# From: Culligan, Kevin [mailto:Culligan.Kevin@epa.gov]

Sent: Friday, May 23, 2014 7:06 PM

To: Higgins, Cortney

Cc: Wayland, Robertj Subject: Abatement TSD - Chapter 4

Per our discussion, we are still working on the alternative approach, but are getting close. We are planning on doing that in a stand-alone document so that it doesn’t slow down getting to yes on this chapter. I’ll be on e-mail a fair amount this weekend, so if you need something, don’t hesitate to e-mail.

- Kevin

<< GHG Abatement Measures TSD-Chapt er 4_05-23-14 revised for OMB.docx >>

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1 GHG Abatement Measures Technical Support Document Chapter 4: Cleaner Generation Sources

4.1. Introduction

Renewable energy is a cost-effective approach for reducing carbon dioxide (CO 2 

## ) emissions from

fossil fuel-fired electric generating units (EGUs) thro ugh the substitution of electricity generated from

renewable resources, referred to in this document as renewable energy (RE). The portfolio of available

RE sources encompasses a wide variety of technologi es from utility-scale RE plants to smaller-scale

distributed generation sited at residential, commercial , or industrial facilities. RE technologies are fueled

by the sun, wind, water, organic matter, and othe r resources regularly replenished by physical and

biological cycles. To integrate the rapidly increasing an d evolving portfolio of RE into the Best System of

Emission Reductions (BSER), the EPA has developed a best practices scenario that builds upon current

state policy encouraging increased production of RE taki ng into account renewable potential in particular

regions of the country.

Additionally, the EPA believes that the planne d expansion of new nuclear generating capacity

and the preservation of existing nuclear generating capacity represent a cost-effective means to reduce

CO 2 

## emissions at fossil fuel-fired EGUs by providing carbon-free generation that can replace generation

at those EGUs. Increasing the amount of nuclear capac ity relative to the amount that would otherwise be

available to operate is a technically viable and economically efficient approach for reducing CO 2



## emissions from affected fossil fuel-fired EGUs.

This TSD is intended to support discussion of cleaner generation sources (RE and nuclear) as a

component of BSER in the preamble (most extensivel y in these sections: Building Blocks for Setting

State Goals and Considerations, State Goals, State Plans, and Impacts of the Proposed Rule) and its

representation within the RIA. Results from this chapter feed into the technical support document (TSD)

on state goal setting. Cleaner generation is also addre ssed in TSDs on Survey of Existing State Actions,

State Plan Considerations, Projecting EGU CO 2 

## Emission Performance, and Legal Memorandum.

4.2. “Best Practices” RE TargetsScenario

To estimate the potential RE available for inclusion as part of BSER

, the EPA developed a “best

practices” RE generation scenario. This scenario provides a target for how much of each state’s

generation can be produced by RE under best practices in the state’s region, and allows each state to grow

RE generation over time towards that target, based upon that state’s current level of RE. The method can

be summarized as follows. First, the country is divided into regions. Second, an RE generation target is Comment [A1]: EPA's methodology to
define renewable energy goals is very difficult

to follow. Additional explanation or a specific

state example would be helpful.

Comment [A2]: EPA Response: Thank you
for the comment. The content has been edited to be responsive to these comments.

Comment [A3]: Hydro Comment -- Document expresses support for existing nuclear generating capacity, as it represents a
cost-effective means to reduce emissions – why then not express support for existing RE generating capacity (e.g. historic hydro)?

We understand that existing nuclear capacity may be more vulnerable to decommissioning – but existing RE generating capacity also represents a cost-effective means to reduce emissions. Can we get a similar statement of support for existing hydro generating capacity?

Comment [A4]: EPA Response: See below
for a clarification of the treatment of hydropower as part of the analysis.

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2 calculated for each region, based upon averaging all 2020 RPS requirements in that region. Third, an

annual growth factor is calculated that would allow the region as a whole to reach the regional RE target

in 2029 assuming that RE generation would increase from 2012 levels beginning in 2017. Fourth, the

annual growth factor for a given re gion is applied to individual stat es’ 2012 RE generation to calculate

future RE generation in that state from 2017 through 2029, not to exceed a maximum RE generation level

equivalent to the regional RE target. Finally, these a nnual RE generation levels for each state are used to

calculate interim and final RE targets for that state.

The best practices scenario is derived from state experience with policies that drive investment in

RE and the generation that results from those efforts. The EPA focused on state-level RE policy for

several reasons. Every state in the union is produc ing electricity from renewable resources, and some

states have achieved significant levels of renewa ble generation, surpassing a quarter of in-state

generation. State-level RE requirements have been implemented in 29 states plus Washington, DC,

representing all regions of the country. Eight Nine states have voluntary goals. 1 

## These state-level goals

and requirements have been developed and implemen ted with technical assistance from state-level

regulatory agencies and utility commissions such that they reflect expert assessments of RE technical and

economic potential that can be cost-effectively developed for that state’s electricity consumers.

The best practices scenario focuses on RE requi rements established through Renewable Portfolio

Standards (RPS), which provide specific quantifia ble RE generation requirements over time. The EPA

used these RPS-mandated quantities as th e basis for deriving regional targets tothat could be applied to

states as part of BSER, using the RPS-based targ ets as a reasonable benchmark of regionally costeffective RE generation which states could grow towa rds over time. While EPA’s best practices scenario

is derived from RPS data, states may also consider a broad variety of other RE policies to increase

generation, such as performance-based incentives, financial assistance programs, regulatory changes to

facilitate the development of renewable sources and their interconnection to the grid and “lead by

example” strategies integrating RE generation into state properties. 2 

## Because the EPA did not quantify

potential that could be tapped through any of those policy approaches, the agency believes that the RE

targets derived from RPS mandates represent a conservative estimate of cost-effective generation that

could actually be developed by states.

1 

## Database of State Incentives for Renewables and Efficiency, March 2013. Accessed May 23, 2014, www.dsireusa.org; Alaska House Bill 306, Signed by Governor Sean Parnell June 16, 2010. http://www.legis.state.ak.us/basis/get_bill_text .asp?hsid=HB0306Z&session=26.Map: Renewable Portfolio Standard Policies, www.dsireusa.org, March 2013, can be located at: http://www.dsireusa.org/summarymaps/.

2 

## See State Plan Considerations TSD for a discussion of how states can incorporate such RE policies into their state plans for this rule. Comment [A5]: EPA Comment: Updated to reflect Alaska voluntary goal.

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3 While future RPS requirements will necessitate more RE generation and capacity beyond current

levels, the EPA does not expect the anticipated rate of growth required to meet those requirements to

exceed the historical rate of RE deployment. Full compliance with current RPS requirements through

2035 would necessitate the deployment of approximat ely 3 to 5 GW of new renewable capacity per year

through 2020 and 2 to 3 GW through 2035. Average deployment of RPS-supported renewable capacity

from 2007-2012 has exceeded 6 GW per year. 3 

## In addition, recent improvements in RPS compliance rates

indicate to the EPA the reasonableness of current RPS growth trajectories. Weighted average compliance

rates among all states have improved in each of the past three reported years (2008 - 2011) from 92.1

percent to 95.2 percent despite a 40 percent in crease in RPS obligations during this period. 4 

## As the

Lawrence Berkeley National Laboratory (LBNL) RPS Status Update found, in the period 1998-2012,

67% of all non-hydro U.S. RE capacity additions, to taling roughly 46,000 MW, was built in states with

RPS requirements. 5



## This scenario provides an estimate of an achievable level of total RE generation within states. It

does not represent an EPA forecast of business-as-us ual impacts of state policies or an EPA estimate of

the full potential of RE available to the power system; rather, it is intended to represent a feasible

development scenario that enables reductions of CO 2 

## emissions from fossil fuel-fired EGUs in all states

and that is generally consistent with ongoing trends in RE development. The scenario uses a level of

performance that has already been demonstrated or required by policies of leading states, while

considering each state’s unique existing level of RE performance and allowing appropriate time for each

state to increase from their current level of performance to the identified best practice level. In the context

of this rulemaking, RE “performance” and RE targets are measured as the share of total generation

represented by non-hydro renewables, 

# renewables as explained further below.

3 

## Barbose, Galen, “Renewables Portfolio Standards in the United States: A Status Update,” Lawrence Berkeley National Lab, November 2013. Also, Heeter, J., Barbose, G., Bird, L., Weaver, S., Flores-Espino, F., KuskovaBurns, K., and Wiser, R. (Forthcoming). “A Survey of State-Level Cost and Benefit Estimates of Renewable Portfolio Standards.” NREL Report No. 6A20-61042, LBNL Report No. 6589E.

4 

## http://emp.lbl.gov/rps, retrieved March 2014. The RPS comp liance measure cited is inclusive of credit multipliers and banked RECs utilized for compliance, but excludes alternative compliance payments, borrowed RECs, deferred obligations, and excess compliance. This estimate does not represent official compliance statistics, which vary in methodology by state.

5 

## Barbose, Galen, “Renewables Portfolio Standards in the United States: A Status Update,” Lawrence Berkeley National Lab, November 2013. Slide 8. Also, Heeter, J., Barbose, G., Bird, L., Weaver, S., Flores-Espino, F., Kuskova-Burns, K., and Wiser, R. (Forthcoming). “A Su rvey of State-Level Cost and Benefit Estimates of Renewable Portfolio Standards.” NREL Report No. 6A20-61042, LBNL Report No. 6589E. Comment [A6]: Why focus on non-hydro in this recent period? If the cited study excluded hydro, is there a different one that did not?

Comment [A7]: EPA Response: The inclusion of hydropower should not significantly alter the c onclusion. EIA historic data shows that the percent of existing hydropower generating capacity as a portion of total capacity remained relatively unchanged through the period in question.

Comment [A8]: Why exclude hydro? In almost all RPS, hydro is an eligible resource. Policy should be to encourage new-hydro, especially where it is counted in state RPS
calculations. If the BSER is built on state RPS (that consider hydro an eligible generation source) – hydro should be an eligible generation source.

Comment [A9]: EPA Response: EPA makes no assumptions in this target-setting scenario as to what RE technologies are used to satisfy RPS requirements, and hydropower is not specifically excluded from the RPS requirement that are inputs to the analysis. Existing hydropower is excluded from the 2012 baseline generation data used to calculate RE targets and growth factors, so that state targets would not be distorted by the relatively large existing hydropower generation that is present only in certain states. EPA specifies that this analysis is not making any determinations as to allowable RE compliance

measures.

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4 The following steps were taken to establish the inputs for development of the best practice scenario

for each state . The implementation of each step is illustrated in the table below its description, using the

state of Illinois as an example.

4.2.1 Determine current level of performance

4.2.2 Determine best practice level of performance

4.2.3 Determine start year for state efforts

4.2.4 Determine pace at which states improve fr om start year to best practice level of

performance

4.2.5 Calculate RE targets for interim and final state targets

4.2.1 Determine current level of performance

The type and extent of current RE capacity varies significantly across states, and is influenced by

the renewable resources available, the economics of the power sector to date in different regions, and the

state policies that affect renewable sources specifica lly and energy production generally. The extent of

that generation has also changed rapidly in the past few years, and states with RE policies have

significantly increased their renewable capacity. To characterize the current level of RE usegeneration

and total generation 6 

## , we have used the most current state-le vel data on generation: 2012 net generation

data by state. 7



## Definitions of qualifying RE vary across state RP S requirementspolicies, and in this analysis EPA

makes no assumptions as to what type of RE is used to satisfy state RPS requirement, or would be used to

comply with this rule. For the sake of comparing RPS requirements in order to derive RE targets for each

regionFor the purposes of calculating a baseline level of RE generation in each state , the EPA adopted a

broad interpretation of RE generation to include any non-fossil renewable fuel type, with the exception of

generation from existing hydroelectric power facilities

. . Large existing hydroelectric facilities provide a

large percentage of RE generation in a few states , (hydropower is America’s largest existing source of

6 

## EIA state-level total generation has been adjusted to remove utility-scale fossil generation located in Indian Country.

7 

## U.S. EIA state level data available at http://www.eia.gov/electricity/data/state/. Comment [A10]: True, but almost all RPSs identify hydropower is an eligible resource.

Hydropower rules related to RPS differ state by state, but generally restrict hydropower by capacity/size, vintage, or technology. The predominant limiting factor to hydropower RPS inclusion is age.

Comment [A11]: EPA Response: This target-setting analysis makes no assumptions as to what RE technologies are used to satisfy RPS requirements, and hydropower is not specifically excluded from the RPS requirements that are inputs to the analysis. This is done in part because RPS policies vary from state to state, as the comment indicates. Existing hydropower is excluded from the 2012 baseline generation data used to calculate RE targets and growth factors, so that state targets would not be distorted by the relatively large existing hydropower generation that is present only in certain states. EPA specifies that we do not assume any specific RE technologies are developed in the best practice scenario, and the analysis is not making any determinations as to allowable RE compliance

measures.

Comment [A15]: EPA Response: We have accepted many of the edits provided, and further adjusted the language to clarify the method. EPA specifies th at the assumptions in this target-setting analysis do not making any determinations as to allowable RE compliance

measures. Comment [A14]: Suggest including this clarification in the preamble. What about EPA’s interpretation of RE that can be included as part of a state’s compliance? Comment [A12]: This would seem to
indicate that biomass would count in states
where it’s an eligible RE source. Is this right?

Comment [A13]: EPA Response: Generation from dedicated biomass generators was included in the 2012 baseline generation used to develop targets. The “best practices” approach does not need to distinguish any individual RE technology as “eligible” – instead, this section is describing how EPA has estimated total RE generation potential in order to establish “best practices” RE targets that inform the calculation of the proposal’s state goals.

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5 RE, for which generating capacity has remained relative constant over the last 20 years), and inclusion of

this generation in current and projected levels of perf ormance would distort the best practices scenario by

presuming future development potential of large hydroelectric capacity in other states. These types of

facilities have not been the focus of most RPS policiesBecause RPS policies werepolicies were

implemented to stimulate the development of new RE generation, existing hydroelectric facilities are

often excluded from RPS accounting., and many RPS policies specifically exclude their use in

compliance . No states are expected to significantly increase generation from existing large hydropower

facilities nor develop any new large facilities. 8 

## The RE target-setting method presented in the body of this

chapter includes only non-hydropower RE in the target-setting calculations and in the RE generation

levels used to inform the state goals calculated in th is proposal. In Appendix 4-1, we provide a different

version of the RE generation targets that includes existing hydropower generation from 2012 for each

state in the state RE targets. These targets that in clude existing hydropower generation as of 2012 reflect

the potential incorporation of existing hydropower in the state RE targets that could inform the calculation

of state goals if such generation were included in the quantification of BSER-related RE generation. The

analysis of potential informing regional RE targets does not e xplicitly account for the potential of

building new smaller hydroelectric facilities as a source under RPS policies; however, states may choose

to encourage such development, and generation from such facilities would not be excluded from

compliance with a state’s goal under this rule

. Can we have a more affirmative statement to

recognize that such development can be included and is encouraged?

.

The most recent 2012 performance data for all states is shown in Table 4-1. Consistent with the

design of a number RPS policies, RE “performance” is measured here 

# as the share of total generation

represented by non-hydro RE

..

Table 4-1. 2012 RE Performance by State (MWh)

State Non-Hydro RE
Generation Total Generation Performance
Level

Alabama 2,776,554 152,878,688 2%
Alaska 39,958 6,946,419 1%
Arizona 1,697,652 95,016,925110,904,994 2%
Arkansas 1,660,370 65,005,678 3%

8 

## U.S. EIA, Annual Energy Outlook 2014, p. 121, available at http://www.eia.gov/forecasts/archive/aeo13/index.cfm.. http://www.eia.gov/forecasts/archive/aeo13/index.cfm

. Check this – do we agree. I thought we do have examples of significant new generation via efficiency improvements or expansions at existing facilities. Comment [A16]: Because – the intent of
RPSs is to stimulate new renewable development – that is why old, existing development is excluded.

Comment [A17]: EPA Response: thank you
for the comment.

Comment [A18]: Reclamation does not agree with this statement. What does “significantly increase” mean? How much generation is significant? The agency is currently installing optimization systems at existing, large facilities. Optimization systems will allow facilities to generate an additional 1- 3% annually. Once all facilities are optimized, we expect to see an additional 410,000 MWh – 1,230,000 MWh annually. This is a significant
increase. ... [1]

Comment [A19]: EPA Response: We have removed the related language.

Formatted: Not Highlight

Formatted: Not Highlight

Formatted: Not Highlight

Comment [A20]: What is meant by this? Is future hydro implicitly included? It should be ... [2]

Formatted: Not Highlight Comment [A21]: EPA Response: As the text says, though not explicitly included in this ... [3]

Formatted: Not Highlight

Comment [A23]: EPA Response: Clarifying language has been included in the preamble. Comment [A22]: Suggest including this clarification in the preamble.

Formatted: Not Highlight Comment [A24]: EPA Response: We have added language accordingly.

Formatted: Not Highlight

Comment [A26]: EPA Response: Please see previous responses to comment above that ... [4] Comment [A25]: Along with ineligible, “old” hydro – some RPS eligible hydro (e.g. ... [5]

Comment [A27]: Same comment -- Aren’t we excluding some eligible hydro here?

Comment [A28]: EPA Response: Please see previous responses to comment above that ... [6]

Comment [A30]: Thank you for the
comment. We have added a unit label in the ... [7] Comment [A29]: Might be helpful to include
units: MWh.

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6 California 29,966 ,846 199,518,567 15%
Colorado 6,192,082 52,556,701 12%
Connecticut 666,525 36,117,544 2%
Delaware 131,051 8,633,694 2%

District of Columbia 9 

## - 71,787 0%
Florida 4,523,798 221,096,136 2% Georgia 3,278,536 122,306,364 3%
Hawaii 924,815 10,469,269 9%
Idaho 2,514,502 15,499,089 16%
Illinois 8,372,660 197,565,363 4%
Indiana 3,546,367 114,695,729 3%
Iowa 14,183,424 56,675,404 25%
Kansas 5,252,653 44,424,691 12% Kentucky 332,879 89,949,689 0%
Louisiana 2,430,042 103,407,706 2%
Maine 4,098,795 14,428,596 28% Maryland 898,152 37,809,744 2%
Massachusetts 1,843,419 36,198,121 5% Michigan 3,785,439 108,166,078 3%
Minnesota 9,453,871 52,193,624 18% Mississippi 1,509,190 54,584,295 3%
Missouri 1,298,579 91,804,321 1%
Montana 1,261,752 27,804,784 5%
Nebraska 1,346,762 34,217,293 4%
Nevada 2,968,630 35,173,263 8% New Hampshire 1,381,285 19,264,435 7% New Jersey 1,280,715 65,263,408 2%
New Mexico 2,573,851 2,289,452436,635,909 711 %
New York 5,192,427 135,768,251 4%
North Carolina 2,703,919 116,681,763 2%
North Dakota 5,280,052 36,125,159 15%
Ohio 1,738,622 129,745,731 1%
Oklahoma 8,520,724 77,896,588 11% Oregon 7,207,229 60,932,715 12% Pennsylvania 4,459,118 223,419,715 2%
Rhode Island 101,895 8,309,036 1%
South Carolina 2,143,473 96,755,682 2%

9 

## The District of Columbia has no utility-scale RE generati on, but the District does have distributed RE resources contributing to the electrical grid. It can also be noted that the non-RE generation reported closed in 2012, so the District of Columbia no longer has any utility-scale generation

. Comment [A31]: We have revised the Arizona, New Mexico and Utah numbers in order to remove generation from units on Indian country from these states’ total generation, which impacts the RE calculations.

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7 South Dakota 2,914,666 12,034,206 24%
Tennessee 836,458 77,724,264 1%
Texas 34,016,697 429,812,510 8%
Utah 1,099,724 36,312,52739,402,961 3%
Vermont 465,169 6,569,670 7% Virginia 2,358,444 70,739,235 3% Washington 8,214,350 116,835,474 7% West Virginia 1,296,563 73,413,405 2%
Wisconsin 3,223,178 63,742,910 5% Wyoming 4,369,107 49,588,606 9%

4.2.2 Determine best practice level of performance

Achievable RE potential exists at significant and comparable levels in all regions of the country.

While varied regional characteristics (e.g., the extent of renewable resources available, cost of competing

sources of power, and level of past RE development) affect estimates of achievable potential, ongoing

improvements in technologies and practices, and conti nually improving strategies for RE development are

increasing the extent of economically utilized renewabl e resources across all regions of the United States.

RE has been capturing a growing percentage of new capacity additions in the past few years. In 2012, RE

accounted for more than 56% of all new electrical capacity installations in the U.S. – a major increase

from 2004 when renewable installations captured only 2% of new capacity additions. 10 

## The economics of

the fastest growing RE technologies – on-shore wind and solar photovoltaics (PV) – are improving . and

are competitive in many regions. In 2012, cumulative installed wind capacity increased by nearly 28%

and cumulative installed solar PV capacity grew more than 83% from the previous year. 11 

## In the United

States, installed wind electricity capacity increased more than 23 fold between 2000 and 2012. 12 

## Solar

electricity generating capacity grew by a factor of over 21 between 2000 and 2012 and currently accounts

for 0.3% of annual U.S. electricity generation. 13 

## In 2013, 4.8 GW of solar PV capacity was installed,

bringing total sola r U.S. solar capacity to 12.1 GW. 14 

## The National Renewable Energy Laboratory

(NREL) has also found that the continental U.S. has solar potential that exceeds high solar generating

countries like Germany, which is now has the capacity to generat inge over 6% of their electricity from

10 

## U.S. Department of Energy. 2012 Renewable Energy Data Book. DOE/GO-102013-4291.October 2013. p. 3.

11 

## U.S. Department of Energy. 2012 Renewable Energy Data Book. DOE/GO-102013-4291.October 2013. p. 18.

12 

## Ibid. p. 53.

13 

## Ibid. p. 63.
14 

## GTM Research and the Solar Energy Industries Association (SEIA), “SEIA Solar Market Insight Report 2013: Year in Review”, 2014, available at: http://www.seia.org /research-resources/solar-market-insight-report-2013-yearreview. Comment [A32]: A significant amount of
solar was installed in 2013, namely 4.8 GW, bringing the total amount of installed solar to
12.1 GW (SEIA Solar Market Insight Report

2013 Year in Review). The annual generation
of the current solar fleet will be significantly larger than 0.3%.

Comment [A33]: EPA Response: Thank you for the comment, that information has been
added to the text.

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8 solar. 15 

## Looking forward, the U.S. Department of Energy has found that 46 states would have substantial

wind development by 2030 under a scenario in which 20% of national generation is provided by wind.

The distribution of that deployment is shown in Figure 4.1. 16



## Figure 4.1. 

# DOE Projected Installed Wind Capacity by State under 20% National Generation

Scenario

15 

## NREL. Photovoltaic Solar Resource: The United States, Spain and Germany. 2009. Available at: http://www.nrel.gov/gis/images/us_germany_spain/pvmap _usgermanyspain%20poster-01.jpg. Also IEA. PVPS Snapshot of Global PV 1992-2013. Report IEA- PVPS T1-24:2014, March 31, 2014. http://www.ieapvps.org/fileadmin/dam/public/report/statistics/PV PS_report_-_A_Snapshot_of_Global_PV_-_1992-2013_- _final_3.pdf.

16 

## U.S. Department of Energy. 20% Wind Energy by 2030: Increasing Wind Energy’s Contribution to U.S. Electricity Supply – Executive Summary. December 2008. http://www.nrel.gov/doc s/fy09osti/42864.pdf. Comment [A34]: The TSD could do with
more information on actual state resources for wind, solar and geothermal, to support the current regional averaging procedure for eliciting future RE rates.

Also, the text at the bottom of this figure is
unreadable.

Comment [A35]: The content has been
edited to include some additional relevant resources. The figure has been replaced with a more readable image.

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9 4.2.2.1. Quantification of Effective RE Levels from State-Level RPS Requirements

The best practices scenario is also based upon an analysis of renewable portfolio standards, a

policy that facilitates the quantification of RE targ ets. By only examining the impact of one type of

policy, the analysis is inherently conservative, as many other policy options are also available to states in

addition to RPS.

In order to apply the various RPS policies to the development of a best practice level of

performance, the EPA used publicly-available quant itative information about mandatory state RPS

requirements from the Database for State Incentives for Renewables and Efficiency (DSIRE). 17 

## This

17 

## Database of State Incentives for Renewables & Efficiency (DSIRE) is a very comprehensive source of information on incentives and policies that support renewables and energy efficiency in th e United States. DSIRE is currently operated by the N.C. Solar Center at N.C. Stat e University, with support from the Interstate Renewable Energy Council, Inc. DSIRE is funded by the U.S. Department of Energy. http://www.dsireusa.org/.

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10 information enabled the EPA to determine the effectiv e RE levels in 2020 for states with mandatory RPS

requirements. 18



## DSIRE provides regularly-updated RPS Data Spreadsheets that detail state RPS requirements by

year, resources, and other key component parts. 19 

## The RPS compliance schedules are broken down into

the specific annual percentages requirements for the years 2000 to 2030. Many states have multiple

compliance requirements, including the main per centage requirements for eligible resources and

additional resource-specific percentage requirements that states are increasingly using to promote the

development of a particular set of resources or technologies (e.g., solar PV). DSIRE called each of these

sets of resource requirements “tiers” and applied a standardized approach to them, “in order to compare

RPS policies on equal footing.” 20 

## The benefit of this approach is that state resource requirements become

additive and facilitate a process of selection and exclusion. The EPA added together each state’s tiers, as

standardized by DSIRE, to determine states’ effective RE levels for 2020, but excluded tiers, other than

main tiers, that include energy efficiency or any fossil fuel.

In addition, six states have established more than one set of RPS requirements for in-state

utilities, including “secondary” and “tertiary” RPS requirements for smaller utilities, municipal utilities,

or cooperative utilities. The EPA only included the prim ary RPS requirements to simplify the analysis of

primary and secondary RPS requirements in determin ing states’ effective RE levels for 2020. By only

considering primary requirements, there is additional inherent conservatism in the RPS estimates, as

additional state-level RPS obligations are not included in the calculated targets.

Figure 4.2 RPS Data Structure 21

18 

## EPA did not include targets that were capacity-based.

19 

## DSIRE. RPS Data Spreadsheet. April 2013 versi on. http://www.dsireusa.org/rpsdata/index.cfm.

20 

## DSIRE. DSIRE RPS Field Definitions. April 2011. http://www.dsireusa.org/rpsdata/RPSFieldDefinitionsApril2011.pdf. p. 1.

21 

### DSIRE. RPS Data Spreadsheet. April 2013 version.

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11 The RPS compliance schedules in six states im plement maximum requirements prior to 2020;

their effective RE levels for 2020 are set to those maximum levels. In fact, most states maintain their

percentage requirements indefinitely.

TABLE 4.2 . Effective RE Levels Derived from RPS Requirements

RPS
States Primary Target Target
Year 2020
Effective
RE
Levels Exclusions

AZ 15% 2025 10%

CA 33% 2020 33%
CO 30% 2020 30% Secondary RPS requirement

CT 23% 2020 23% Class 3 includes non-RE

DC 20% 2023 20%

DE 25% 2027 19%

HI 40% 2030 25%
IL 25% 2025 16% Secondary RPS requirement

KS 20% 2020 20%

MA 33% 2030 22%

MD 20% 2022 18%

ME 40% 2017 40%

MI 10% 2015 10% Comment [A36]: Question for clarification – does this column include existing hydro in the number, thereby reporting a total state RE rate of both hydro and non-hydro, or is it limited to the states’ non-hydro rate?

Comment [A37]: EPA Response: The primary targets have not been adjusted to exclude hydropower, so it includes hydropower to the extent that the state policy
did so.

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12 MN 30% 2020 30% Secondary RPS requirement

MO 15% 2021 10%

MT 15% 2015 15%
NC 13% 2021 10% Secondary RPS requirement

NH 25% 2025 20%

NJ 24% 2021 22%
NM 20% 2020 20% Secondary RPS requirement

NV 25% 2025 22%

NY 29% 2015 29%

OH 13% 2024 9%

OR 25% 2025 20% Secondary & tertiary RPS requirements

PA 8% 2021 8% Class 2 includes non-RE

RI 16% 2019 16%

WA 15% 2020 15%

WI 10% 2015 10%

4.2.2.2. Development of Regional RE Generation Targets from State-level Effective RE Levels

To take into account the varied availability of different renewable resources across regions of the

United States, the EPA uses the state-level effective RE levels derived from RPS requirements to quantify

regional RE targets consistent with states’ best practice in RE development. This methodology helps us to

quantify RE potential in states which do not have an RPS policy from which the renewable resource

potential can be inferred. Specifically, the scenario estimates each region’s RE potential by assuming all

states in each region can achieve by 2030 the average of the 2020 requirements of RPS states in that

region.

The regions assigned to states to quantify th eir RE generation target are based upon North

American Electric Reliability Corporation (NERC) regions and Regional Transmission Organizations

(RTOs) and are the same as the regions used in the modeling of the “regional” compliance scenarios as

outlined in the proposal RIA (see Figure 4-3). 22 

## States within each region exhibit similar profiles of RE

potential or have similar levels of renewable resource s. The regional similarities can be inferred from the

state-level technical potential reported in an NREL GIS-based analysis. 23 

## The results show clear trends for

22 

## For more information on the structure of these regions, please refer to the Regulatory Impact Analysis Chapter 3.
23 

## NREL. U.S. Renewable Energy Technical Potentials: A GIS-Based Analysis. NREL/TP-A20-51946. July 2012. http://www.nrel.gov/docs/fy12osti/51946.pdf.

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13 the regions used to create the best practices scenario , with portfolios of particular technologies showing

clear dominance in specific regions. North Central and South Central regions have strong on-shore wind

resource potential. The East Central and Southeast regions show moderate to strong resources in both

biopower and rooftop PV potential. The West has unique notable potential in geothermal (hydrothermal)

power and concentrating solar power , in addition to potential for in creased hydropower generation . The

Northeast has strong resources in off-shore wind and moderate biopower and solar resources available. It

should be noted that high technical potential in a particular renewable resource is not necessarily needed

to reach the generation levels called for in this proposalquantified under this approach . For example,

Maine produced 28% of its electricity generation in 2012 from biopower and onshore wind, while it is

estimated in this report to have relatively moderate technical potential for biopower and relatively low

levels of onshore wind capacity. Overall, analysis of results from the NREL GIS-based analysis shows

that the regional RE targets accessincluded in this proposed approach assume development of similar

levels of RE resource across all states within each region. In most regions, the RE targets are belowonly

0.5% of the technical RE potential available, with the exceptions of the Northeast and the East Central

regions, where the targets are at mostto 4.5% of the RE technical resources in those regions. See Figure

4.3.1 for a graph showing the state RE targets in each region represented as a percentage of the renewable

resources available in the state.

Figure 4.3. Regions for Development of Best Practices RPS Scenario Comment [A38]: Can we note hydro potential in pacific northwest?

Comment [A39]: EPA Response: We have added language accordingly.

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14 Table 4.3. List of States Included in Regions for Development of RE Best Practices Scenario 24



## Region States

East Central Delaware, District of Columbia, Maryland, New Jersey, Ohio, Pennsylvania,

Virginia, West Virginia

North Central Illinois, Indiana, Iowa, Michigan, Minnesota , Missouri, North Dakota, South

Dakota, Wisconsin

Northeast Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode

Island, Vermont

South Central Arkansas, Kansas, Loui siana, Nebraska, Oklahoma, Texas

Southeast Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South

Carolina, Tennessee

24 

## Alaska and Hawaii are not grouped with other states into regions. Formatted: Font: 11 pt

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15 West Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico,

Oregon, Utah, Washington, Wyoming

Figure 4.3.1. Regional RE Targets of each State as a Percentage of the State’s Renewable Resources

The EPA compiled the state-level effective RE levels derived above, organized them by region,

and determined an average percent generation target for that region. This average did not include any

values for states in which there is no binding RPS requirement. For example, the RE target for the North

Central region is calculated as the average of 2020 R PS requirements in Illinois (16%), Michigan (10%),

Minnesota (30%), Missouri (10%), and Wisconsi n (10%), which is equivalent to 15%. This average

regional RE generation target offers a basis for the determination of state-level RE targets for informing

state goals, as described below. Given their unique locations, Alaska and Hawaii are not grouped with Formatted: Font: 11 pt, Complex Script Font: 11 pt

Comment [A40]: Is there a reason why EPA did not weigh the RPS targets by current generation before averaging across the region? As currently defined, RPS targets for smaller states with lower total generation receive the same weight as RPS targets for large states. Can EPA explain its rationale?

Comment [A41]: EPA Response: We
believe it is reasonable to interpret RPS policyrequirements that are expressed as percentageof-sales mandates as relative targets that can support this methodology of quantifying a similarly relative target at the regional level.

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16 other states into these regions. As a conservative approach to estimating co st-effective RE generation

potential in Alaska and Hawaii, the EPA developed RE generation targets for each of those states based

on the lowest values for the six regions evaluated here , equivalent to the regional target for the Southeast

region. The calculated regional RE targets are shown in Table 4.4.

Table 4.4. Regional RE Generation Targets

Region Regional RE Generation Targets

Alaska 10%

East Central 16%

Hawaii 10%



# North Central 15%

Northeast 25%



# South Central 20%

South 

# east 10%

West 21%

4.2.3 Determine start year for state efforts

The best practice scenario assumes that RE gene ration will begin increasing in 2017, the year

following the initial state plan submission deadline 25 

## , and continues through 2029, by which time the EPA

assumes the regions can achieve the identified regional RE target level of performance. The EPA has set

each state’s level of performance prior to the start year of the scenario (2017) to be equal to its current

level of performance (as shown above using 2012 ge neration data). This approach assumes neither

improvement nor decline in performance between 2012 and 2017.

4.2.4 Determine pace at which states improve from start year to best practice level of performance

In order to account for the time needed to plan and construct the required additional amounts of

renewable capacity, the best practices scenario assumes an increasing trend over time of annual levels of

RE generation that can carry the start year performance level of each region in the start year (in 2017,

25 

## See Preamble Section 8.E – Process for State Plan Submittal and Review for further discussion of timing requirements for state plan submittals. Comment [A42]: May be better to verify with some independent estimate since these regions are geographically quite different.

Comment [A43]: EPA Response: Thank you very much for the comment, we are specifically requesting comment on alternative methods to this proposal for Alaska and
Hawaii.

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Comment [A44]: 2013 has been a strong

year for solar, and we expect continued
acceleration in deployment, especially with
the ITC continuing to 2016 and rapidly declining technical costs. We also expect 2014

to be a strong year for wind, with many projects starting construction prior to expiration of the PTC. Keeping renewable growth flat from 2012 to 2017 will grossly
underestimate the renewable deployment in
the 2017 start year. For states with existing RPSs, DOE recommends assuming they

continue to meet their RPS targets through

2017.

Comment [A45]: EPA Response: These calculations apply the RPS requirements as the target-setting criteria to historical generation data that does not make any projections as to future behavior. Any additional qualifying capacity added between 2012 and 2017 will be able to have its generation during the program period count towards state compliance.

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17 assumed to be equivalent to its 2012 observed perfor mance level) to that region’s RE generation target by

2029. This 2017-2029 trend yields an annual growth factor that is unique to each region and based upon

each region’s current renewable generation level and its RE target level identified above.

To derive the annual growth factor, the EPA determined the amount of additional renewable

generation (in megawatt-hours) that would be required beyond each region’s historic (2012) generation to

reach that region’s RE target. The EPA then determined the constant rate at which each region would

need to increase its generation each year to reach the regional RPS target, if these rates are applied in the

period 2017-2029. The constant rate of annual RE gene ration increase calculated from this approach is

called the growth factor in this context

. For example, the North Central region had 52,058,236 MWh of

RE generation in 2012, while the North Central regi onal RE target of 15% applied to total 2012

generation across states in that region would yield an RE generation level of 110,786,042 MWh. This

approach assumes that the North Cent ral region would begin to increase its RE generation, starting at its

2012 level, from the year 2017 onward and would achieve its RE target level by 2029. Under those

conditions, an annual growth rate of 6% per year for RE generation would occur in the North Central

region. Due to their unique location, the EPA used a different method to calculate growth factors for

Alaska and Hawaii, calculating an annual grow th factor based on the difference between both each states’

individual historical 2005 2002 and 2012 RE generation.

Table 4.5. Regional Annua l RE Growth Factors

Region Growth Factor


# Alaska 8%

East Central 17%

Hawaii 8%

North Central 6%

Northeast 1013 %
South Central 8%

Southeast 13%

West 6% Comment [A46]: Is this explained in greater detail anywhere else?

Comment [A47]: EPA Response: We have added an example below that hopefully demonstrates this more clearly.

Comment [A48]: EPA Comment: This is an adjustment made to the method following submission of the TSD to interagency review. This adjustment assures that Alaska and Hawaii are treated differently in determination of growth rate, based upon their unique historical generation.

Comment [A49]: Please check that the
value for the Northeast is correct.

Comment [A50]: EPA Response: The value for the Northeast growth factor has been
corrected.

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18 Then, for all states in a given region, that regi on’s annual growth factor was applied to each

state’s historic (2012) RE generation level to calculate a new level of RE generation for that state in the

initial year (2017). This cal culation is then repeated for each year in the 2017-2029 time period. If, as the

growth factor is applied annually, a state reaches an RE generation level that equals or exceeds the

regional RE percent generation target, their RE generation target is made equal to the RE percent

generation target as applied to that state’s 2012 generation and is no longer grown overis kept at that level

for the remainder of the time period. If a state’s RE generation in 2012 has already exceeded the regional

RE target, their annual RE generation levels are held to the regional RE target for all years in the 2017-

2029 time period. For all other states, the annual grow th factor is applied through 2029. These annual RE

generation estimates represent the realization of the best practice scenario for each state. These RE

generation levels are provided in absolute and percen tage (share of total generation) terms in Table 4.6

and Table 4.7.

This approach imposes the same regional RE target in percentage (share of total generation) terms

to all states in a given region; therefore, the absolute megawatt-hour target will be smaller for states

starting with a lower absolute amount of RE genera tion and larger for a state starting with a higher

absolute amount of RE generation.

This approach applies the calculated growth factors and regional RE targets to state-level

generation, whereas the state-level RPS requirements upon which they are based are not necessarily

applied in practice to generation that is produced with in the relevant state. However, the EPA notes that

state-level RPS policies are often established with th e aim of developing in-state renewables generation. 26



## This intention is evident in RPS policies that include minimum requirements for specific types of

renewable resources whose development is desired in that state. Regional analysis by NREL has also

shown that many states in the west are satisf ying RPS requirements with in-state generation. 27



## Furthermore, the regional RE target is not applied directly as an immediate requirement of each state but

is instead used to calculate a regional growth factor that is then applied to each state’s pre-existing RE

generation, such that historic RE performance acts as a limiting factor on the extent to which a state is

assumed to reach the regional target. Over the program period, several states do not reach the RE

percentage target in the best practices scenario, such as Kentucky in the Southeast and Nevada in the

26 

## Wiser, Ryan H., and Galen L. Barbose. 2008. Renewable Portfolio Standards in the United States: A Status Report with Data Through 2007 . LBNL-154E. Berkeley, CA: Lawrence Berkeley National Laboratory, p. 7.

27 

## Hurlbut, David, Joyce McLaren, and Rachel Gelman. Be yond Renewable Portfolio Standards: An Assessment of Regional Supply and Demand Conditions Affecting the Future of Renewable Energy in the West. NREL/TP-6A20- 57830. Golden, CO: NREL, August 2013. Comment [A51]: States exceeding the regional RPS average in 2012 have cost

‐ effective renewable resources and would easily meet CO2 guidelines. Thus, EPA is reducing the stringency of the proposed rule
due to lack of historical policy action in laggard states rather than providing a level of stringency consistent across states

Comment [A52]: EPA Response: We believe this approach applies a consistent level of RE stringency across states in each region, and that it is incidental if a state has already achieved that level of RE performance in practice.

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19 West. Thus, this approach is designed to respect each state’s ability to improve toward the RE targets

developed above.

An illustrative calculation for Illinois’s Best Practice RE generation level is provided below.

Generation levels for all states, in gigawatt-hours a nd percentage terms, are provided in Tables 4.6 and

4.7. Under this approach, Illinois grows its own historic RE generation level by the 6% growth factor

calculated for the North Central region, but it does not reach the North Central regional RE target

generation level of 15% (which would be 29,860 GWh for Illinois) between 2017 and 2029.

State 2012 RE (MWh) (source:

EIA) Assigned Region Regional

RE

Generation Targets (%) Annual Regional
Growth

Factor (%) RE Generation Targets in Each Year (top = GWh, bottom = % of 2012 generation)

2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

Illinois 8,373 North
Central 15% 6% 8,873 9,404 9,967 10,563 11,195 11,864 12,574 13,326 14,123 14,968 15,863 16,812 17,818

4.5% 4.8% 5.0% 5.3% 5.7% 6.0% 6.4% 6.7% 7.1% 7.6% 8.0% 8.5% 9.0%



## An illustrative calculation for Minnesota’s Best Practice RE generation level is provided here, as

an example of a state which has already reached its RE target, with 9,454 GWh of RE generation in 2012,

and thus its obligation under the target is capped at its share of the 15% regional RE target, 7,889 GWh of

RE generation.

State 2012 RE (MWh) (source:

EIA) Assigned Region Regional RE

Generation Targets (%) Annual Regional
Growth

Factor (%) RE Best Practice RE Generation Targets in Each Year (top = GWh, bottom = % of 2012 generation)

2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

Minnesota 9,453 North
Central 15% 6% 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889

15% 15% 15% 15% 15% 15% 15% 15% 15% 15% 15% 15% 15%



## Table 4.6. State Best Practice RE Generation Levels ( Thousand MeGi gawatt-hours)

State Historic
RE Best Practice RE Generation Levels Targets ( thousand MG Wh)

2012 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

AK Calculation for 2017 Generation Target = 8,372 x 1.06 = 8,873

Calculation for 2018 Generation Target = 8,873 x 1.06 = 9,404

Similar calculations are performed for all years from 2017 through 2029, with quantified RE targets in any year not

to exceed the regional RE target level (e.g., 15% for states in the North Central region). 

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Comment [A53]: EPA Comment: We have revised the Arizona, New Mexico and Utah numbers in order to remove generation from units on Indian country from these states’ total generation, which has affected the RE
calculations. This has affected the numbers for these states as well as had small impacts on other states in the Western region.

We have revised Alaska and Hawaii’s target calculations to reflect the revised growth factor
method outlined in this document. This resulted in minor changes in results for both

states.

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20 40 45 43 50 47 55 50 62 54 69 58 76 63 85 68 95 73 106
79 118
85 131
92 146
100 163
107



### AL 2,777 3,150 3,573 4,053 4,597 5,214 5,915 6,709 7,611 8,633 9,793 11,108 12,600 14,293



### AR 1,660 1,799 1,949 2,112 2,288 2,479 2,686 2,911 3,154 3,417 3,702 4,011 4,346 4,709



### AZ 1,698 1,801 1,807 1,911 1,924 2,027 2,048 2,151 2,181 2,282 2,322 2,421 2,472 2,569 2,632 2,725 2,802 2,891 2,983 3,068 3,175 3,255 3,381 3,453 3,599 3,663 3,832



### CA 29,967 31,793 31,903 33,731 33,965 35,787 36,160 37,968 38,497 40,282 40,984 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151 41,151



### CO 6,192 6,569 6,592 6,970 7,018 7,395 7,472 7,845 7,955 8,324 8,469 8,831 9,016 9,369 9,598 9,940 10,219 10,546 10,840 10,840 10,840 10,840 10,840 10,840 10,840 10,840 10,840



### CT 667 750 845 951 1,071 1,206 1,358 1,529 1,721 1,938 2,182 2,457 2,766 3,114



### DE 131 154 180 211 248 291 341 399 468 549 644 755 886 1,038



### FL 4,524 5,131 5,821 6,603 7,490 8,496 9,637 10,931 12,400 14,066 15,955 18,098 20,529 22,110



### GA 3,279 3,719 4,219 4,785 5,428 6,157 6,984 7,922 8,987 10,194 11,563 12,231 12,231 12,231



### HI 925 998 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047



### IA 14,183 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566 8,566



### ID 2,515 2,668 2,677 2,830 2,850 3,003 3,034 3,186 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197 3,197



### IL 8,373 8,873 9,404 9,967 10,563 11,195 11,864 12,574 13,326 14,123 14,968 15,863 16,812 17,818



### IN 3,546 3,758 3,983 4,222 4,474 4,742 5,025 5,326 5,645 5,982 6,340 6,719 7,121 7,547



### KS 5,253 5,691 6,166 6,681 7,239 7,843 8,498 8,885 8,885 8,885 8,885 8,885 8,885 8,885



### KY 333 378 428 486 551 625 709 804 912 1,035 1,174 1,332 1,511 1,714



### LA 2,430 2,633 2,853 3,091 3,349 3,629 3,931 4,260 4,615 5,001 5,418 5,870 6,361 6,892



### MA 1,843 2,076 2,337 2,631 2,962 3,335 3,755 4,228 4,761 5,360 6,035 6,795 7,650 8,613



### MD 898 1,053 1,235 1,448 1,698 1,991 2,335 2,738 3,210 3,764 4,414 5,176 5,982 5,982



### ME 4,099 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612 3,612



### MI 3,785 4,012 4,252 4,506 4,776 5,061 5,364 5,685 6,025 6,385 6,767 7,172 7,601 8,056



### MN 9,454 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889 7,889



### MO 1,299 1,376 1,459 1,546 1,638 1,736 1,840 1,950 2,067 2,190 2,322 2,460 2,608 2,764



### MS 1,509 1,712 1,942 2,203 2,499 2,834 3,215 3,647 4,137 4,692 5,323 5,458 5,458 5,458



### MT 1,262 1,343 1,430 1,523 1,621 1,726 1,837 1,956 2,082 2,217 2,360 2,513 2,675 2,848



### NC 2,704 3,067 3,479 3,946 4,477 5,078 5,760 6,534 7,412 8,407 9,536 10,817 11,668 11,668



### ND 5,280 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460 5,460



### NE 1,347 1,459 1,581 1,713 1,856 2,011 2,179 2,361 2,558 2,771 3,003 3,254 3,525 3,819



### NH 1,381 1,555 1,751 1,971 2,220 2,499 2,814 3,168 3,567 4,016 4,522 4,822 4,822 4,822



### NJ 1,281 1,502 1,761 2,065 2,421 2,839 3,329 3,904 4,577 5,367 6,294 7,380 8,654 10,147



### NM 2,574 2,731 2,740 2,897 2,917 3,074 3,106 3,261 3,306 3,460 3,520 3,671 3,748 3,894 3,990 4,132 4,248 4,384 4,522 4,651 4,814 4,722 5,125 4,722 5,457 4,722 5,809


### NV

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21 2,969 3,150 3,160 3,342 3,365 3,545 3,582 3,761 3,814 3,991 4,060 4,234 4,322 4,492 4,602 4,766 4,899 5,056 5,216 5,364 5,553 5,691 5,912 6,038 6,294 6,406 6,700



### NY 5,192 5,846 6,582 7,411 8,344 9,395 10,578 11,910 13,409 15,098 16,999 19,139 21,549 24,262



### OH 1,739 2,039 2,391 2,803 3,287 3,854 4,519 5,299 6,214 7,287 8,544 10,019 11,748 13,776



### OK 8,521 9,232 10,003 10,838 11,743 12,723 13,785 14,936 15,579 15,579 15,579 15,579 15,579 15,579



### OR 7,207 7,647 7,673 8,113 8,169 8,607 8,697 9,132 9,259 9,688 9,857 10,279 10,494 10,905 11,172 11,570 11,894 12,275 12,567 12,567 12,567 12,567 12,567 12,567 12,567 12,567 12,567



### PA 4,459 5,229 6,131 7,189 8,430 9,885 11,591 13,592 15,938 18,688 21,914 25,696 30,131 35,331



### RI 102 115 129 145 164 184 208 234 263 296 334 376 423 476



### SC 2,143 2,431 2,758 3,128 3,549 4,025 4,566 5,180 5,875 6,665 7,560 8,575 9,676 9,676



### SD 2,915 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819 1,819



### TN 836 949 1,076 1,221 1,385 1,571 1,782 2,021 2,293 2,601 2,950 3,346 3,796 4,306



### TX 34,017 36,857 39,934 43,268 46,880 50,794 55,034 59,629 64,607 70,001 75,845 82,177 85,963 85,963



### UT 1,100 1,167 1,171 1,238 1,246 1,313 1,327 1,393 1,413 1,478 1,504 1,568 1,601 1,664 1,705 1,765 1,815 1,873 1,932 1,987 2,057 2,108 2,190 2,237 2,331 2,373 2,482



### VA 2,358 2,765 3,243 3,802 4,459 5,228 6,131 7,189 8,429 9,884 11,192 11,192 11,192 11,192



### VT 465 524 590 664 748 842 948 1,067 1,201 1,353 1,523 1,645 1,645 1,645



### WA 8,214 8,715 8,745 9,246 9,310 9,810 9,912 10,408 10,552 11,042 11,234 11,715 11,960 12,429 12,733 13,186 13,556 13,990 14,432 14,843 15,365 15,747 16,358 16,707 17,415 17,726 18,540



### WI 3,223 3,416 3,620 3,837 4,066 4,310 4,567 4,841 5,130 5,437 5,762 6,107 6,472 6,859



### WV 1,297 1,520 1,783 2,090 2,451 2,874 3,370 3,952 4,634 5,434 6,372 7,471 8,761 10,273



### WY 4,369 4,635 4,651 4,918 4,952 5,218 5,272 5,536 5,613 5,873 5,975 6,231 6,362 6,611 6,773 7,014 7,210 7,441 7,676 7,895 8,172 8,376 8,700 8,886 9,263 9,428 9,861



## Table 4.7. State Best Practice RE Genera tion Levels (% of Total Generation)

State Historic
RE Best Practice RE Generation Levels

2012 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

AK 0.6% 0.6% 0.7% 0.8%0.
7% 0.9%0.
8% 1.0%0.
8% 1.1%0.
9% 1.2%1.
0% 1.4%1.
1% 1.5%1.
1% 1.7%1.
2% 1.9%1.
3% 2.1%1.
4% 2.3%1.
5%



### AL 2% 2.1% 2.3% 2.7% 3.0% 3.4% 3.9% 4.4% 5.0% 5.6% 6.4% 7.3% 8.2% 9.3%



### AR 3% 2.8% 3.0% 3.2% 3.5% 3.8% 4.1% 4.5% 4.9% 5.3% 5.7% 6.2% 6.7% 7.2%



### AZ 2% 1.9%1.
6% 2.0%1.
7% 2.1%1.
8% 2.3%2.
0% 2.4%2.
1% 2.5%2.
2% 2.7%2.
4% 2.9%2.
5% 3.0%2.
7% 3.2%2.
9% 3.4%3.
0% 3.6%3.
2% 3.9%3.
5%



### CA 15% 16.0% 17.0% 18.1% 19.3% 20.5% 20.6% 20. 6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6%



### CO 12% 12.5% 13.4% 14.2% 15.1% 16.1% 17.2% 18. 3% 19.4% 20.6% 20.6% 20.6% 20.6% 20.6%



### CT 2% 2.1% 2.3% 2.6% 3.0% 3.3% 3.8% 4.2% 4.8% 5.4% 6.0% 6.8% 7.7% 8.6%



### DE 2% 1.8% 2.1% 2.4% 2.9% 3.4% 3.9% 4. 6% 5.4% 6.4% 7.5% 8.7% 10.3% 12.0%



### FL 2% 2.3% 2.6% 3.0% 3.4% 3.8% 4.4% 4. 9% 5.6% 6.4% 7.2% 8.2% 9.3% 10.0%



### GA 3% 3.0% 3.4% 3.9% 4.4% 5.0% 5.7% 6. 5% 7.3% 8.3% 9.5% 10.0% 10.0% 10.0%



### HI 9% 9. 56 % 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0%

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22 IA 25% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15. 1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1%



### ID 16% 17.3% 18.4% 19.6% 20.6% 20.6% 20.6% 20. 6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6%



### IL 4% 4.5% 4.8% 5.0% 5.3% 5.7% 6.0% 6.4% 6.7% 7.1% 7.6% 8.0% 8.5% 9.0%



### IN 3% 3.3% 3.5% 3.7% 3.9% 4.1% 4.4% 4.6% 4.9% 5.2% 5.5% 5.9% 6.2% 6.6%



### KS 12% 12.8% 13.9% 15.0% 16.3% 17.7% 19.1% 20. 0% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0%



### KY 0% 0.4% 0.5% 0.5% 0.6% 0.7% 0.8% 0.9% 1.0% 1.2% 1.3% 1.5% 1.7% 1.9%



### LA 2% 2.5% 2.8% 3.0% 3.2% 3.5% 3.8% 4.1% 4.5% 4.8% 5.2% 5.7% 6.2% 6.7%



### MA 5% 5.7% 6.5% 7.3% 8.2% 9.2% 10.4% 11. 7% 13.2% 14.8% 16.7% 18.8% 21.1% 23.8%



### MD 2% 2.8% 3.3% 3.8% 4.5% 5.3% 6.2% 7. 2% 8.5% 10.0% 11.7% 13.7% 15.8% 15.8%



### ME 28% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0 % 25.0% 25.0% 25.0% 25.0% 25.0%



### MI 3% 3.7% 3.9% 4.2% 4.4% 4.7% 5.0% 5.3% 5.6% 5.9% 6.3% 6.6% 7.0% 7.4%



### MN 18% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15. 1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1%



### MO 1% 1.5% 1.6% 1.7% 1.8% 1.9% 2.0% 2.1% 2.3% 2.4% 2.5% 2.7% 2.8% 3.0%



### MS 3% 3.1% 3.6% 4.0% 4.6% 5.2% 5.9% 6. 7% 7.6% 8.6% 9.8% 10.0% 10.0% 10.0%



### MT 5% 4.8% 5.1% 5.5% 5.8% 6.2% 6.6% 7. 0% 7.5% 8.0% 8.5% 9.0% 9.6% 10.2%



### NC 2% 2.6% 3.0% 3.4% 3.8% 4.4% 4.9% 5. 6% 6.4% 7.2% 8.2% 9.3% 10.0% 10.0%



### ND 15% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15. 1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1%



### NE 4% 4.3% 4.6% 5.0% 5.4% 5.9% 6.4% 6. 9% 7.5% 8.1% 8.8% 9.5% 10.3% 11.2%



### NH 7% 8.1% 9.1% 10.2% 11.5% 13.0% 14.6% 16. 4% 18.5% 20.8% 23.5% 25.0% 25.0% 25.0%



### NJ 2% 2.3% 2.7% 3.2% 3.7% 4.4% 5.1% 6. 0% 7.0% 8.2% 9.6% 11.3% 13.3% 15.5%



### NM 711 % 11.9%
7.5% 12.7%
8.0% 13.4%
8.5% 14.2%
9.0% 15.1%
9.6% 16.0%
10.2% 17.0%
10.9% 18.0%
11.6% 19.1%
12.3% 20.3%
13.1% 20.6%
14.0% 20.6%
14.9% 20.6%
15.9%



### NV 8% 9.0% 9.6% 10.2% 10.8% 11.5% 12.3% 13. 1% 13.9% 14.8% 15.8% 16.8% 17.9% 19.0%



### NY 4% 4.3% 4.8% 5.5% 6.1% 6.9% 7.8% 8. 8% 9.9% 11.1% 12.5% 14.1% 15.9% 17.9%



### OH 1% 1.6% 1.8% 2.2% 2.5% 3.0% 3.5% 4. 1% 4.8% 5.6% 6.6% 7.7% 9.1% 10.6%



### OK 11% 11.9% 12.8% 13.9% 15.1% 16.3% 17.7% 19. 2% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0%



### OR 12% 12.6% 13.4% 14.3% 15.2% 16.2% 17.2% 18. 3% 19.5% 20.6% 20.6% 20.6% 20.6% 20.6%



### PA 2% 2.3% 2.7% 3.2% 3.8% 4.4% 5.2% 6. 1% 7.1% 8.4% 9.8% 11.5% 13.5% 15.8%



### RI 1% 1.4% 1.6% 1.8% 2.0% 2.2% 2.5% 2.8% 3.2% 3.6% 4.0% 4.5% 5.1% 5.7%



### SC 2% 2.5% 2.9% 3.2% 3.7% 4.2% 4.7% 5. 4% 6.1% 6.9% 7.8% 8.9% 10.0% 10.0%



### SD 24% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15. 1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1%



### TN 1% 1.2% 1.4% 1.6% 1.8% 2.0% 2.3% 2.6% 2.9% 3.3% 3.8% 4.3% 4.9% 5.5%



### TX 8% 8.6% 9.3% 10.1% 10.9% 11.8% 12.8% 13. 9% 15.0% 16.3% 17.6% 19.1% 20.0% 20.0%



### UT 3% 3.2%3.
0% 3.4%3.
2% 3.6%3.
4% 3.8%3.
6% 4.1%3.
8% 4.3%4.
1% 4.6%4.
3% 4.9%4.
6% 5.2%4.
9% 5.5%5.
2% 5.8%5.
6% 6.2%5.
9% 6.5%6.
3%



### VA 3% 3.9% 4.6% 5.4% 6.3% 7.4% 8.7% 10. 2% 11.9% 14.0% 15.8% 15.8% 15.8% 15.8%



### VT 7% 8.0% 9.0% 10.1% 11.4% 12.8% 14.4% 16. 2% 18.3% 20.6% 23.2% 25.0% 25.0% 25.0%



### WA 7% 7.5% 8.0% 8.5% 9.0% 9.6% 10.2% 10. 9% 11.6% 12.4% 13.2% 14.0% 14.9% 15.9%



### WI 5% 5.4% 5.7% 6.0% 6.4% 6.8% 7.2% 7. 6% 8.0% 8.5% 9.0% 9.6% 10.2% 10.8%



### WV 2% 2.1% 2.4% 2.8% 3.3% 3.9% 4.6% 5. 4% 6.3% 7.4% 8.7% 10.2% 11.9% 14.0%



### WY 9% 9.4% 10.0% 10.6% 11.3% 12.0% 12.8% 13. 7% 14.5% 15.5% 16.5% 17.5% 18.7% 19.9% 

### Comment [A54]: Such a low commitment, a combination of low starting point and low annual rate of improvement.

Comment [A55]: EPA Response: Thank you for the comment. The method applies the growth factor to existing generation to account for the current level of RE capacity within the

state.

Comment [A56]: EPA should reconsider the policy of reducing a small number of state mandates below what they are already doing or have committed to doing. This would not be hard to do, just average the regions then for the small number of states with higher levels, accept the higher. EPA’s previous response to this question was that “states may obtain renewables from externally, hence the need for restraint to allow flexibility” does not obviate this opportunity to maintain state
commitments.

Comment [A57]: EPA Response: We believe this approach applies a consistent level of RE stringency across states in each region, and that it is incidental if a state has already achieved, or already committed to achieve, that level of RE performance in practice.

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23 4.2.5. Calculate RE targets for interim and final state goals

The agency then translated the annual RE best practice performance levels for each state into

state-level interim and final RE targets for informing this rule’s quantification of state goals. Separate

interim and final RE targets were calculated for the proposed state goals and the alternate state goals in

this proposed rulemaking. For the proposed state goals, the interim RE target for each state was calculated

as the average of that state’s RE best practice performance level from 2020-2029, and the final target is

equivalent to that state’s RE best practice performance level in the year 2029. For the alternate state goals,

the interim RE target for each state was calculated as the average of that state’s RE best practice

performance level from 2020-2024, and the final target is equivalent to that state’s RE best practice

performance level in the year 2024.

A sample calculation for Illinois is provided below. State-level RE targets, expressed in absolute

(megawatt-hour) terms and as a percentage level of each state’s RE generation as a share of its total

generation, along with 2012 RE levels for each state, are provided in Table 4.8. For an explanation of how

these state-level RE targets informed the calculations of state goals in this rule, please refer to the Goal

Computation TSD.

State RE Best Practice Generation Targets in Each Year (top = GWh, bottom = % of 2012 generation)


## Interim & Final Target Calculation

2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 Proposed

Interim (2020

‐ 2029) Proposed
Final (2030) Alternate

Interim (2020

‐ 2024) Alternate
Final (2025)

Illinois 8,873 9,404 9,967 10,563 11,195 11,864 12,574 13,326 14,123 14,968 15,863 16,812 17,818 13,910,775 17,818,004 11,904,488 13,326,217

4.5% 4.8% 5.0% 5.3% 5.7% 6.0% 6.4% 6.7% 7.1% 7.6% 8.0% 8.5% 9.0% 7.0% 9.0% 6.0% 6.7%



## Table 4.8. Proposed and Alternate State Goals Targets for RE Generation as a Percentage of Total

Generation, with 2012 Hist orical RE Generation

State 2012 Proposed GoalsTargets Alternate GoalsTargets Option 1 Interim = average of 2020

‐ 2029 values
Option 1 Final = 2029 value
Option 2 Interim = average of 2020

‐ 2024 values
Option 2 Final = 2024 value 

### Comment [A58]: This explanation falls short of the necessary level of detail that is laid out in the Appendix, and the effect of the mathematical equation. There are two aspects
that need additional discussion:



## 1. The formula inconsistency in how EPA proposes to incorporate existing and new RE into the denominator, as compared to new
and at risk Nuclear. 

## 2. The effect of using a state’s total 2012 power purchase to generate the outyear RE increments, and the effect this has on states with very high percentage renewable levels
in 2012.

Additonal discussion is need with those intimately familiar with the Appendix and Excel spreadsheet.

Comment [A59]: EPA Response: EPA’s approach to nuclear is intended to capture a portion of existing generation representing the risk that such generation may be retired. This situation is irrelevant to the approach to quantify the amount of RE generation (existing and new) that states may achieve as a
reasonable measure to reduce CO2 from the power sector. EPA participated in the additional discussion requested.

Formatted: Font: (Default) Calibri, 8 pt, Complex Script Font: Calibri, 8 pt

Formatted: Font: 11 pt, Complex Script Font: 11 pt

Formatted: Font: 11 pt, Complex Script Font: 11 pt

Comment [A60]: EPA Comment: We have revised the Arizona, New Mexico and Utah numbers in order to remove generation from units on Indian country from these states’ total generation, which has affected the RE
calculations. This has affected the numbers for these states as well as had small impacts on other states in the Western region.

We have revised Alaska and Hawaii’s target calculations to reflect the revised growth factor
method outlined in this document. This resulted in minor changes in results for both

states.

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24 Interim
Level Final Level Interim
Level Final Level

Alabama 2% 6% 9% 4% 5%

Alaska 1% 12 % 2% 1% 1%



## Arizona 2% 3%3% 4%3% 3%2% 3%3%

Arkansas 3% 5% 7% 4% 5%

California 15% 20% 21% 20% 21%

Colorado 12% 19% 21% 17% 19%

Connecticut 2% 5% 9% 4% 5%

Delaware 2% 7% 12% 4% 5%

Florida 2% 6% 10% 4% 6%

Georgia 3% 8% 10% 6% 7%

Hawaii 9% 10% 10% 10% 10%



## Idaho 16% 21% 21% 21% 21%

Illinois 4% 7% 9% 6% 7%

Indiana 3% 5% 7% 4% 5%

Iowa 25% 15% 15% 15% 15%

Kansas 12% 19% 20% 19% 20%

Kentucky 0% 1% 2% 1% 1%

Louisiana 2% 5% 7% 4% 4%

Maine 28% 25% 25% 25% 25%

Maryland 2% 10% 16% 6% 8%

Massachusetts 5% 15% 24% 11% 13%

Michigan 3% 6% 7% 5% 6%

Minnesota 18% 15% 15% 15% 15%

Mississippi 3% 8% 10% 6% 8%

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25 State 2012 Proposed GoalsTargets Alternate GoalsTargets

Interim
Level Final Level Interim
Level Final Level

Missouri 1% 2% 3% 2% 2%

Montana 5% 8% 10% 7% 7%

Nebraska 4% 8% 11% 6% 7%

Nevada 8% 1514 % 1918 % 12% 14%

New Hampshire 7% 19% 25% 15% 19%

New Jersey 2% 8% 16% 5% 7%

New Mexico 7% 18%12% 21%16% 16%10% 18%12%

New York 4% 11% 18% 8% 10%

North Carolina 2% 7% 10% 5% 6%

North Dakota 15% 15% 15% 15% 15%

Ohio 1% 6% 11% 4% 5%

Oklahoma 11% 19% 20% 18% 20%

Oregon 12% 19% 21% 17% 2019 %

Pennsylvania 2% 9% 16% 5% 7%

Rhode Island 1% 4% 6% 3% 3%

South Carolina 2% 7% 10% 5% 6%

South Dakota 24% 15% 15% 15% 15%

Tennessee 1% 3% 6% 2% 3%

Texas 8% 16% 20% 13% 15%

Utah 3% 5%5% 7%6% 4%4% 5%5%

Virginia 3% 12% 16% 9% 12%

Washington 7% 12% 1615 % 10% 1211 %

West Virginia 2% 8% 14% 5% 6%

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26 State 2012 Proposed GoalsTargets Alternate GoalsTargets

Interim
Level Final Level Interim
Level Final Level

Wisconsin 5% 8% 11% 7% 8%

Wyoming 9% 15% 2019 % 13% 1514 %

Table 4.9. Proposed and Alternate State Goals Targets for RE Generation in Megawatt-hours, with 2012

Historical RE Generation

State 2012 Proposed GoalsTargets Alternate GoalTarget s

Interim Level Final
Level Interim Level Final
Level

Alabama 2,776,554 8,647,278 14,292,801 6,009,218 7,610,632

Alaska 39,958 105,136 78,090 163,089 107,370 77,373 63,422 94,950 73,413

Arizona 1,697,652 2,847,759 2,937,707 3,663,325 3,831,642 2,429,595 2,481,537 2,725,233 2,801,621

Arkansas 1,660,370 3,370,253 4,708,823 2,703,555 3,153,509

California 29,966,846 40,745,587 40,868,634 41,150,704 41,150,704 40,340,469 40,586,564 41,150,704 41,150,704

Colorado 6,192,082 9,821,423 9,945,536 10,839,820 10,839,820 8,861,798 9,051,252 9,940,119 10,218,740

Connecticut 666,525 1,934,220 3,114,375 1,376,991 1,721,274

Delaware 131,051 561,909 1,038,351 349,356 468,394

Florida 4,523,798 13,971,137 22,109,614 9,790,728 12,399,889

Georgia 3,278,536 9,392,695 12,230,636 7,095,644 8,986,583

Hawaii 924,815 1,046,927 1,046,927 1,046,927 1,046,927

Idaho 2,514,502 3,195,6063,196,687 3,196,687 3,194,5263,196,687 3,196,687

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27 Illinois 8,372,660 13,910,775 17,818,004 11,904,488 13,326,217

Indiana 3,546,367 5,892,120 7,547,086 5,042,327 5,644,522

Iowa 14,183,424 8,565,921 8,565,921 8,565,921 8,565,921

Kansas 5,252,653 8,577,482 8,884,938 8,270,026 8,884,938

Kentucky 332,879 1,036,717 1,713,556 720,442 912,434

Louisiana 2,430,042 4,932,549 6,891,619 3,956,800 4,615,333

Maine 4,098,795 3,611,728 3,611,728 3,611,728 3,611,728

Maryland 898,152 3,728,926 5,982,069 2,394,301 3,210,129

Massachusetts 1,843,419 5,349,504 8,613,477 3,808,366 4,760,555

Michigan 3,785,439 6,289,326 8,055,859 5,382,246 6,025,037

Minnesota 9,453,871 7,888,544 7,888,544 7,888,544 7,888,544

Mississippi 1,509,190 4,272,197 5,458,430 3,266,297 4,136,743

Missouri 1,298,579 2,157,527 2,763,528 1,846,357 2,066,863

Montana 1,261,752 2,116,550 2,183,403 2,722,706 2,847,804 1,805,757 1,844,362 2,025,485 2,082,259

Nebraska 1,346,762 2,733,684 3,819,427 2,192,912 2,557,879

Nevada 2,968,630 4,979,784 5,137,075 6,405,939 6,700,268 4,248,556 4,339,384 4,765,528 4,899,105

New Hampshire 1,381,285 3,727,303 4,822,223 2,853,632 3,567,113

New Jersey 1,280,715 5,491,354 10,147,466 3,414,138 4,577,463

New Mexico 2,573,851 4,161,824 4,453,928 4,721,996 3,683,568 3,762,317 4,131,791

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5,809,243 4,247,605

New York 5,192,427 15,068,148 24,261,905 10,727,168 13,409,233

North
Carolina 2,703,919 8,135,750 11,668,176 5,852,016 7,411,538

North Dakota 5,280,052 5,459,957 5,459,957 5,459,957 5,459,957

Ohio 1,738,622 7,454,735 13,775,594 4,634,830 6,214,090

Oklahoma 8,520,724 14,666,348 15,579,318 13,753,378 15,579,318

Oregon 7,207,229 11,411,751 11,551,256 12,567,372 12,567,372 10,314,627 10,535,140 11,569,730 11,894,029

Pennsylvania 4,459,118 19,119,477 35,330,855 11,887,147 15,937,543

Rhode Island 101,895 295,694 476,110 210,507 263,140

South
Carolina 2,143,473 6,534,613 9,675,568 4,639,057 5,875,334

South Dakota 2,914,666 1,818,850 1,818,850 1,818,850 1,818,850

Tennessee 836,458 2,605,058 4,305,814 1,810,322 2,292,760

Texas 34,016,697 67,689,311 85,962,502 55,388,864 64,607,260

Utah 1,099,724 1,844,752 1,903,020 2,373,069 2,482,103 1,573,870 1,607,517 1,765,381 1,814,865

Virginia 2,358,444 8,608,808 11,192,008 6,287,155 8,429,425

Washington 8,214,350 13,779,314 14,214,545 17,725,558 18,539,981 11,755,968 12,007,295 13,186,456 13,556,072

West Virginia 1,296,563 5,559,307 10,273,036 3,456,386 4,634,107

Wisconsin 3,223,178 5,355,156 6,859,301 4,582,807 5,130,122

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29 Wyoming 4,369,107 7,329,040 7,560,533 9,427,996 9,861,177 6,252,848 6,386,526 7,013,706 7,210,300

The annual rates used to set state RE targets under this best practices scenario are comparable to

rates that leader states have been able to approach in the past. Eleven states across four regions have

already achieved over 10% of total generation from RE , surpassing the lowest regional target applied in

the Southeast. Two states, Maine and Iowa, have already equaled or surpassed the highest regional target

of 25% of generation, with South Dakota close behind at 24%. Finally, five states have already reached

their region’s required target.

4.3 Cost Effectiveness of RE

The costs of building new RE capacity and generati ng more RE have changed significantly in the

past decade, particularly for wind and solar. According to an EPA analysis based on EIA levelized costs,

costs of new RE, particularly on-shore wind, are becoming comparable to the cost-effectiveness of other

re-dispatch technologies such as new NGCC plants. 28



## The economics of the fastest growing RE technologies – on-shore wind and solar PV – are

improving. According to recent analyses of wind and solar project costs and pricing trends by U.S.

Department of Energy, levelized long-term power purch ase agreement (PPA) prices have been declining.

PPA prices, in general, reflect actual agreements to pay for power from wind or solar projects over a longterm and cover the cost of installing, operating, and maintaining a wind or solar project, along with a

profit margin. 29 

## For utility-scale solar PV, those levelized PPA prices have fallen by more than two-thirds

in the past five years “driven primarily by lower installed PV project prices (which, in turn, have been

driven primarily by declining module prices), as well as expectations for further cost reductions in future

years.” 30 

## More recent PPAs in the West are reporting le velized PPA prices in the range of $50-60/MWh

28 

## EPA calculations of estimated dollar per tonne costs, based on EIA AEO 2013 levelized costs of electricity.

29 

## Bolinger, Mark, and Samantha Weaver. Utility-Scale So lar 2012: An Empirical Analysis of Project Cost, Performance, and Pricing Trends in the United Stat es. Lawrence Berkeley National Laboratory. LBNL-6408E. September 2013. p. 19.

30 

## Bolinger, Mark, and Samantha Weaver. Utility-Scale So lar 2012: An Empirical Analysis of Project Cost, Performance, and Pricing Trends in the United Stat es. Lawrence Berkeley National Laboratory. LBNL-6408E. September 2013. p. ii. Comment [A61]:  the AEO2013 levelized cost report shows NGCC costs ranging from 60.0 – 76.1 with an average of 65.6. Wind ranges from 73.5 – 99.8 with an average of 86.6. In the commenter’s view, the average levelized costs are not properly characterized as being “comparable.” As discussed in a report posted on EIA’s AEO website, levelized costs are not necessarily a very good measure of the cost-effectiveness of re-dispatch -- see http://www.eia.gov/forecasts/aeo/electricit y_generation.cfm

. Comment [A62]: EPA Response: We have removed the language.

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30 (in 2012 dollars). 31 

## For wind, PPA prices have fallen since 2009 despite a trend within the wind industry

to build projects at lower-quality wind resource sites. 32 

## “The average levelized long-term price from wind

PAs signed in 2011/2012—many of which were for projects built in 2012—fell to around $40/MWh

nationwide.” 33



## Examining RE resource availability regionally, several recent studies have found cost-effective or

economic RE resources are available to serve future needs. The National Renewable Energy Laboratory

(NREL) examined the future availability of RE in the West after Western state RPS requirements level off

in 2025. 34 

## The study compares the cost of RE generation from the West's most productive RE resource

areas—including any needed transmission and integra tion costs—with the cost of energy from a new

natural gas-fired generator built near the customers it serves. The report indicates that by 2025 wind and

solar PV generation could become cost-competitive, if new RE development occurs in the most

productive locations. 35 

## It also has shown that a cost decrease of 10% in 2025 would bring solar power to

cost parity with NGCC in the West, with similar possibilities for utility scale geothermal. In 2010, the

Southeast Energy Efficiency Alliance published a re port by Marilyn Brown et al. titled Renewable

Energy in the South. 36 

## In addition to highlighting significant RE resources in different parts of the region,

it stated, “Under realistic renewable expansion and policy scenarios, the region could economically

supply a large proportion of its future electricity n eeds from both utility-scale and customer-owned RE

sources.” 37 

## This study suggested that increased RE utilization should not necessarily lead to significant

rate increases in part because RE resources may moderate forecasted rate increases in the next decade or

two. 38



## Several studies have found the cost of RPS-driven RE deployment to be modest. One

comparative analysis that "synthesize[d] and analyze[d] the results and methodologies of 28 distinct state

31 

## Ibid.

32 

## Wiser, Ryan H., and Mark Bolinger. 2012 Wind Technologies Market Report. Lawrence Berkeley National Laboratory. August 2013. p. viii.

33 

## Ibid.

34 

## Hurlbut, David, Joyce McLaren, and Rachel Gelman. Be yond Renewable Portfolio Standards: An Assessment of Regional Supply and Demand Conditions Affecting the Future of Renewable Energy in the West. NREL/TP-6A20- 57830. Golden, CO: NREL, August 2013.

35 

## Ibid. p. xvi.

36 

## Brown, Marilyn A., Etan Gumerman, Youngsun Baek, Joy Wang, Cullen Morris, and Yu Wang. 2010. Renewable Energy in the South. Atlanta, GA: Southeast Energy Effi ciency Alliance, December 2010. See also Brown, Marilyn A., Etan Gumerman, Xiaojing Sun, Kenneth Sercy, a nd Gyungwon Kim. 2012. “Myths and Facts about Clean Electricity in the U.S. South,” Energy Policy, 40: 231-241.

37 

## Ibid. p. xxii.

38 

## Ibid., p. 109.

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31 or utility-level RPS cost impact analyses" found the me dian change in retail electricity price to be $0.0004

per kilowatt-hour (only a 0.7 percent increase), the me dian monthly bill impact to be between $0.13 and

$0.82, and the median CO 2 

## reduction cost to be $3 per metric ton. 39 

## This finding has been confirmed with

more recent RPS cost data, including a report that determined 2010-2012 retail electricity price impacts

due to state RPS policies to be less than two percent, with only two states experiencing price impacts of

greater than three percent. 40



## 4.4. Cost Effectiveness of Nuclear Energy

Nuclear generating capacity facilitates CO 2 

## emission reductions at fossil fuel-fired EGUs by

providing carbon-free generation that can replace generation at those EGUs. Increasing the amount of

nuclear capacity relative to the amount that would otherwise be available to operate is therefore a

technically viable approach that states may consider in the development of state plans for reducing CO2

emissions from affected fossil fuel-fired EGUs.

One way to increase the amount of available nuclear capacity is to build new nuclear EGUs.

However, nuclear generating capacity is relativel y expensive to build compared to other types of

generating capacity, and little new nuclear capacity has been constructed in the U.S. in recent years.

Nevertheless, fF ive new nuclear EGUs at three plants are currently under construction: Watts Bar 2 in

Tennessee, Vogtle 3-4 in Georgia, and Summer 2-3 in South Carolina. The EPA believes that since the

decisions to construct these units were made prior to th is proposal, it is reasonable to view the incremental

cost associated with the CO 2 

## emission reductions available from completion of these units as zero for

purposes of setting states’ CO 2 

## reduction goals. Completion of these units therefore represents a highly

cost-effective opportunity to reduce CO 2 

## emissions from affected fossil fuel-fired EGUs. For this reason,

we are proposing that the emission reductions achievable at affected sources due to the generation

provided at the identified new nuclear units should be factored into the state goals for the respective states

where these new units are located.

Another way to increase the amount of available nuclear capacity is to preserve existing nuclear

EGUs that would otherwise be retired. While each retirement decision is based on the unique

39 

## Chen et al., "Weighing the Costs and Benefits of State Renewable Portfolio Standards: A Comparative Analysis of State-Level Policy Impact Projections," Lawrence Berk eley National Laboratory, March 2007, available at http://emp.lbl.gov/publications/weighing-costs-and-benefi ts-state-renewables-portfolio-standards-comparativeanalysis-s.

40 

## Galen Barbose, “Renewables Portfolio Standards in th e United States: A Status Update,” Lawrence Berkeley National Lab, November 2013. Also, Heeter, J., Barbose, G., Bird, L., Weaver, S., Flores-Espino, F., KuskovaBurns, K., and Wiser, R. (Forthcoming). “A Survey of State-Level Cost and Benefit Estimates of Renewable Portfolio Standards.” NREL Report No. 6A20-61042, LBNL Report No. 6589E. Comment [A63]: General Comment: The framing of the discussion is that EPA finds new renewables to be a cost

‐ effective means of reducing CO2 but it does not find new nuclear

to be cost

‐ effective. This language should be
clarified. At a minimum, it must be clear that
those determinations are part of how EPA
decided to include or exclude technology deployments in setting the goals. The way it is

written seems like it is telling states not to

pursue new nuclear.

This also seems to be at odds with earlier statements (p. 1):

Comment [A64]: EPA Response: We have edited the section title to address the framing concern, and we have noted that states may
consider the construction of new nuclear in their development of state plans.

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32 circumstances of that individual unit, the EPA recognizes that a host of factors – increasing fixed

operation and maintenance costs, relatively low wholesale electricity prices, and additional capital

investment associated with ensuring plant security and emergency preparedness – have altered the

outlook for the U.S. nuclear fleet in recent years. Re flecting similar concern for these challenges, EIA in

its most recent Annual Energy Outlook has projected an additional 5.7 GW of capacity reductions to the

nuclear fleet. EIA describes the proj ected capacity reductions – which are not tied to the retirement of any

specific unit – as necessary to recognize the “continued economic challenges” faced by the higher-cost

nuclear units. 41 

## Likewise, without making any judgment about the likelihood that any individual EGU

will retire, we view this 5.7 GW, which comprises an approximately six percent share of nuclear capacity,

as a reasonable proxy for the amount of nuclear capacity at risk of retirement.

While each retirement decision is based on the unique circumstances of that individual unit, the EPA

believes that increased fixed costs associated with unit age play a role, particularly as the units approach

the point of deciding whether to apply for renewal of their initial operating licenses (which have 40-year

terms). Of the existing fleet of nuclear EGUs, units with 7.8 GW of capacity, representing approximately

eight percent of total existing U.S. nuclear generatin g capacity, have not yet submitted applications for

license renewal to the Nuclear Regulatory Commission. Without making any judgment about the

likelihood that any individual EGU will retire, we view this eight percen t share of nuclear capacity as a

reasonable proxy for the amount of nuclear capacity at risk of retirement for reasons including, but not

limited to, additional fixed costs related to age and relicensing.

We believe that, based on available information regarding the cost and performance of the

nuclear fleet, preserving the operation of this existing, at-risk nuclear capacity is likely to be a relatively

cost-effective approach to achieving CO2 reductions from affected EGUs. According to a recent report,
nuclear units may be experiencing up to a $6/MWh sh ortfall in covering their operating costs with

electricity sales. 42 

## Assuming that such a revenue shortfall is representative of the incentive to retire the

estimated eight percent of at-risk nuclear capacity, one can estimate the value of offsetting the revenue
loss at these at-risk nuclear units to be about $12 to $17 per metric ton. 43 

## The EPA views this cost as

reasonable. We therefore propose that the emission reductions achievable by retaining in operation

41 

## “Implications of accelerated power plant retirements ,” Jeffrey Jones and Michael Leff, EIA, April 2014

42 

## “Nuclear... The Middle Age Dilemma?” Eggers, et al., Credit Suisse, February 2013

43 

## The derivation of $12 to $17 per metric ton assumes that replacement power for at-risk nuclear capacity is sourced either from new NGCC capacity at 800 lbs CO 2 

## /MWh or from the projected averag e 2020 emissions intensity across the U.S. power system at 1,127 lbs CO 2 

## /MWh(from EPA’s IPM Base Case). Comment [A65]: Please consider providing more information on the choice of 8%.

Comment [A66]: EPA Response: Based on discussions with interagency reviewers, we have changed the methodology for quantifying at-risk nuclear capacity and have amended this TSD accordingly.

Comment [A67]: Including additional references would be helpful.

Comment [A68]: EPA Response: Content has been adjusted.

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33 approximately eight six percent of each state’s existing historical nuclear capacity should be factored into

the state goals for the respective states. 44



## The amount of at-risk nuclear generation quantified for each state is displayed in Table 4.10:

Table 4.10. Nuclear At-Risk Generation by State

State 2012 Nuclear Fleet (MW)* At

‐ Risk Nuclear Capacity (MW) At

‐ Risk Nuclear

Generation (GWh)

Alabama 5,043 295 2,330

Arizona 3,937 230 1,818

Arkansas 1,823 107 842

California 2,240 131 1,035

Connecticut 2,103 123 971

Florida 3,514 205 1,623

Georgia 4,061 237 1,876

Illinois 11,486 671 5,305

Iowa 601 35 278

Kansas 1,175 69 543

Louisiana 2,133 125 985
Maryland 1,705 100 788

Massachusetts 685 40 316

Michigan 3,957 231 1,828

Minnesota 1,819 106 840

Mississippi 1,368 80 632

Missouri 1,190 70 550

Nebraska 1,245 73 575

New Hampshire 1,246 73 576

New Jersey 3,499 204 1,616

44 

## Historical nuclear fleet excludes Watts Bar 2, Vogtle 3-4, and Summer 2-3, as well as all units that have retired or are committed to retire (as of May 2014).

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34 New York 5,219 305 2,411

North Carolina 4,970 290 2,296

Ohio 2,150 126 993

Pennsylvania 9,700 567 4,480

South Carolina 6,486 379 2,996

Tennessee 3,401 199 1,571

Texas 4,960 290 2,291

Virginia 3,562 208 1,645

Washington 1,097 64 507

Wisconsin 1,184 69 547

Total 97,559 5,700 45,062

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35 Appendix 4-1. RE Generation Targets Including Existing

Table 4-1.1. State Best Practice RE Generation Levels including 20 12 Existing Hydropower Generation

(Gigawatt-hours)

State 2012 Existing Hydro 2012
Nonhydro
RE (GWh) 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

Alabama 7,435 2,777 10,585 11,008 11,488 12,032 12,650 13,350 14,145 15,046 16,068 17,228 18,543 20,035 21,728

Alaska 1,575 40 1,620 1,625 1,630 1,637 1,644 1,652 1,660 1,670 1,681 1,693 1,706 1,721 1,738

Arizona 6,717 1,698 8,518 8,628 8,744 8,868 8,999 9,138 9,286 9,442 9,608 9,784 9,971 10,170 10,380

Arkansas 2,198 1,660 3,997 4,148 4,310 4,487 4,678 4,885 5,109 5,352 5,615 5,901 6,210 6,544 6,907

California 26,837 29,967 58,631 60,568 62,624 64,805 67,120 67,988 67,988 67,988 67,988 67,988 67,988 67,988 67,988

Colorado 1,497 6,192 8,067 8,467 8,892 9,343 9,821 10,328 10,866 11,437 12,043 12,337 12,337 12,337 12,337

Connecticut 312 667 1,063 1,157 1,263 1,383 1,518 1,670 1,841 2,033 2,250 2,494 2,769 3,078 3,427

Delaware
- 131 154 180 211 248 291 341 399 468 549 644 755 886 1,038

Florida 151 4,524 5,282 5,971 6,753 7,640 8,646 9,787 11,082 12,550 14,216 16,105 18,249 20,680 22,260

Georgia 2,236 3,279 5,955 6,455 7,021 7,664 8,393 9,220 10,159 11,223 12,430 13,799 14,467 14,467 14,467

Hawaii 115 925 1,112 1,162 1,162 1,162 1,162 1,162 1,162 1,162 1,162 1,162 1,162 1,162 1,162

Idaho 10,940 2,515 13,608 13,771 13,943 14,126 14,137 14,137 14,137 14,137 14,137 14,137 14,137 14,137 14,137

Illinois 111 8,373 8,985 9,515 10,078 10,674 11,306 11,976 12,685 13,437 14,235 15,079 15,975 16,924 17,929

Indiana 434 3,546 4,192 4,417 4,655 4,908 5,175 5,459 5,759 6,078 6,416 6,773 7,153 7,555 7,981

Iowa 766 14,183 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332 9,332

Kansas 10 5,253 5,702 6,177 6,692 7,249 7,854 8,508 8,895 8,895 8,895 8,895 8,895 8,895 8,895

Kentucky 2,362 333 2,739 2,790 2,848 2,913 2,987 3,071 3,166 3,274 3,397 3,536 3,694 3,872 4,075

Louisiana 680 2,430 3,313 3,533 3,771 4,029 4,308 4,611 4,940 5,295 5,681 6,098 6,550 7,041 7,572

Maine 3,733 4,099 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344 7,344

Maryland 1,657 898 2,710 2,891 3,105 3,355 3,648 3,991 4,394 4,867 5,421 6,070 6,832 7,639 7,639

Massachusetts 912 1,843 2,988 3,249 3,544 3,875 4,248 4,668 5,141 5,673 6,272 6,947 7,707 8,563 9,526

Michigan 1,215 3,785 5,227 5,467 5,721 5,991 6,276 6,579 6,900 7,240 7,600 7,982 8,387 8,816 9,271

Minnesota 561 9,454 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450 8,450

Mississippi
- 1,509 1,712 1,942 2,203 2,499 2,834 3,215 3,647 4,137 4,692 5,323 5,458 5,458 5,458

Missouri 714 1,299 2,091 2,173 2,260 2,353 2,451 2,554 2,664 2,781 2,905 3,036 3,175 3,322 3,478

Montana 11,283 1,262 12,622 12,704 12,790 12,882 12,980 13,083 13,193 13,309 13,432 13,563 13,702 13,850 14,006

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36 Nebraska 1,257 1,347 2,716 2,838 2,970 3,113 3,268 3,436 3,618 3,815 4,028 4,260 4,511 4,782 5,076

Nevada 2,440 2,969 5,590 5,782 5,986 6,202 6,431 6,674 6,932 7,206 7,496 7,805 8,131 8,478 8,846

New Hampshire 1,289 1,381 2,845 3,040 3,261 3,509 3,789 4,103 4,458 4,856 5,306 5,811 6,112 6,112 6,112

New Jersey 11 1,281 1,513 1,772 2,076 2,432 2,850 3,340 3,914 4,588 5,378 6,305 7,391 8,665 10,158

New Mexico 223 2,574 2,954 3,120 3,297 3,484 3,683 3,894 4,117 4,355 4,606 4,874 4,945 4,945 4,945

New York 24,652 5,192 30,499 31,235 32,064 32,997 34,047 35,230 36,562 38,062 39,750 41,651 43,791 46,201 48,914

North Carolina 3,728 2,704 6,795 7,207 7,674 8,205 8,806 9,488 10,262 11,139 12,135 13,264 14,545 15,396 15,396

North Dakota 2,477 5,280 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937 7,937

Ohio 414 1,739 2,453 2,805 3,217 3,701 4,268 4,934 5,714 6,628 7,701 8,958 10,433 12,162 14,190

Oklahoma 1,146 8,521 10,378 11,148 11,983 12,888 13,869 14,931 16,082 16,725 16,725 16,725 16,725 16,725 16,725

Oregon 39,410 7,207 47,057 47,523 48,017 48,542 49,098 49,689 50,315 50,980 51,685 51,978 51,978 51,978 51,978

Pennsylvania 2,242 4,459 7,471 8,373 9,431 10,672 12,127 13,833 15,834 18,179 20,930 24,156 27,938 32,373 37,573

Rhode Island 4 102 119 133 150 168 189 212 238 267 301 338 380 427 480

South Carolina 1,420 2,143 3,852 4,178 4,549 4,969 5,446 5,986 6,600 7,296 8,085 8,980 9,996 11,096 11,096

South Dakota 5,981 2,915 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800 7,800

Tennessee 8,296 836 9,244 9,372 9,517 9,681 9,867 10,078 10,317 10,588 10,896 11,246 11,642 12,092 12,601

Texas 584 34,017 37,441 40,518 43,852 47,464 51,378 55,619 60,213 65,192 70,586 76,430 82,762 86,547 86,547

Utah 748 1,100 1,915 1,986 2,061 2,141 2,226 2,316 2,412 2,513 2,621 2,735 2,856 2,985 3,121

Virginia 1,044 2,358 3,809 4,287 4,846 5,503 6,272 7,174 8,232 9,473 10,928 12,236 12,236 12,236 12,236

Washington 89,464 8,214 98,179 98,711 99,274 99,872 100,506 101,179 101,893 102,651 103,455 104,307 105,212 106,172 107,190

West Virginia 1,431 1,297 2,952 3,214 3,522 3,883 4,306 4,802 5,383 6,066 6,865 7,803 8,903 10,192 11,704

Wisconsin 1,522 3,223 4,938 5,143 5,359 5,589 5,832 6,090 6,363 6,652 6,959 7,284 7,629 7,994 8,382

Wyoming 893 4,369 5,529 5,811 6,111 6,429 6,767 7,124 7,504 7,907 8,335 8,788 9,269 9,780 10,321



## Table 4-1.2. State Best Practice RE Generation Levels (% of Total Generation) including 2012 Existing Hydropower Generation

State State Abbrev 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029

Alabama AL 6.9% 7.2% 7.5% 7.9% 8.3% 8.7% 9.3% 9.8% 10.5% 11.3% 12.1% 13.1% 14.2%

Alaska AK 23.3% 23.4% 23.5% 23.6% 23.7% 23.8% 23.9% 24.0% 24.2% 24.4% 24.6% 24.8% 25.0%

Arizona AZ 9.0% 9.1% 9.2% 9.3% 9.5% 9.6% 9.8% 9.9% 10.1% 10.3% 10.5% 10.7% 10.9%

Arkansas AR 6.1% 6.4% 6.6% 6.9% 7.2% 7.5% 7.9% 8.2% 8.6% 9.1% 9.6% 10.1% 10.6%

California CA 29.4% 30.4% 31.4% 32.5% 33.6% 34.1% 34.1% 34.1% 34.1% 34.1% 34.1% 34.1% 34.1%

Colorado CO 15.3% 16.1% 16.9% 17.8% 18.7% 19.7% 20.7% 21.8% 22.9% 23.5% 23.5% 23.5% 23.5%

Connecticut CT 2.9% 3.2% 3.5% 3.8% 4.2% 4.6% 5.1% 5.6% 6.2% 6.9% 7.7% 8.5% 9.5% 

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37 Delaware DE 1.8% 2.1% 2.4% 2.9% 3.4% 3.9% 4.6% 5.4% 6.4% 7.5% 8.7% 10.3% 12.0%

Florida FL 2.4% 2.7% 3.1% 3.5% 3.9% 4.4% 5.0% 5.7% 6.4% 7.3% 8.3% 9.4% 10.1%

Georgia GA 4.9% 5.3% 5.7% 6.3% 6.9% 7.5% 8.3% 9.2% 10.2% 11.3% 11.8% 11.8% 11.8%

Hawaii HI 10.6% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1% 11.1%

Idaho ID 87.8% 88.8% 90.0% 91.1% 91.2% 91.2% 91.2% 91.2% 91.2% 91.2% 91.2% 91.2% 91.2%

Illinois IL 4.5% 4.8% 5.1% 5.4% 5.7% 6.1% 6.4% 6.8% 7.2% 7.6% 8.1% 8.6% 9.1%

Indiana IN 3.7% 3.9% 4.1% 4.3% 4.5% 4.8% 5.0% 5.3% 5.6% 5.9% 6.2% 6.6% 7.0%

Iowa IA 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5% 16.5%

Kansas KS 12.8% 13.9% 15.1% 16.3% 17.7% 19.2% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0%

Kentucky KY 3.0% 3.1% 3.2% 3.2% 3.3% 3.4% 3.5% 3.6% 3.8% 3.9% 4.1% 4.3% 4.5%

Louisiana LA 3.2% 3.4% 3.6% 3.9% 4.2% 4.5% 4.8% 5.1% 5.5% 5.9% 6.3% 6.8% 7.3%

Maine ME 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9% 50.9%

Maryland MD 7.2% 7.6% 8.2% 8.9% 9.6% 10.6% 11.6% 12.9% 14.3% 16.1% 18.1% 20.2% 20.2%

Massachusetts MA 8.3% 9.0% 9.8% 10.7% 11.7% 12.9% 14.2% 15.7% 17.3% 19.2% 21.3% 23.7% 26.3%

Michigan MI 4.8% 5.1% 5.3% 5.5% 5.8% 6.1% 6.4% 6.7% 7.0% 7.4% 7.8% 8.2% 8.6%

Minnesota MN 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2% 16.2%

Mississippi MS 3.1% 3.6% 4.0% 4.6% 5.2% 5.9% 6.7% 7.6% 8.6% 9.8% 10.0% 10.0% 10.0%

Missouri MO 2.3% 2.4% 2.5% 2.6% 2.7% 2.8% 2.9% 3.0% 3.2% 3.3% 3.5% 3.6% 3.8%

Montana MT 45.4% 45.7% 46.0% 46.3% 46.7% 47.1% 47.4% 47.9% 48.3% 48.8% 49.3% 49.8% 50.4%

Nebraska NE 7.9% 8.3% 8.7% 9.1% 9.6% 10.0% 10.6% 11.1% 11.8% 12.4% 13.2% 14.0% 14.8%

Nevada NV 15.9% 16.4% 17.0% 17.6% 18.3% 19.0% 19.7% 20.5% 21.3% 22.2% 23.1% 24.1% 25.2%

New Hampshire NH 14.8% 15.8% 16.9% 18.2% 19.7% 21.3% 23.1% 25.2% 27.5% 30.2% 31.7% 31.7% 31.7%

New Jersey NJ 2.3% 2.7% 3.2% 3.7% 4.4% 5.1% 6.0% 7.0% 8.2% 9.7% 11.3% 13.3% 15.6%

New Mexico NM 12.9% 13.6% 14.4% 15.2% 16.1% 17.0% 18.0% 19.0% 20.1% 21.3% 21.6% 21.6% 21.6%

New York NY 22.5% 23.0% 23.6% 24.3% 25.1% 25.9% 26.9% 28.0% 29.3% 30.7% 32.3% 34.0% 36.0%

North Carolina NC 5.8% 6.2% 6.6% 7.0% 7.5% 8.1% 8.8% 9.5% 10.4% 11.4% 12.5% 13.2% 13.2%

North Dakota ND 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0% 22.0%

Ohio OH 1.9% 2.2% 2.5% 2.9% 3.3% 3.8% 4.4% 5.1% 5.9% 6.9% 8.0% 9.4% 10.9%

Oklahoma OK 13.3% 14.3% 15.4% 16.5% 17.8% 19.2% 20.6% 21.5% 21.5% 21.5% 21.5% 21.5% 21.5%

Oregon OR 77.2% 78.0% 78.8% 79.7% 80.6% 81.5% 82.6% 83.7% 84.8% 85.3% 85.3% 85.3% 85.3%

Pennsylvania PA 3.3% 3.7% 4.2% 4.8% 5.4% 6.2% 7.1% 8.1% 9.4% 10.8% 12.5% 14.5% 16.8%

Rhode Island RI 1.4% 1.6% 1.8% 2.0% 2.3% 2.5% 2.9% 3.2% 3.6% 4.1% 4.6% 5.1% 5.8%

South Carolina SC 4.0% 4.3% 4.7% 5.1% 5.6% 6.2% 6.8% 7.5% 8.4% 9.3% 10.3% 11.5% 11.5%

South Dakota SD 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8% 64.8%

Tennessee TN 11.9% 12.1% 12.2% 12.5% 12.7% 13.0% 13.3% 13.6% 14.0% 14.5% 15.0% 15.6% 16.2%

Texas TX 8.7% 9.4% 10.2% 11.0% 12.0% 12.9% 14.0% 15.2% 16.4% 17.8% 19.3% 20.1% 20.1%

Utah UT 5.3% 5.5% 5.7% 5.9% 6.1% 6.4% 6.6% 6.9% 7.2% 7.5% 7.9% 8.2% 8.6%

Virginia VA 5.4% 6.1% 6.9% 7.8% 8.9% 10.1% 11.6% 13.4% 15.4% 17.3% 17.3% 17.3% 17.3%

Washington WA 84.0% 84.5% 85.0% 85.5% 86.0% 86.6% 87.2% 87.9% 88.5% 89.3% 90.1% 90.9% 91.7%

West Virginia WV 4.0% 4.4% 4.8% 5.3% 5.9% 6.5% 7.3% 8.3% 9.4% 10.6% 12.1% 13.9% 15.9%

Wisconsin WI 7.7% 8.1% 8.4% 8.8% 9.1% 9.6% 10.0% 10.4% 10.9% 11.4% 12.0% 12.5% 13.1%

# I NTERAGENCY 

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38 Wyoming WY 11.1% 11.7% 12.3% 13.0% 13.6% 14.4% 15.1% 15.9% 16.8% 17.7% 18.7% 19.7% 20.8%



## Table 4-1.3. Proposed and Alternate State Targets for RE Generation as a Percentage of Total Generation,

with 2012 Historical RE Generation

State 2012 Proposed Targets Alternate Targets

Interim Level Final
Level Interim Level Final
Level

Alabama 7% 11% 14% 9% 10%

Alaska 23% 24% 25% 24% 24%

Arizona 9% 10% 11% 10% 10%

Arkansas 6% 9% 11% 8% 8%

California 28% 34% 34% 34% 34%

Colorado 15% 22% 23% 20% 22%

Connecticut 3% 6% 9% 5% 6%

Delaware 2% 7% 12% 4% 5%

Florida 2% 6% 10% 4% 6% Georgia 5% 10% 12% 8% 9%

Hawaii 10% 11% 11% 11% 11%

Idaho 87% 91% 91% 91% 91%

Illinois 4% 7% 9% 6% 7%

Indiana 3% 6% 7% 5% 5%

Iowa 26% 16% 16% 16% 16%

Kansas 12% 19% 20% 19% 20% Kentucky 3% 4% 5% 3% 4%

Louisiana 3% 5% 7% 4% 5%

Maine 54% 51% 51% 51% 51% Maryland 7% 14% 20% 11% 13%

Massachusetts 8% 17% 26% 13% 16% Michigan 5% 7% 9% 6% 7%

Minnesota 19% 16% 16% 16% 16% Mississippi 3% 8% 10% 6% 8%

Missouri 2% 3% 4% 3% 3%

Montana 45% 48% 50% 47% 48%

Nebraska 8% 12% 15% 10% 11%

Nevada 15% 21% 25% 19% 20% New Hampshire 14% 26% 32% 22% 25%
New Jersey 2% 8% 16% 5% 7%

New Mexico 12% 19% 22% 17% 19%

# I NTERAGENCY 

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# D RAFT 

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# .

39 New York 22% 29% 36% 26% 28%

North Carolina 6% 10% 13% 8% 10%

North Dakota 21% 22% 22% 22% 22%

Ohio 2% 6% 11% 4% 5%

Oklahoma 12% 20% 21% 19% 21% Oregon 77% 83% 85% 82% 84% Pennsylvania 3% 10% 17% 6% 8%

Rhode Island 1% 4% 6% 3% 3%

South Carolina 4% 8% 11% 6% 8%

South Dakota 74% 65% 65% 65% 65%

Tennessee 12% 14% 16% 13% 14%

Texas 8% 16% 20% 13% 15%

Utah 5% 7% 9% 6% 7% Virginia 5% 14% 17% 10% 13% Washington 84% 88% 92% 87% 88% West Virginia 4% 10% 16% 7% 8%

Wisconsin 7% 11% 13% 10% 10% Wyoming 11% 17% 21% 14% 16%

Table 4-1.4. Proposed and Alternate State Target s for RE Generation in Megawatt-hours, with 2012

Historical RE Generation

State 2012 Proposed Targets Alternate Targets

Interim Level Final Level Interim Level Final Level

Alabama 10,211,777 16,082,501 21,728,024 13,444,441 15,045,855

Alaska 1,615,003 1,680,181 1,738,134 1,652,418 1,669,995

Arizona 8,414,586 9,564,693 10,380,259 9,146,529 9,442,167

Arkansas 3,858,842 5,568,725 6,907,295 4,902,027 5,351,981

California 56,804,216 67,582,957 67,988,075 67,177,840 67,988,075

Colorado 7,689,291 11,318,632 12,337,029 10,359,007 11,437,328

Connecticut 978,666 2,246,361 3,426,516 1,689,132 2,033,415

Delaware 131,051 561,909 1,038,351 349,356 468,394

# I NTERAGENCY 

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# .

40 Florida 4,674,309 14,121,648 22,260,125 9,941,239 12,550,400

Georgia 5,514,836 11,628,995 14,466,936 9,331,944 11,222,883

Hawaii 1,039,396 1,161,508 1,161,508 1,161,508 1,161,508

Idaho 13,454,907 14,136,011 14,137,092 14,134,931 14,137,092

Illinois 8,483,868 14,021,983 17,929,212 12,015,696 13,437,425

Indiana 3,979,872 6,325,625 7,980,591 5,475,832 6,078,027

Iowa 14,949,615 9,332,112 9,332,112 9,332,112 9,332,112

Kansas 5,263,052 8,587,881 8,895,337 8,280,425 8,895,337

Kentucky 2,694,661 3,398,499 4,075,338 3,082,224 3,274,216

Louisiana 3,109,986 5,612,493 7,571,563 4,636,744 5,295,277

Maine 7,831,400 7,344,333 7,344,333 7,344,333 7,344,333

Maryland 2,554,691 5,385,465 7,638,608 4,050,840 4,866,668

Massachusetts 2,755,901 6,261,986 9,525,959 4,720,848 5,673,037

Michigan 5,000,293 7,504,180 9,270,713 6,597,100 7,239,891

Minnesota 10,014,892 8,449,566 8,449,566 8,449,566 8,449,566

Mississippi 1,509,190 4,272,197 5,458,430 3,266,297 4,136,743

Missouri 2,012,848 2,871,796 3,477,797 2,560,626 2,781,132

Montana 12,545,217 13,400,015 14,006,171 13,089,222 13,308,950

Nebraska 2,603,816 3,990,738 5,076,481 3,449,966 3,814,933

Nevada 5,409,045 7,420,199 8,846,354 6,688,971 7,205,943
New Hampshire 2,670,671 5,016,689 6,111,609 4,143,018 4,856,499

New Jersey 1,291,470 5,502,109 10,158,221 3,424,893 4,588,218

New Mexico 2,796,670 4,384,643 4,944,815 3,906,387 4,354,610

New York 29,844,923 39,720,644 48,914,401 35,379,664 38,061,729

North Carolina 6,431,857 11,863,688 15,396,114 9,579,954 11,139,476

# I NTERAGENCY 

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# .

41 North Dakota 7,757,282 7,937,187 7,937,187 7,937,187 7,937,187

Ohio 2,152,783 7,868,896 14,189,755 5,048,991 6,628,251

Oklahoma 9,666,238 15,811,862 16,724,832 14,898,892 16,724,832

Oregon 46,617,408 50,821,930 51,977,551 49,724,805 50,979,909

Pennsylvania 6,701,038 21,361,397 37,572,775 14,129,067 18,179,463

Rhode Island 106,161 299,960 480,376 214,773 267,406

South Carolina 3,563,745 7,954,885 11,095,840 6,059,329 7,295,606

South Dakota 8,895,631 7,799,815 7,799,815 7,799,815 7,799,815

Tennessee 9,132,118 10,900,718 12,601,474 10,105,982 10,588,420

Texas 34,601,171 68,273,785 86,546,976 55,973,339 65,191,734

Utah 1,847,510 2,592,538 3,120,855 2,321,656 2,513,167

Virginia 3,402,218 9,652,582 12,235,782 7,330,929 9,473,199

Washington 97,678,705 103,243,669 107,189,913 101,220,323 102,650,811

West Virginia 2,728,003 6,990,747 11,704,476 4,887,826 6,065,547

Wisconsin 4,745,413 6,877,391 8,381,536 6,105,042 6,652,357

Wyoming 5,262,577 8,222,510 10,321,466 7,146,318 7,907,176

## Page 5: [1] Comment [A18] Author


# Reclamation does not agree w ith this statement. What does “significan tly increase” mean? How much generation is significant? The agency is currently installing optimization systems at existing, large facilities. Optimization systems will allow facilities to generate an additional 1-3% annually. Once all facilities are optimized, we expect to see an additional 410,000 MWh – 1,230,000 MW h annually. This is a significant increase.

Also – an additional generating unit is scheduled to be constructed at Black Canyon (an existing hydropower facility) to capture additional flows. I am not certain what the exp ected increase in annual generation is – but it could be “significant.”

Page 5: [2] Comment [A20] Author


# What is meant by this? Is future hydro implicitly included? It should be counted and encouraged.

Page 5: [3] Comment [A21] Author

EPA Response: As the text says, though not explicitly included in this target setting analysis, ne w hydro is not excluded for c ompliance with state targets.



## Page 5: [4] Comment [A26] Author


# EPA Response: Please see previous responses to commen t above that address the question of treatment of hydropower. EPA does not expect that the exclusion of some small new or existing hydropower would have a significant impact on the results, based on review of EIA historic and modeled data.

Page 5: [5] Comment [A25] Author


# Along with ineligible, “old” hydro – some RPS eligible hydr o (e.g. new, small, development) would certainly have been thrown out in this data set. Why throw out eligible hydro?

Page 5: [6] Comment [A28] Author


# EPA Response: Please see previous responses to comment above that address the question.

Page 5: [7] Comment [A30] Author


# Thank you for the comment. We have added a unit label in the title of the table.