory response.57
Varied approaches to aggregating demand-side resources, and limits on their participation also
prejudices markets toward conventional solutions. RTOs/ISOs should be required to facilitatemeans by which demand-side resources can fully participate through aggregation. This includes
allowing aggregators or distribution utilities to participate directly in RTO/ISO markets rather
than requiring these resources be controlled directly by RTOs/ISOs. Addressing restrictions on
resource participation can tap into a significant amount of flexibility that is available today but
going unused.
Pay for Uncompensated Reliability Services
An evolving resource mix on the grid will increase the value of certain grid services while
decreasing the value of others. For example, turbine-based generators (including steam and gas
turbines) provide inertia and frequency response (through governor response) and this is a
useful response after a major transmission or power plant outage. Because turbine-based
generators have been ubiquitous in the past, RTOs/ISOs did not see a need to specificallyprocure frequency response (other than through standards) or indeed to even pay for thisservice, and grid operating practices have adjusted to the relatively slow frequency response
provide by such resources. However, the growth in inverter-based resources (such as wind, solar,

56 “Investigating the Economic Value of Flexible Solar Power Plant Operations.” Energy and Environmental Economics, Inc.

October 2018. URL: https://www.ethree.com/wp-content/uploads/2018/10/Investigating-the-Economic-Value-of-Flexible-SolarPower-Plant-Operation.pdf; Nelson, James H. and Wisland, Laura. “Electricity in California: The Role of Non-Flexibility in a Cleaner
Electricity Grid.” Union of Concerned Scientists August 2015.
https://www.ucsusa.org/sites/default/files/attach/2015/08/Achieving-50-Percent-Renewable-Electricity-In-California.pdf.
57 Gramlich, Rob and Goggin, Michael. “Too Much of a Wrong Thing: The Need for Capacity Market Replacement or Reform.”

Grid Strategies, LLC. November 2019. http://eelp.law.harvard.edu/wp-content/uploads/Ari-and-Jason-Burwen-TranscriptFinal.pdf.

22batteries and many newer loads) means that less of this traditional frequency response may beavailable to system operators over time.
However, using the power electronics and software of their modern inverters, wind, solar, andbattery resources can provide almost any desired grid behaviors, including frequency response
and other grid-support services, and can do so with great speed and accuracy.58 However, an
opportunity cost may exist for these resources to provide these services, and the ideal grid
service may be different from the service that conventional generators were capable ofproviding, so a new product should be defined and market mechanisms should be created toencourage provision of the services from whichever resources can do so with the lowest cost
and the greatest benefit to the grid.
As new resources enter the electricity mix and create value for new and different services,
RTOs/ISOs should create new products that expose the value of these services and encourage
their provision at least cost.
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Introduce legislation clarifying FERC’s authority to direct ormodify the governance of RTOs/ISOs, and providing aframework for evaluating stakeholder and state regulator
access to decision-making.
Enhance price signals in the energy markets themselves.
Reduce or eliminate dependence on capacity markets; raiseor remove the cap on scarcity prices; and adopt reserve
shortage adders like operating reserve demand curves, which
better reflect the value of resources to the system as it
approaches a shortage.
Keeping in mind a preference for enhancing energy pricesignals and reducing dependence on capacity-likemechanisms, expose the value of flexibility through specificproducts that pay for and obtain the type of flexibility that has
system value.
Require all generators participating in wholesale markets,
including imports and renewables, to participate in economic
dispatch. Consider expanding this requirement to nonRTO/ISO, FERC-jurisdictional utilities and generators.
Address restrictions on resource participation in energy,
ancillary services, and capacity markets, particularly wind,solar, storage, efficiency, and demand response. Continue
and build on the work of Order 841.

FERC,RTOs/ISOs

FERC, RTOs/ISOs

FERC, RTOs/ISOs

FERC, RTOs/ISOs

58 Loutan, Clyde and Klauer, Peter et al. “Demonstration of Essential Reliability Services by a 300-MW Solar Photovoltaic Power

Plant.” National Renewable Energy Laboratory April 2017. URL: https://www.nrel.gov/docs/fy17osti/67799.pdf

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DOE/National Labs

FERC, RTOs/ISOs

Work with FERC and RTOs/ISOs to develop useful technology
pilots, model language to increase resource participation, andmodel rules to pay for flexibility.
As new resources enter the electricity mix and create value
for new and different ancillary services, RTOs/ISOs should
create new products that expose the value of these services
and allow encourage their provision at least cost.

REMAKING UTILITY REGULATION FOR THE MODERN GRID
In the U.S., federal and state jurisdiction over electricity industry is split – the federal
government regulates wholesale electricity sales under the authority granted to Congress fromthe Interstate Commerce Clause of the Constitution, while the rest (typically characterized asretail sales) is left to the states. Due to natural electricity grid monopoly characteristics,
monopoly distribution utilities of some kind will always serve as an interface between customers
and the bulk grid system. State utility commissions govern monopoly distribution utilities, andplay a primary role in ensuring these entities meaningfully contribute to a low-cost, reliable
electricity future.
PERFORMANCE-BASED REGULATION AND NEW UTILITY BUSINESS MODELS
If current trends hold, significant portions of power demand will be met with resources that
operate on the distribution system, either owned and operated by local utilities or customers
themselves. These “distributed energy resources” comprise battery storage, distributed solar PV,
energy efficiency, demand response, and electric vehicles, which can all contribute both energy
and much-needed flexibility to the system. Each has the opportunity to provide system flexibility
and help with zero-carbon energy, but the distribution utility serves as a gatekeeper bydetermining price signals to electricity customers and managing the operation of the distribution
grid. Regulators need new approaches to ensure distribution utilities are properly incented to
optimize the system around the value these resources provide.
Performance-based regulation (PBR) is a model for aligning utility incentives with societal goals
like affordability, reliability and resilience, and better environmental outcomes.59 PBR reforms
the current method of paying for utility service. Under the current regime, utilities increase
earnings by building more stuff, on which they recover costs plus a regulated return for

59 Littell, David and Kadoch, Camille et al. “Next-Generation Performance-Based Regulation: Emphasizing Utility Performance toUnleash Power Sector Innovation. Regulatory Assistance Project September 2017. URL: https://www.raponline.org/knowledgecenter/next-generation-performance-based-regulation-emphasizing-utility-performance-unleash-power-sector-innovation/;
Gold, Rachel and Myers, Amanda, et al. “Performance Incentive Mechanisms for Strategic Demand Reduction.” American Council
for an Energy Efficiency Economy and Energy Innovation: Policy and Technology, LLC. February 2020. URL:
https://energyinnovation.org/wp-content/uploads/2020/02/Performance-Incentive-Mechanisms-for-Strategic-DemandReduction.pdf; Aggarwal, Sonia and O’Boyle, Mike. “Getting the Most out of Grid Modernization.” Energy Innovation: Policy andTechnology, LLC. URL: https://energyinnovation.org/wpcontent/uploads/2017/02/GridModernizationMetricsOutcomes_Feb2017.pdf.

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shareholders. PBR breaks this link, instead it explicitly
ties utility profits to the outcomes indicative of a clean,resilient, affordable power system. Innovative PBR
mechanisms include performance incentive mechanisms
for demand-side optimization and decarbonization,
multi-year rate plans to incent affordable service, andearnings sharing mechanisms to incent customer-side(“non-wires”) solutions in lieu of traditional
infrastructure.60
State regulators should explore and expand
performance-based regulation as a complementarypolicy to encourage early compliance with clean energy
goals, incent cost-effective demand-side management,
and control utility costs through the transition. For
example, Hawaii’s Public Utility Commission (HIPUC) has
recognized that current utility regulation is incompatible
with the state’s 100 percent clean energy standard.61
The HIPUC has undertaken thorough stakeholder
engagement, and identified a range of performancebased regulation approaches as key pillars of reformneeded to achieve an affordable clean energy future.
COMPETITIVE ALL-SOURCE PROCUREMENT
Regulated monopoly utilities will be the largest (and inmany cases, only) “buyers” of wholesale power. They
participate in wholesale electricity markets on behalf ofcustomers, both purchasing from competitive markets
and hedging against these markets with long-term
bilateral contracts for certain resources. Many others
are vertically integrated, owning and operating power
plants and the poles and wires that ultimately reachcustomers.

Electrification and Flexible DemandWith rapid U.S. electricity grid decarbonization,transitioning transportation and buildings from oil
and gas to electricity can drastically reduce
emissions in those sectors. Thankfully, electric cars,heat pumps and air conditioners, and water
heaters can also provide significant grid flexibility
to complement wind and solar variability, reducing
energy transition costs. On the other hand, rapidtransportation and building electrification would
increase electricity demand, and thus the need forclean energy deployment. The 90 Percent Cleancase in the 2035 Report accounts for very little ofthis potential flexibility or new load, but thebroader modeling literature suggests significant
positive impacts of flexible load on cost andreliability.1
Even without electric vehicles and buildings driving
greater demand, flexible demand management
today is already an underused source of grid
flexibility. Brattle economists identified nearly 200
GW of cost-effective demand flexibility potential in
the U.S. by 2030. This demand flexibility potential,
which equates to 20 percent of estimated U.S.
peak demand in 2030, would more than triple theexisting demand response (DR) capability andwould be worth more than $15 billion annually in
avoided system costs.1
Well-timed charging of electric vehicles andbuilding heating can reduce power system costs
significantly by making the most of renewablegeneration, reducing peak demand to reduce theneed for grid upgrades, and reducing the need forstorage, gas peaker plants, and other sources offlexibility on the bulk system. Studies of Colorado1
and Minnesota1 by Vibrant Clean Energy indicatethat deep decarbonization of the vehicle andbuilding sectors is possible at a low cost if vehicles
and building components provide grid flexibility,
charging or preheating buildings or water heaters
when renewables are readily available, anddelaying when they are not.

Monopoly utilities have embedded incentives to insulatethemselves from competition or the need to innovate,
which often results in them choosing to build andmaintain overly risk-averse portfolios of resources and passing the related unnecessary costs

60 Cross-Call, Dan and Gold, Rachel et al. Navigating Utility Business Model Reform: A Practical Guide to Regulatory Design.” Rocky

Mountain Institute November 2018. URL: https://rmi.org/wpcontent/uploads/2018/10/RMI_Navigating_Utility_Business_Model_Reform_2018-1.pdf.
61 “Performance Based Regulation.” State of Hawaii Public Utilities Commission. Accessed June 5, 2019. URL:

https://puc.hawaii.gov/energy/pbr/.

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through to customers. Moreover, those same utilities pass on significant environmental risks tocustomers through their pollution. Regulation must ensure utilities procure any new resources
fairly, allowing all different kinds of technologies – including customer-owned resources anddemand management – to compete to provide the least-cost clean energy solution to customers
under a 90 percent clean energy standard.
All-source procurement has emerged as a model for obtaining needed energy at very low costs.
As noted above, federal funds assisting states in compliance with a 90 percent clean energy
standard should come with conditions, including requiring competitive all-source procurement.
In particular, regulators and utilities should observe the following principles62 in procurement:
•
•
•
•
•

Regulators should use an open resource planning process to determine a technologyneutral total procurement need before opening procurement.
Regulators should require utilities to conduct competitive, all-source bidding processes,
including demand-side resources, with robust bid evaluation.
Regulators should conduct advance review and approval of procurement assumptions
and terms.
Regulators should renew procedures to ensure that utility ownership is not at odds withcompetitive bidding.
Regulators should revisit rules for fairness, objectivity and efficiency.

To effectively incorporate demand-side resources into procurement, DOE and the national labs
should sponsor new pilots for “clean energy portfolio” development in partnership with
distribution utilities. RMI has demonstrated that portfolios of distributed energy resources,
storage, wind, and solar, can provide the energy and services of a conventional gas plant at
lower cost.63 Now we need real-world models of this portfolio-based approach, resulting in ascaling up of valuable distributed energy resources in procurement.
Who Can Get It Done

Decision-maker

PolicyPublic Utility Commissions

Explore and expand performance-based regulation to
encourage early compliance with clean energy goals, incent
cost-effective demand-side management, and control utility
costs through the transition. Use Hawaii’s open and thoroughstakeholder process as a model.
Sponsor new pilots for “clean energy portfolio” developmentin partnership with distribution utilities.

DOE/National Labs

62 Wilson, John and O’Boyle Mike et al. “Making the Most of the Power Plant Market.” Energy Innovation: Policy and Technology,

LLC. April 2020. URL: https://energyinnovation.org/wp-content/uploads/2020/04/All-Source-Utility-Electricity-GenerationProcurement-Best-Practices.pdf.
63 Dyson, Mark and Engel, Alex. “The Economics of Clean Energy Portfolios.” Rocky Mountain Institute 2018. URL:

https://rmi.org/insight/the-economics-of-clean-energy-portfolios/.

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Public Utility Commissions

Require utilities to undertake all-source procurements when
they identify the need for more generation resources,
allowing all resources to compete to meet a technologyneutral need, using the principles above.

Congress

Condition federal funds assisting utilities with compliance witha 90 percent clean energy standard on competitive all-source
procurement, using the principles above.

R&D TO SUPPORT THE PATHWAY TO 100 PERCENT CLEAN ELECTRICITY
Although the 2035 Report shows we can maintain a dependable, affordable electricity grid while
rapidly deploying wind and solar, it makes sense for the federal government to support research
now to clarify the path to 100 percent. Increased funding for research, collaboration, andtechnology transfer efforts can speed along the development and acceptance of needed
solutions, with particular focus on system needs like long-duration storage and system stability.
LONG-DURATION STORAGE
The 2035 Report shows a 90 percent clean electricity system can meet customer demand forevery hour of the year over the whole period. To do this, nearly 80 percent of existing gas
capacity operates at a low capacity factor, provides energy during sustained but infrequent
shortages of wind and solar power. To squeeze the remaining GHGs out of the electricity sector,
we will likely need resources that provide dispatchable, long-duration energy, or a way of
capturing and sequestering carbon. Some technologies are promising, including flow batteries,
new battery chemistries, compressed air energy storage, modular nuclear, and electrolysisderived hydrogen production, but none have reached commercialization for power provision yet.
To prepare for the last 10 percent of decarbonization, Congress should leverage and amplify theincredible capacity of DOE and the national labs for research in developing and commercializing
the most promising of these technologies.
NEW RESOURCE ADEQUACY FRAMEWORKS
Resource adequacy (RA) is a key way of assessing the reliability of a given set of resources.64 The
current RA framework focuses on having sufficient conventional generation (or using newer
resources only as if they are conventional-like generators), plus a reserve margin, available when
the system demand peaks. This is often defined as megawatts of electricity generation capacity
available year-round. But the grid is changing, and reliability no longer solely depends on having
enough power plants to meet infrequent peak demand. Instead, as renewables become agreater share of the total energy mix, day-to-day grid flexibility will be key to reliability. Many
new kinds of resources will be available to help provide the flexibility the system needs –distributed energy resources, storage, and demand response are some of the most important.

64 Gimon, Eric. “Why Climate Advocates Should be Interested in Resource Adequacy.” Energy Innovation: Policy and Technology,

LLC. April 2020. URL: https://energyinnovation.org/wp-content/uploads/2020/04/Why-Climate-Advocates-Should-Be-InterestedIn-Resource-Adequacy.pdf.

27

System needs will change under a high share of renewable energy – researchers must develop
new metrics that can give utilities, regulators, and system operators the confidence they need toinvest in a low-cost low-carbon portfolio that moves beyond dispatching power plants to meetpeak demand.
INADEQUACY OF DISPATCH AND PLANNING MODELSStandard models for transmission system planning used by RTOs/ISOs fail to account for thecapabilities of new technologies. They treat electricity demand trends as static, and do notproperly model capabilities of new, clean resources like energy storage, demand response, solar,
and wind. For example, solar-plus-storage together can meet summer peaks in many systems,
yet the models do not allow for this option to be considered. Standard models determine whichplants generate in real-time, relying on generic “participation models” based on conventional
power plant characteristics. New forms of generation (e.g., renewable energy), storage, demandside resources, and combinations thereof, are forced to fit into existing participation models,
unfairly discriminating against these resources while promoting dispatch of fossil fuel generators.
DOE and FERC have roles to play to standardize models and articulate modeling capabilities
RTOs/ISOs must possess to qualify as regional planning entities. Federal agencies can empower
the national laboratories to improve these models and develop open-source tools that utilities,
RTOs/ISOs, and state public utility commissions can use in their planning and operations.
VOLTAGE, FREQUENCY, AND STABILITY CONTROL TECHNOLOGIESWind and solar PV generation (and many modern loads) are electrically connected to theelectricity system via power electronic converters. This stands in contrast to the synchronous
generator that has dominated electrical generation technology from the beginning. Somefundamental issues and opportunities come along with this underlying change in the nature of
the electricity system.
As previously noted, using the power electronics and software of modern inverters, wind, solar,
and battery resources can provide almost any grid behaviors that are desired, and can do so withgreat speed and accuracy. In 100 percent clean electricity systems with little or no synchronous
generation, some of the other grid resources, including renewable generation and storage, may
need to provide additional stability and reliability services. Congress should fund already ongoing
research into technologies, such as grid-forming inverters65, to commercialize technologies
needed to support a 100 percent clean energy grid by 2045.
Who Can Get It Done

Decision-maker

PolicyU.S. Congress

Allocate funds to DOE and national labs to create new models
for resource adequacy under high shares of renewables,

65 GFI have been tested successfully in microgrids, but not as part of the bulk system. See Ellis, Abraham. “Grid Forming Inverters

in Interconnected Systems.” Sandia National Laboratories 2018. URL: https://der-lab.net/wp-content/uploads/2018/11/Ellis_GFIVienna.pdf.

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improve electricity sector resource planning and wholesalemarket models, and study and commercialize grid-forming
inverters and grid stability in high-renewables electricity
systems.
National Association ofRegulatory Utility
Commissioners; PUCs

Support regulated utility research and development tosupport the transition to 100% clean. Consider pooling
resources at the RTO/ISO level, regional level, or multistateutility level to share risk and increase impact.

Department of Energy (DOE)

Allocate funds to improve electricity sector resource planningand wholesale market models. Use national laboratory
capabilities to improve these models and develop opensource tools that utilities, RTOs/ISOs, and state public utility
commissions can use in their planning and operations.

Federal Energy Regulatory
Commission (FERC)

Articulate advanced modeling capabilities RTOs/ISO mustpossess and use to qualify as regional planning entities.

DOE; National Labs

Conduct research in conjunction with utilities and RTOs/ISOs
into grid-forming inverters and other technologies to support
system stability and security.

CONCLUSION
America has an opportunity to harness cheap, clean electricity to transform our economy,
boosting jobs and cutting pollution while lowering electricity bills for citizens. It would be a crime
to waste it. We have the technology, the enterprising businesses to get it done, a solid
manufacturing base to build, and we know the policy pathway. Bold action to adopt a clean
energy standard can set the nation on the right course, and complementary policies can help
support action at every level from federal to state and local communities.

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