# Clean Power Plan – A Producer Perspective EPA Workshop for Communities with Environmental Justice Concerns on the Proposed Rule to Reduce Carbon Pollution from Existing Power Plants 

# Exelon Corporation

Kathleen Robertson October 30, 2014

# Who is Exelon?

• Leading diversified energy company

– Focus is reliable, clean, and affordable energy • Headquartered in Chicago, Exelon operates in 48 states, the District of Columbia, and Canada.

– One of the nation’s cleanest and lowest
cost power generation fleets.

– Exelon’s utilities deliver electricity and natural gas to more than 7.8 million utility customers in central Maryland (BGE), northern Illinois (ComEd) and southeastern Pennsylvania (PECO).
• Exelon is a long
- time proponent of federal climate action.

1

# Exelon 2020 Initiative

• Exelon has been a low
- carbon company since its formation in October 2000 , and we take pride in maintaining one of the lowest owned
generation portfolio GHG emission rates of all of the large U.S. power producers.
• In 2008, we took early action under EPA’s voluntary Climate Leaders program by reducing GHG emissions by 36 percent from 2001 levels.
• After achieving our Climate Leaders goal in 2008 , we committed to Exelon 2020 . • This included operational reductions, customer - facing, and other energy efficiency programs.

• This year, we are proud to announce that we surpassed the Exelon 2020 goal — seven years ahead of schedule — with the abatement of more than 18 million metric tons of CO 2 e in 2013.

Clean Power Plan
– A Producer Perspective 2

# Exelon in the Communities

• In 2014, Exelon the Dow Jones Sustainability Indices (DJSI) and CDP recognized Exelon’s corporate sustainability performance and reporting of climate
- related information.

– DJSI named Exelon to the Dow Jones Sustainability North America Index for the ninth year in a row. Only five utility companies out of 600 North American companies were named.

– CDP also selected Exelon to the S&P 500 Climate Disclosure Leadership Index (CDLI ) for the fifth time.
• Contributed more than $32.3 million to local and national nonprofit organizations, for a total of $ 88.9 million over the past three years throughout our communities.
• Served 96,939 hours on 804 volunteer projects through Exelon employee volunteer efforts.

Clean Power Plan
– A Producer Perspective 3

# Reducing Compliance Costs and Ensuring Reliability

• To address reliability and affordability concerns for all customers, Exelon supports cost - effective implementation of the Clean Power Plan as soon as practicable.

– We support implementing the program no later than 2020, and will offer recommendations to encourage feasible actions prior to 2020.
• In addition, we will offer recommendations to ensure that clean baseload generation is encouraged to continue to operate for the benefit of our customers.

– As proposed, the rule would exacerbate economic pressures facing nuclear plants.

– If not addressed, challenged nuclear plants will retire, driving up both emissions and costs. • Generation would need to be replaced, and would almost certainly be replaced by natural gas generation, which emits both CO 2 and criteria pollutants such as NOx , a contributor to ozone and particulate pollution. • In addition, the loss of nuclear plants increases electricity rates, as evidenced by the upcoming closing of the Vermont Yankee nuclear plant (Forbes 9/29/14).

- National Grid expects a 37% rate increase for its customers in western Massachusetts on November 1.

- National Grid expects a 50 % increase in New Hampshire.

- Customers of the New Hampshire Electric Coop will face a 12% increase.

- Vermont ratepayers are protected this year based on the plant’s profit
- sharing, but rate increases are anticipated for next y ear. • EPA and MISO analyses indicate regional approaches save billions of dollars.

4Clean Power Plan
– A Producer Perspective 5 

# 32 days until December 1...