12-15-14 Georgia EPD_R1

1

Proposed Method for Projecting Generation for 111(d) 

Mass-based Goal Translation

Georgia EPD

December 15, 2014

(revision 1)
12-15-14 Georgia EPD_R1

2

Mass-based goal:

Mass goal = (emiss. rate based on emissions and generation from EGUs + affected nuclear + RE + EE)

x (generation from EGUs + affected nuclear + RE + EE)

Generation for mass-based goal:

• Should be identical to generation used to compute rate-based goal if the two forms of the performance

goal are to be considered equivalent (translation from one form to the other)

• Follows from first bullet that generation used to develop the two forms of the performance goal must be

based on same assumptions (projection data and percent that each BSER block comprises of the goal year

generation portfolio)

• Generation projection should be based on nationally recognized demand projection data (EIA’s Annual

Energy Outlook)
12-15-14 Georgia EPD_R1

3

BACKGROUND - EMISSIONS AND GENERATION FROM GOAL COMPUTATION TSD

2030 Emissions*

Emissions Source Cell Reference Emissions (lbs CO2)

Coal-fired, after HRI

and NGCC redispatch

M12 x L12 58,646,790,741

NGCC, after redispatch O12 x C12 42,213,046,893

Other P12 68,345,447

Total 101,928,183,081

2030 Generation*

Generation Source 2030 Generation (MWh)

Coal-fired 27,190,604

NGCC 51,372,609

Other 83,815

Additive to fossil gen.

__Existing and UC nuclear 19,220,561

__RE 12,230,636

__EE (avoided gen) 12,149,397

Total 122,247,623

*Source: Clean Power Plan file “20140602tsd-goal-data-computation-1.xls”

Rate-based goal = 101,928,183,081/122,247,623

 = 834 lbs CO2/MWh

50,964,092 tons CO2
12-15-14 Georgia EPD_R1

4

PROPOSED METHOD TO PROJECT 2030 GENERATION (AEO SERC GROWTH RATIO)

• Annual Energy Outlook 2014, Electricity and Renewable Fuel Tables, Table 86 (SERC generation, not sales)

• SERC data includes 111(d) affected and non-affected generation (hydro, existing nuclear)

• Calculate SERC demand growth ratio 2012 to 2030

• Georgia 2012 generation (affected and non-affected) from EIA 2012 profile*

• Total GA 2030 generation = (Georgia 2012 generation) x (SERC growth ratio)

• Affected GA 2030 generation = Total GA 2030 generation – 2012 hydro* – 0.942 x existing nuclear**

*EIA Georgia Electricity Profile 2012, Release date May 1, 2014, Table 5.

** Goal Computation TSD
12-15-14 Georgia EPD_R1

5

PROPOSED METHOD (continued)

SERC Demand Growth Ratio, 2012 to 2030

Generation end use 2012

generation

(106 MWh)

2030

generation

(106 MWh)

regional customers* 242.4 314.3

interregional exports* 24.9 31.8

international exports* 0.0 0.0

Total 267.3 346.1

* AEO 2014, Electricity and Renewable Fuel Tables, Table 86, “Net Energy for Load” data

Demand growth ratio = 346.1/267.3 = 1.2948 

Avg. annual growth rate = 1.0144, or 1.44 %.
12-15-14 Georgia EPD_R1

6

PROPOSED METHOD (continued)

Georgia Electricity Profile, 2012

• Total generation = 122,300,000 MWh

• Hydro = 2,236,300 MWh

Total Electric 

Industry*

122,306,364

Coal 40,715,049

Hydroelectric 2,236,300

Natural Gas 42,538,601

Nuclear 33,941,634

Other 56,055

Other 

Biomass

168,122

Petroleum 378,072

Pumped 

Storage

-837,884

Solar 2,921

Wood 3,107,494

*Excerpt from EIA Georgia Electricity Profile 2012, Release

date May 1, 2014, Table 5.

2012 Non-affected Nuclear (per 111(d) Goal Computation TSD)

• existing nuclear = 4042 MW x 8760 hrs x 0.9 cap factor = 31,867,000 MWh

• 2012 nonaffected nuclear (not "at risk") = existing nuclear x .942 = 30,019,000

MWh
12-15-14 Georgia EPD_R1

7

PROPOSED METHOD (continued)

Georgia Total Projected 2030 Generation

• Total 2012 generation x SERC growth ratio = 122,300,000 x 1.2948 =

158,354,000 MWh

Projected 2030 Affected Entity Generation, AEO 2014 Basis With SERC Generation

Growth Rate

• Total projected 2030 generation - 2012 hydro - 2012 nonaffected nuclear

• 158,354,000 - 2,236,000 - 30,019,000 = 126,099,000 MWh

• Emissions at 834 lb/MWh = 52,583,000 tons
12-15-14 Georgia EPD_R1

8

Comparisons of 2030 Mass-based Goal Computations to 2005 and 2012 Actual Emissions

Method

Number

2030 affected entity

generation (MWh) and basis

2030 CO2

emissions goal

(short tons)*

Reduction from 

94,101,000 tons

(2005 actual CO2

emissions)

Reduction from

62,850,000 tons

(2012 actual CO2

emissions)

1 122,216,047

Goal Comp. TSD

50,964,092 46 % 19 %

2 126,099,000

AEO 2014 projection, SERC

generation growth

52,583,000 44 % 16 %

3 83,753,806

Goal Translation TSD – Tables

1 & 4 (existing affected)

34,843,000 63 % 45 %

4 112,094,059

Goal Translation TSD – Tables

3 & 5 (existing and new fossil)

46,600,000 50 % 26 %

* assuming rate-based goal of 834 lbs CO2/MWh
12-15-14 Georgia EPD_R1

9

Comparisons of 2030 Generation for Four Southeastern States, by Computation Method

Method

Number

Generation

Computation Basis

GA 2030 * 

generation

(MWh) SERC-SE

SC 2030 *

generation

(MWh) SERC-VACA

AL 2030 ** 

generation

(MWh) SERC-SE

NC 2030

generation

(MWh) SERC-VACA

1 Goal Comp. TSD 122,216,047 77,921,758 124,946,589 103,184,884

2 AEO 2014 projection,

SERC generation

growth 2012 - 30

126,099,000 78,669,000 152,583,414 113,661,047

3 Goal Translation TSD –

Table 1 (existing

affected, no growth)

83,753,806 45,181,812 104,643,354 82,030,617

4 Goal Translation TSD –

Table 3 (existing and

new fossil, SERC sales

growth 2012 - 29)

112,094,059 62,886,514 123,268,725 100,354,356

* states with under construction nuclear programs

** IPP/CHP natural gas generation is significant fraction
12-15-14 Georgia EPD_R1

10

Issue with Goals Based on Projections - Deviation Of Actual Goal Year Generation From State Plan Projected

Generation (see GA EPD comment document, Attachment A, for more detail)

• Example: actual 2030 generation << projected 2030 generation, performance could meet mass-based goal

but effective emissions rate performance could be higher than rate-based goal which is “equivalent” to

state plan mass-based goal

 

• Mechanism needed to adjust state plan mass-based goals up or down with near-term generation

projections or with actual generation

• Possible solutions: (a) Use AEO to “correct” mass goal 3 – 4 years ahead of goal year (b) Generation range

bins, each with an associated mass-based goal 
12-15-14 Georgia EPD_R1

11

Summary - Projecting Generation for 111(d) Mass-based Goal Translation

• Georgia EPD believes that projection of generation for the mass-based goal based on AEO generation

projection data for a FERC region (Method 2) is a viable and reasonable basis for computation of a massbased goal

 

• Existing affected generation method (Method 3) illustrated in EPA’s goal translation TSD results in CO2

emissions reductions from Georgia’s 2005 baseline that are more than double the expected nationwide

reduction level of 30%

• “Mass-equivalent generation” determined by methods illustrated in Goal Translation TSD (Methods 3 and

4) appears to be significantly low for states with under-construction nuclear and perhaps other selected

states

• The quantified nationwide CO2 reduction should be the same for the two forms of the performance goal

• Generation used to develop the two forms of the performance goal must be based on the same

assumptions (projection data and percent that each BSER block comprises of the goal year generation

portfolio) if the two forms of the goal are to be considered equivalent

• Generation projection should be based on nationally recognized demand projection data (EIA’s Annual

Energy Outlook)

• Calculation and setting of a mass-based goal should address deviation of actual goal year generation from

state plan projected generation