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-Chapter 4_05-23-14 revised for OMB.docx >> 
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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 (CO2) emissions from 

fossil fuel-fired electric generating units (EGUs) through 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 technologies 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 other resources regularly replenished by physical and 

biological cycles. To integrate the rapidly increasing and 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 taking into account renewable potential in particular 

regions of the country.

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

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

CO2 emissions 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 a technically viable and economically efficient approach for reducing CO2

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 extensively 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 addressed in TSDs on Survey of Existing State Actions, 

State Plan Considerations, Projecting EGU CO2 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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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 region is applied to individual states’ 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 annual 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 producing electricity from renewable resources, and some 

states have achieved significant levels of renewable 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 implemented 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 requirements established through Renewable Portfolio 

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

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

states as part of BSER, using the RPS-based targets as a reasonable benchmark of regionally costeffective RE generation which states could grow towards 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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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 approximately 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 increase 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, totaling 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-usual 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 CO2 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 compliance 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 Survey 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 conclusion. 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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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 from 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 specifically 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 generation6, we have used the most current state-level data on generation: 2012 net generation 

data by state. 7

Definitions of qualifying RE vary across state RPS 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 that 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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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 performance 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 this 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 include 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 explicitly 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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 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 Columbia9 - 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 generation, 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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 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 continually improving strategies for RE development are 

increasing the extent of economically utilized renewable 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 solar 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 generatinge 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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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/PVPS_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/docs/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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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 targets. 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 quantitative 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 the United States. DSIRE is 

currently operated by the N.C. Solar Center at N.C. State 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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information enabled the EPA to determine the effective 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 percentage 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 primary RPS requirements to simplify the analysis of 

primary and secondary RPS requirements in determining 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 Structure21

 

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

19 DSIRE. RPS Data Spreadsheet. April 2013 version. 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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The RPS compliance schedules in six states implement 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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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 their 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 resources. 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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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 increased 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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Table 4.3. List of States Included in Regions for Development of RE Best Practices Scenario24 

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, Louisiana, 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. 

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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 RPS requirements in Illinois (16%), Michigan (10%), 

Minnesota (30%), Missouri (10%), and Wisconsin (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 

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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 policy 

requirements 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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other states into these regions. As a conservative approach to estimating cost-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% 

Southeast 10% 

West 21% 

4.2.3 Determine start year for state efforts 

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

following the initial state plan submission deadline25, 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 generation 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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assumed to be equivalent to its 2012 observed performance 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 generation 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 regional 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 Central 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 growth factor based on the difference between both each states’ 

individual historical 2005 2002 and 2012 RE generation. 

 

Table 4.5. Regional Annual 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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Then, for all states in a given region, that region’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 calculation 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 growth 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 percentage (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 generation 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 within the relevant state. However, the EPA notes that 

state-level RPS policies are often established with the 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 satisfying 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. Beyond 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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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 and 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 MeGigawatt-hours) 

State Historic 

RE Best Practice RE Generation Levels Targets (thousand MGWh) 

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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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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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 Generation 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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 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 Historical 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. 

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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. 
INTERAGENCY WORKING COMMENTS ON DRAFT LANGUAGE UNDER EO12866

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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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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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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 GoalTargets 

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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 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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 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 generating 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 purchase 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 levelized 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 Solar 2012: An Empirical Analysis of Project Cost, 

Performance, and Pricing Trends in the United States. Lawrence Berkeley National Laboratory. LBNL-6408E. 

September 2013. p. 19. 

30 Bolinger, Mark, and Samantha Weaver. Utility-Scale Solar 2012: An Empirical Analysis of Project Cost, 

Performance, and Pricing Trends in the United States. 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 integration 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 report 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 needs 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. Beyond 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 Efficiency Alliance, December 2010. See also Brown, Marilyn 

A., Etan Gumerman, Xiaojing Sun, Kenneth Sercy, and 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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or utility-level RPS cost impact analyses" found the median change in retail electricity price to be $0.0004 

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

$0.82, and the median CO2 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 CO2 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 relatively 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, fFive 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 this proposal, it is reasonable to view the incremental 

cost associated with the CO2 emission reductions available from completion of these units as zero for 

purposes of setting states’ CO2 reduction goals. Completion of these units therefore represents a highly 

cost-effective opportunity to reduce CO2 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 Berkeley National Laboratory, March 2007, available at 

http://emp.lbl.gov/publications/weighing-costs-and-benefits-state-renewables-portfolio-standards-comparativeanalysis-s. 

40 Galen Barbose, “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.

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. Reflecting 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 projected 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 generating 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 percent 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 shortfall 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 CO2/MWh or from the projected average 2020 emissions intensity across 

the U.S. power system at 1,127 lbs CO2/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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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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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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Appendix 4-1. RE Generation Targets Including Existing 

Table 4-1.1. State Best Practice RE Generation Levels including 2012 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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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%

Formatted Table
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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%
INTERAGENCY WORKING COMMENTS ON DRAFT LANGUAGE UNDER EO12866

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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%
INTERAGENCY WORKING COMMENTS ON DRAFT LANGUAGE UNDER EO12866

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 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 Targets 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 
INTERAGENCY WORKING COMMENTS ON DRAFT LANGUAGE UNDER EO12866

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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 
INTERAGENCY WORKING COMMENTS ON DRAFT LANGUAGE UNDER EO12866

INTERAGENCY REVIEW. SUBJECT TO FURTHER POLICY REVIEW.

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 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. 

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 expected 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, new hydro is not excluded for compliance with state 

targets. 

Page 5: [4] Comment [A26] Author 

EPA Response: Please see previous responses to comment 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 hydro (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.