Technical Report

NREL/TP-6A2-45877

May 2009

Comparative Analysis of Three 

Proposed Federal Renewable 

Electricity Standards 

Patrick Sullivan, Jeffrey Logan, Lori Bird, and 

Walter Short
National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 • www.nrel.gov

NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Operated by the Alliance for Sustainable Energy, LLC

Contract No. DE-AC36-08-GO28308

Technical Report

NREL/TP-6A2-45877

May 2009

Comparative Analysis of Three 

Proposed Federal Renewable 

Electricity Standards 

Patrick Sullivan, Jeffrey Logan, Lori Bird, and 

Walter Short

Prepared under Task No. SAO7.9C50
NOTICE

This report was prepared as an account of work sponsored by an agency of the United States government. 

Neither the United States government nor any agency thereof, nor any of their employees, makes any 

warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or 

usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not 

infringe privately owned rights. Reference herein to any specific commercial product, process, or service by 

trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, 

recommendation, or favoring by the United States government or any agency thereof. The views and 

opinions of authors expressed herein do not necessarily state or reflect those of the United States 

government or any agency thereof.

Available electronically at http://www.osti.gov/bridge

Available for a processing fee to U.S. Department of Energy

and its contractors, in paper, from:

U.S. Department of Energy

Office of Scientific and Technical Information

P.O. Box 62

Oak Ridge, TN 37831-0062

phone: 865.576.8401

fax: 865.576.5728

email: mailto:reports@adonis.osti.gov

Available for sale to the public, in paper, from:

U.S. Department of Commerce

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

phone: 800.553.6847

fax: 703.605.6900

email: orders@ntis.fedworld.gov

online ordering: http://www.ntis.gov/ordering.htm

Printed on paper containing at least 50% wastepaper, including 20% postconsumer waste
iii

Acknowledgments

This work was funded by the U.S. Department of Energy’s (DOE’s) Office of Energy 

Efficiency and Renewable Energy (EERE). The authors would like to thank Doug Arent, 

Monisha Shah, and Ted James of the National Renewable Energy Laboratory (NREL) for 

their guidance and input. We also thank Ryan Wiser of the Lawrence Berkeley National 

Laboratory for providing helpful feedback. Special appreciation goes to Jeff Deyette of the 

Union of Concerned Scientists, Eliot Metzger of the World Resources Institute, and John 

Wilson of the Southern Alliance for Clean Energy for their reviews and input on revisions to 

the model. The authors also offer their thanks to Michelle Kubik in the NREL Technical 

Communications Office for providing editorial support. Any remaining errors or omissions 

are, of course, the responsibility of the authors. 
iv

Executive Summary

This paper analyzes potential impacts of proposed national renewable electricity standard 

(RES) legislation. An RES is a mandate requiring certain electricity retailers to provide a 

minimum share of their electricity sales from qualifying renewable power generation. 

The analysis focuses on draft bills introduced individually by Senator Jeff Bingaman and 

Representative Edward Markey, and jointly by representatives Henry Waxman and 

Markey.1 

We used NREL’s Regional Energy Deployment System (ReEDS) model to evaluate the 

impacts of the proposed RES requirements on the U.S. energy sector in four scenarios: 

• A base case where only currently enacted legislation is simulated

• A 20% by 2021 RES target, with 25% of the RES assumed to be met with 

qualifying energy efficiency projects (hereafter referred to as “Bingaman”) 

• A 25% by 2025 RES target, with no energy efficiency substitutions allowed 

(Markey)

• A 25% by 2025 RES target, with 20% of the RES assumed to be met by 

efficiency, and a cumulative 15% reduction in load by 2020 (Waxman). 

The fourth scenario considers the RES and the associated energy efficiency resource 

standard (EERS) independently of all other energy or climate measures in the Waxman 

discussion draft. No carbon policies are considered. 

The Bingaman RES proposal analyzed here exempts small electricity providers and 

allows up to 25% of the RES targets to be met through qualifying energy efficiency 

projects annually. The Markey legislation exempts a smaller group of utilities from 

meeting the RES and does not allow the substitution of energy efficiency for renewable 

energy. The Waxman discussion draft calls for a 25% renewable target by 2025, with the 

same exemptions regarding utility size as in the Markey bill; however, Waxman allows 

states to reduce the annual RES targets by up to 20% if the state has met the EERS. The 

EERS is a separate, but linked, requirement in the bill, and mandates cumulative national 

electricity savings of 15% by 2020. 

Existing hydropower and municipal solid-waste generation resources do not qualify as 

eligible forms of renewable energy under any of the proposed RES bills, but are deducted 

from retail electricity providers’ retail sales to calculate their renewable energy 

compliance obligations. In each of the proposed bills, the RES would allow affected 

electricity providers to use any combination of the following to achieve their target: 1) 

generate their own renewable energy, 2) purchase renewable energy certificates (RECs), 

or 3) pay an “alternative compliance payment,” which serves as an effective safety-valve 

on the price of RECs. In each bill, distributed generators (such as rooftop photovoltaic 

(PV) systems) would earn triple credits for every kilowatt hour produced. 

 

1 This analysis updates an earlier, preliminary NREL investigation into the proposed Bingaman legislation 

that did not include changes mandated by the American Recovery and Reinvestment Act of 2009. In 

particular, it considers an extension of production tax credit through December 31, 2012. Available at 

http://www.nrel.gov/docs/fy09osti/45161.pdf. 
v

Each bill also aims to prevent preemption of, or interference with, existing state RES 

mandates that meet or exceed the federal requirement. Our analysis indicates that the 

current versions of the Markey and Waxman legislation may address REC market design 

issues more clearly than the Bingaman draft. Details are found in Section 5. 

Findings are summarized in Table ES1: 

Table ES1. Comparative Findings of the Proposed RES Legislation

Peak

Effective 

RES (%)

Qualifying Renewable 

Generation in 2030 

(TWh)

Qualifying Renewable 

Capacity in 2030 

(GW)

CO2 Emissions 

Reductions in 2030

(million metric tons)

Base 

Case NA 699 208 NA

Bingaman 12.1 638 197 95

Markey 21.8 867 261 150

Waxman 17.4 573 183 435

• Effective RES. The Bingaman legislation has a nominal RES requirement of 20% in 

2021, but the effective renewable energy requirement is only 12.1% of total U.S.

retail sales in that year. This conclusion is reached after considering the small-utility 

exemption and assuming that 25% of the target is met by fully using the energy 

efficiency compliance option. Hydropower and municipal solid waste generation, 

which are not counted toward the generation on which the RES is calculated, are 

subtracted later. For the Markey and Waxman bills, the effective renewable 

requirements are about 22% and 17%, respectively, of total retail sales in 2025.

• Resulting RE Increment Required. The base case scenario estimates that qualifying 

renewable generators will provide 10.4% of the national load in 2020 and 12.4% in 

2024 (the model tracks only even-numbered years), due to a combination of existing 

state RES mandates, other existing incentives, and the forecasted, least-cost 

economics of electricity generation. The proposed Bingaman legislation would 

ostensibly require about an additional 2% of total load to be met with qualifying 

renewables by 2021 beyond the assumed base case. However, the triple credits 

granted to generation from distributed PV satisfy the Bingaman RES requirements 

with less than 10% of total generation coming from qualified renewable sources. 

Thus, this analysis indicates a slight reduction in energy generated from renewables 

in the Bingaman case compared to the base case; this is due to the triple credits 

applied to distributed PV and the reduction in load due to energy efficiency options.2

The Markey legislation would require about 10% more load to be met by generation 

from qualifying renewables beyond the base case scenario by 2025, while the 

Waxman bill would require renewable sources to meet an additional 5% of total load. 

• Impact on Capacity. Qualifying renewable energy capacity reaches approximately 

208 gigawatts (GW) in 2030 in the base case. In comparison, the Bingaman, Markey, 

and Waxman cases result in 197, 261, and 183 GW of renewables in 2030, 

 

2 If a system is required to have 12% renewable generation but grants triple credits to distributed PV, that 

system could, for instance, meet the requirement with only 10% renewable generation if 1% of generation 

is from distributed PV. The 9% from central renewable plus 3 times 1% from distributed equals 12%.
vi

respectively. Renewable capacity in the Bingaman scenario is less than that in the 

base case for two reasons. First, the assumption about energy efficiency in this 

scenario reduces electricity demand significantly, and thus the need for renewable 

contributions. Second, this analysis used an external forecast of PV deployment from 

a 2009 study by the Union of Concerned Scientists. The exogenously calculated PV 

penetration in all three RES scenarios is higher than in the base case, and thus further 

reduces the need for other renewable options to contribute. These reasons also apply 

to the Waxman scenario, which forecasts renewable capacity very close to that in the 

Bingaman case. 

• Impact on Emissions. The Bingaman RES results in a modest 95 million metric ton 

(MMT) annual reduction in carbon dioxide (CO2) emissions in 2030 compared to the 

base case. Most of this reduction is due to efficiency savings rather than expanded use 

of renewable energy. The Markey RES saves an estimated 150 MMT per year in 

2030, exclusively from expanded renewable energy use. The Waxman scenario 

reduces annual carbon dioxide emissions in 2030 by 435 MMT, most of which is due 

to the assumed 15% reduction in power demand compared to the baseline. 

• Importance of Transmission. All results noted here assume that transmission 

capacity is built as required for both transporting electricity and maintaining system 

reliability. Results would differ if construction of transmission is delayed. 

• Regional Results. Western states, endowed with wind and solar resources, exceed 

their RES requirements based on renewable energy deliveries; states in the Southeast 

generally rely on biomass co-firing and purchasing RECs. 

• Impact on Prices. None of the RES bills modeled have a significant impact on 

consumer electricity prices at the national level. Differences between average national 

electricity prices in the RES cases and the base case are less than1%, according to the 

assumptions used in the modeling. The prices calculated in the Waxman scenario are 

significantly less than the base case, although our analysis did not consider the costs 

involved in implementing the EERS. In the Markey scenario, more states see a 

decline in calculated electricity prices than an increase, and no state sees an increase 

of more than 5% compared to the base case in 2022, the year of peak impact on 

prices. Estimated national REC prices peak in 2022 in the Waxman RES case at just 

less than $25/MWh, while they reach about $15/MWh in the Markey case.
vii

Table of Contents

Acknowledgments.............................................................................................................. iii

Executive Summary ........................................................................................................... iv

Table of Contents .............................................................................................................. vii

List of Figures ................................................................................................................... vii

List of Tables .................................................................................................................... vii

1. Background ..................................................................................................................... 1

2. Methodology and Assumptions ...................................................................................... 2

3. Impacts ............................................................................................................................ 6

4. Potential Follow-on Work ............................................................................................. 15

5. REC Market Design Issues in the Proposed RES Legislation ...................................... 16

Appendix A – Attributes of Modeling Renewable Electricity: ReEDS vs. NEMS .......... 20

Appendix B – State-Level 2030 Renewable Generation Totals from Markey Scenario 

(TWh) ................................................................................................................................ 21

List of Figures

Figure 1. Levelized cost of electricity inputs used in ReEDS ............................................ 5

Figure 2. Electricity-generating capacity by technology in the base case .......................... 7

Figure 3. Electricity generation by technology in the base case ......................................... 7

Figure 4. Generating capacity and electricity generation in 2030 in each of the scenarios 8

Figure 5. Cumulative and annual installations of wind power ......................................... 10

Figure 6. Annual and cumulative changes in CO2 emissions among the scenarios ......... 11

Figure 7. Preliminary assessment of RES on average national electricity prices ............. 12

Figure 8. Impact of Markey scenario on state electricity prices in 2022 .......................... 13

Figure 9. Simulated national price of renewable energy credits ....................................... 13

List of Tables

Table 1. Main Provisions of the Three RES Bills ............................................................... 2

Table 2. PV Deployment Forecast in the RES Scenarios (GW) ......................................... 4

Table 3. Comparative Requirements of the Proposed RES Legislation ............................. 6

Table 4. 2030 Capacity (GW) by Technology .................................................................... 9

Table 5. Key Differences in REC Market Issues in the Three Proposed RES Bills ......... 16
1

1. Background

A renewable electricity standard (RES)—also referred to as a renewable portfolio 

standard (RPS)—requires certain electricity retailers to provide a minimum specified 

share of their total electricity sales from qualifying renewable power generation.

3 RES 

policies can incorporate market-based mechanisms that enable obligated entities to buy or 

sell tradable renewable energy certificates (RECs) to demonstrate compliance. Many 

economists contend that the flexibility introduced in market-based trading systems lowers 

the overall cost in meeting the goal of expanded renewable energy use. 

At the beginning of 2009, 28 states had RES mandates and an additional five had goals 

for renewable energy deployment.4 The U.S. Congress has considered a national RES 

since the 105th session (1997-1999): the Senate has passed legislation three times, and the 

House once. To date, however, both houses have not acted in unison to pass legislation.5

While many in Congress support a national RES because of its perceived benefits for 

resource diversity, price stability, and environmental quality, others are concerned that it 

could lead to higher consumer costs and differentiated regional impacts.

In late January 2009, Senator Jeff Bingaman released a draft discussion document 

proposing a 20% RES by 2021.6 The following week, Representative Edward Markey 

sponsored RES legislation in the House,7

 calling for 25% renewable electricity by 2025. 

On the same day, he released separate legislation designed to provide cumulative national 

electricity savings of 15% by 2020.8 One week later, Senator Tom Udall of New Mexico 

sponsored legislation with targets similar to the Markey RES bill; that legislation is not 

analyzed in this paper.9 Finally, in late March, representatives Waxman and Markey 

released the American Clean Energy and Security Act discussion draft, which included a 

modified version of the Markey RES, a utility energy efficiency resource standard 

(EERS), a cap-and-trade title, and other clean energy provisions.10

 

3 For more background on existing state RES policies in the United States, see R. Wiser and G. Barbose, 

“Renewable Portfolio Standards in the United States: A Status Report with Data Through 2007,” Lawrence 

Berkeley National Laboratory, April 2008; and D. Hurlbut, “State Clean Energy Practices: Renewable 

Portfolio Standards,” National Renewable Energy Laboratory, July 2008.

4 The District of Columbia also has a mandated RES. The classification of state RES programs into 

mandatory or voluntary groupings can be debated. A map summarizing state RES mandatory and voluntary 

programs is available on the DSIRE Web site at http://www.dsireusa.org. 5 For a history of RES legislation in the House and Senate, see F. Sissine, “Renewable Energy Portfolio 

Standard (RES): Background and Debate over a National Standard,” Congressional Research Service, 

December 5, 2007.

6 At the time of this writing, Senator Bingaman’s discussion draft had not been given a bill number. 7 H.R. 890, the American Renewable Energy Act.

8 H.R. 889, the Save America Energy Act.

9 The Udall bill (S. 433) offers voluntary exemptions to municipal, cooperative, state, and federal utilities, 

and could thus result in lower deployment of renewable energy than the Markey legislation despite many 

other similarities.

10 More information on the discussion draft is available on the House Web site at 

http://energycommerce.house.gov/index.php?option=com_content&task=view&id=1560&Itemid=1
2

This analysis considers the three proposed RES bills compared to a base case scenario. It 

does not simulate the impact of the cap-and-trade provision in the Waxman proposal in 

combination with the RES. 

Table 1 summarizes the main provisions of the three RES bills analyzed. Section 5

highlights other important differences among the REC trading markets established by the 

bills.

Table 1. Main Provisions of the Three RES Bills

Issue Bingaman Markey Waxman

RES Target 4% by 2011, 20% by 2021 

(through 2039)

6% by 2012, 25% by 

2025 (through 2040)

Same as Markey

Covered Entities All suppliers selling more than 

4 million MWh (except in 

Hawaii)

All suppliers selling more 

than 1 million MWh

Same as Markey

“Existing” vs.

“New” Renewables

RECs for existing renewables 

(before 1/1/2006) cannot be 

traded 

No distinction No distinction

Energy Efficiency 

Allowed?

Yes – EE can be used to meet 

up to 25% of target each year

No – Markey proposes an 

independent EERS in a 

separate bill (H.R. 889)

Yes – States may 

petition to reduce 

annual obligation by up 

to 20% if utilities 

comply with separate 

EERS 

Credit Multipliers Two federal RECs/kWh for 

projects on tribal lands; three 

RECs/kWh for distributed 

generation (at “customer site,” 

1MW limit)

Three federal RECs/kWh 

from distributed 

generation sources (noncombustion projects “at or 

near” customer site, up to 

2 MW)

Same as Markey

2. Methodology and Assumptions 

The Regional Energy Deployment System (ReEDS) model, the capacity expansion and 

dispatch tool used for this analysis, was created to compare national electricity policy 

scenarios; it also has built-in capabilities for modeling an RES policy. An overview of 

ReEDS is provided in the text box on the following page.11 

To appropriately model the proposed RES scenarios in ReEDS, the following 

assumptions were made. First, the target RES—which reaches 20% from 2021 to 2039 in 

the Bingaman bill and 25% from 2025 to 2039 in the Markey and Waxman bills—was 

prorated to 17%, 22%, and 22%, respectively, because small electric suppliers are 

exempted from the proposed requirements. 

 

11 A more detailed summary of the ReEDS methodology is found in Appendix A of the earlier NREL report 

on the proposed Bingaman RES, available at http://www.nrel.gov/docs/fy09osti/45161.pdf. Appendix A of 

this report compares and contrasts ReEDS with the U.S. Department of Energy’s Energy Information 

Administration’s (EIA) NEMS model.
3

Overview of the ReEDS Model

NREL developed the Regional Energy Deployment System (ReEDS) model to analyze energy and 

climate policy options in the U.S. electricity sector. ReEDS is a linear programming model that simulates 

the least-cost expansion of electricity generation capacity and transmission, with detailed treatment of 

renewable electric options. ReEDS minimizes the system-wide cost of meeting forecasted electric loads, 

reserve requirements, and emission constraints by building and operating new generators and 

transmission in 22 two-year increments from 2006 to 2050. 

ReEDS is unique in its ability to simulate access to and cost of transmission, access to and quality of 

renewable resources, the variability of wind and solar power, and the impact of variability on the 

reliability of the grid. ReEDS addresses these issues through a highly discretized regional structure (356 

resource areas), explicit accounting for the variability in wind and solar output over time, and 

consideration of ancillary services requirements and costs.

ReEDS simulates “feedback” effects in the electricity market resulting from changes in demand, 

including how greater or lesser use of renewables might impact the price of fossil fuels used in power 

generation.

Second, in the Bingaman scenario, all balancing areas were assumed to use their full 

efficiency allowance (25% of the RES), because efficiency measures are usually more 

cost-effective than adding renewable power supply.12 In Waxman, the analysis assumes 

that all obligated entities meet the EERS, and that states petition to have the RES targets 

reduced by 20%. These efficiency substitutions further reduced the effective RES to 

about 12% of total U.S. retail sales in Bingaman from 2021 to 2039, and 17% in Waxman 

from 2025 to 2040. The effective RES is the minimum amount of renewable power that 

would be required; in reality, not all states would necessarily use the entire efficiency 

allowance or allow their excess RECs used for meeting state RES obligations to count 

toward the federal obligation. The efficiency assumptions in both cases simplify what the 

legislation actually proposes and serve to identify one outer range where all efficiency 

substitutions are fully used.

13 

 Technologies that contribute to the RES include wind, concentrated solar power (CSP), 

geothermal, biopower,14 and distributed photovoltaics (PV). As designated in the 

proposed legislation, existing hydropower and municipal solid waste are not counted, 

although both are subtracted from the generation on which the RES target is applied (the 

denominator). Also similar to the proposed legislation, distributed renewable energy 

systems are permitted to claim triple credits toward the RES (i.e., 1 kWh from a rooftop 

PV system counts as 3 kWh for RES accounting purposes). PV is the only eligible 

distributed renewable technology considered in this analysis. 

 

12 This simplification was assumed because ReEDS does not explicitly represent efficiency savings. 13 In a recent report, the EIA analyzed the impacts of the Waxman bill by assuming full use of the 

efficiency substitution in one scenario and no use of the substitution in another. That study is available at 

http://www.eia.doe.gov/oiaf/servicerpt/acesa/index.html. Demand growth projections in ReEDS are taken 

from the EIA’s Annual Energy Outlook 2009 (AEO 2009) projections. 14 This includes both dedicated biomass generation and biomass co-firing at coal plants.
4

Because ReEDS cannot analyze distributed technologies with the same rigor as it does 

utility installations, the expansion of distributed PV in the scenarios is guided by an 

exogenous projection at the North American Electric Reliability Corporation (NERC) 

region/subregion level. Table 2 shows these estimates, which come from a recent study 

by the Union of Concerned Scientists (UCS).15 There are three separate deployment 

forecasts: one for the base case, one for Bingaman, and one for Markey and Waxman. 

With recent and projected reductions in the price of photovoltaics, these market 

penetration estimates are particularly uncertain.

Table 2. PV Deployment Forecast in the RES Scenarios (GW)

2010 2020 2030 2040 2050

Base 2.5 18 25 36 52

Bingaman 2.5 21 31 45 65

Markey and Waxman 2.5 19 39 57 83

This analysis applies the selected RES to the nation as a whole, and assumes that states, 

regions, or individual utilities purchase RECs to meet local shortfalls. If the entire 

country falls short of the RES, the analysis assesses an alternative compliance payment 

(see Section 5). The RES constraint, being only a national one, carries an implicit 

assumption that the REC market is frictionless—i.e., there is no transaction cost in the 

exchange of RECs. Thus, if it is cheaper for a region to purchase RECs through the 

market rather than build its own renewable generators or contract for renewable energy, it 

will do so. 

There are other assumptions that are not specific to this analysis but can significantly 

affect the results and are, therefore, worth mentioning. 

• Technology cost and performance parameters and projections are from Black and 

Veatch as estimated for the 20% Wind Energy by 203016

• Fuel cost projections are from the Energy Information Administration (EIA) 

Annual Energy Outlook (AEO) 2009 reference case. The price of natural gas, in 

particular, can have a large impact on both investment and dispatch decisions in 

the model. 

study (see Figure 1). 

• Wind and other qualifying renewable electricity generators receive a production 

tax credit (PTC) of 2.1 cents per kilowatt hour (in 2008$) through 2012; 

qualifying non-wind renewables receive the credit through 2013. 

• CSP and distributed PV receive an investment tax credit (ITC) of 30% through 

2016, after which it drops to 10%. 

• Nuclear capital costs have been multiplied by 1.5 from the Black and Veatch 

projections (i.e., from roughly $3,000/kW to $4,500/kW) to better represent 

recently publicized cost-estimate increases and the current social political climate 

of uncertainty toward the technology. 

 

15 Union of Concerned Scientists, “Clean Energy, Green Jobs,” March 23, 2009. The UCS analysis used a 

modified version of the EIA’s National Energy Modeling System (NEMS). 

http://www.ucsusa.org/clean_energy/solutions/renewable_energy_solutions/clean-energy-green-jobs.html 16 U.S. Department of Energy, 20% Wind Energy by 2030: Increasing Wind Energy’s Contribution to U.S. 

Electricity Supply, July 2008. http://www1.eere.energy.gov/windandhydro/pdfs/41869.pdf
5

Figure 1. Levelized cost of electricity inputs used in ReEDS

• Load growth rates are defined by NERC region/subregion from the EIA AEO

2009 reference case, and seasonal and diurnal load curves are from Platts, an 

energy information service. 

• There is no price, cap, or tax of any kind on CO2 or other greenhouse gases; sulfur 

dioxide (SO2) is subject to the Clean Air Interstate Rule caps.

• All existing state-level RES targets with enforceable penalties are met in the 

baseline case. Most state RES programs ramp up renewable requirements through 

2020 or 2025 before leveling off.17

• The analysis explicitly accounts for the cost of new transmission for all power 

generation options by determining when new transmission lines are needed and 

including the cost of building them. 

 

• Other assumptions are outlined in the 20% Wind Energy by 2030 study.

Although the above inputs and assumptions have been vetted, some aspects of the future 

most likely will differ from the projections made in the model. In particular, political 

momentum to restrict carbon dioxide emissions will likely result in relatively higher costs 

for carbon-intensive generation sources that are not currently reflected in any of the 

scenarios. Additionally, recent changes in commodity pricing and other factors have led 

to changes in capital costs for most power generation technologies that differ from those 

established by Black and Veatch, and the current financial crisis has short-term 

implications for the cost of financing. Because this analysis focuses out to 2030, we have 

not accounted for these short-term perturbations. 

 

17 See the DSIRE database for information on specific state RES mandates (www.dsireusa.org).
6

This analysis is based on optimizing least-cost expansion of the U.S. electricity sector. To 

be more specific, the result of a ReEDS scenario is the distribution of capacity expansion 

and dispatch that satisfies all of the required constraints (i.e., the system must reliably 

meet all load requirements and contingencies while satisfying emission laws, renewable 

standards, or other policy requirements) with the lowest cost for the overall system. 

Furthermore, as the model optimizes for least cost over the electric sector, these results 

are in no way indicative of the potential future make-up of the electric sector including 

factors such as job creation, economic development, or water availability and use. 

Despite the limitations outlined here, ReEDS provides a useful picture of how the 

electricity sector might develop during the next several decades under various policy 

scenarios.

3. Impacts

We simulated four scenarios in this analysis: a business-as-usual case, a Bingaman RES 

case, a Markey RES case, and a Waxman RES case. The scenarios will be referred to 

here as “base,” “Bingaman,” “Markey,” and “Waxman.” 

Table 3 shows the parameters that drive the base case and scenarios. In some instances, 

the figures in the “actual renewable generation” column are lower than the “required 

renewable generation” column because distributed renewable generation gets triple 

compliance credit. In the Waxman scenario, for example, there are 57 terawatt hours 

(TWh) of distributed PV generation in 2030, so tripling this value would increase actual 

renewable generation from 573 TWh to 687 TWh, thus satisfying the RES requirement. 

Additionally, the entries in the “eligible load” column include feedback effects of 

electricity prices on demand. The eligible load in the Markey case, for example, is higher 

than the base case because lower electricity prices in that scenario during the 2020 decade 

induce slightly higher electricity demand. 

Table 3. Comparative Requirements of the Proposed RES Legislation

2030 Eligible 

Load (TWh)18

Effective 

RES (%)

Required Renewable 

Generation in 2030 (TWh)

Actual 2030

Renewable Generation 

(TWh)

Base 4505 0 0 699

Bingaman 4314 12.1 520 638

Markey 4510 21.8 981 867

Waxman 3784 17.4 658 573

Figure 2 illustrates the generating capacity of each technology in the base case. The 

least-cost framework projects an increase in new coal plant construction beginning in 

2025 (no carbon constraint assumed), a gradual retirement of nuclear units, and rapid 

expansion of on-shore wind power plants and gas-fired combustion turbines. 

 

18 Hydropower is subtracted from these data, but power from small generators is not. The “Effective RES” 

column is reduced to account for the small-utility exemption.
7

Figure 2. Electricity-generating capacity by technology in the base case

Figure 3 shows the amount of generation that each of the technologies provides through 

2050. New coal plants provide most of the new generation, with wind and other 

renewable sources accounting for marginal additions as well. 

Figure 3. Electricity generation by technology in the base case

Figure 4 illustrates the least-cost installed generating capacity and electricity generation 

in 2030, according to technology type in each of the scenarios. Hydroelectric and nuclear 

capacities are unchanged between the base case and other scenarios—hydroelectric, 
8

because new capacity is not considered; nuclear because, with the higher costs, new 

capacity was not sufficiently attractive.

Figure 4. Generating capacity and electricity generation in 2030 in each of the scenarios

The Markey RES: The Markey RES is the most straightforward of the scenarios because 

it has no efficiency component. In that scenario, the additional renewable generation 

largely displaces coal while natural gas capacity and generation remain fairly constant 
9

from the base case. All renewable technologies increase over the base case—most 

notably wind with its additional 25 GW of capacity by 2030. Table 4 summarizes the 

capacity figures in the base case and RES cases. 

Table 4. 2030 Capacity (GW) by Technology

Base Bingaman Markey Waxman

Gas 379 352 378 274

Coal 370 359 350 326

 Biomass co-fire-ready coal* 27 25 48 42

Nuclear 96 96 96 96

Hydropower 76 76 76 76

Wind 153 139 178 120

CSP 21 18 30 13

Distributed PV 25 31 39 39

Geothermal 3 3 5 3

Biopower 2 2 2 2

 Qualifying Renewable Total 208 197 261 183

 

 * Biomass co-fire-ready coal capacity is included in the total coal capacity. Only 15% of 

this capacity is included in the qualifying renewable total row. 

The Bingaman RES: The Bingaman RES—with an efficiency allowance that reduces 

overall electricity demand and a less-aggressive standard than the other bills—has a 

different effect on the generation mix than the Markey RES. Due to the reduced load, 

renewable capacity and generation both decline compared to the base case. The various 

exemptions and reductions applied to the original 20% target allow the RES requirement 

to be met in 2022 with only 10.3% of non-hydropower generation derived from 

renewable sources.19

The Waxman RES: Adding an assumed 15% demand-reduction requirement alongside 

the Waxman RES results in the most aggressive displacements of coal and gas 

generation. Consequently, there are large reductions in CO2 emissions. On the other hand, 

because the RES is now acting on a smaller amount of total generation, it is smaller in

terms of megawatt hours. Therefore, there is less renewable capacity in the Waxman case 

than in the Markey or base cases. The steep decline in CSP capacity may be attributed to 

the fact that both distributed PV and CSP provide most of their output during the 

afternoon time-slice. There is a considerable amount of PV serving this time-slice based 

on the exogenously determined levels of distributed PV.

 As a result, wind and CSP capacity are, in fact, lower in 2030 in the 

Bingaman case than in the base case. Similarly, both coal and gas see mild reductions in 

the Bingaman case.

 

19 20% is reduced to ~17% through the small-utility exemption. The efficiency component reduces that by a 

further 25%, to 11.7%. Distributed PV supplies 0.77% of eligible load, for which it gets triple credit, an 

effective 2.3%. The 9.7% from central renewables plus 2.3% from distributed PV exceeds the required 

11.7%.
10

Wind Capacity: Wind capacity expansion projections for the four scenarios are shown in 

Figure 5. The rapid expansion through 2012 is a direct result of the PTC, recently 

extended through that year; and the abrupt drop-off in 2014 is due to the expiration of 

that credit. Post PTC, the base, Bingaman, and Waxman RES cases allow slow wind 

growth until the mid 2020s when wind becomes economically competitive again—this 

time without the national PTC incentive. 

Figure 5. Cumulative and annual installations of wind power

In the Bingaman case, wind builds in the 2020s are not being driven by the RES, but by 

favorable economics: Renewable generation exceeds the RES after 2024. Under the 

Markey case, the renewable standard becomes binding again in 2018, encouraging wind 

project construction to resume earlier than in the base case. Once the RES is fully

implemented, in 2026, wind installations drop again. In the later years of the model 

simulation, the base, Bingaman, and Waxman cases build more new wind than the 

Markey case—likely because, in the latter, those attractive sites that would have been 
11

economically viable in the 2040s were built in the 2020s to meet the RES instead. Thus, 

the gaps in total wind installations among the various scenarios shrink after 2030. 

Carbon Dioxide Emissions: As shown in Figure 6, carbon dioxide (CO2) emissions 

under the Bingaman RES decline by about 95 million metric tons (out of nearly 3,000 

MMT) annually in 2030, compared to the base case. The Markey RES case results in 

slightly higher annual reductions in 2030, roughly 150 MMT. The Waxman scenario 

estimates annual CO2 reductions in 2030 of approximately 435 MMT; much of this 

reduction is due to the assumption that national electricity demand is 15% lower than in 

the base case because of the EERS. Cumulative CO2 emission reductions are shown in 

the bottom graph of Figure 6. The difference in cumulative CO2 emissions between the 

Waxman and base scenarios in 2030 is more than 5,000 MMT. 

Figure 6. Annual and cumulative changes in CO2 emissions among the scenarios 

Price Impacts: The impact of the scenarios on average national electricity prices is 

shown in Figure 7. Differences among the base case and the Bingaman or Markey 

scenarios are very small (less than 1%). This is expected for the Bingaman RES because 
12

it is a small departure from the base case. For the Markey RES, however, there is 

substantial additional renewable capacity signifying increased capital costs for the overall 

system. Offsetting the capital increases are decreases in operational costs as the lowmarginal-cost renewable technologies displace coal, which results in fuel cost savings. 

Figure 7. Preliminary assessment of RES on average national electricity prices

The analysis explicitly accounts for demand elasticity, and the reduction in coal demand 

means a reduction in coal prices, compounding the savings. To account for efficiency 

savings, we made the simplifying assumption that investments to improve energy 

efficiency and lower electricity demand did not affect the price of electricity. Thus, the 

Waxman case, with its 15% reduction in total load, has a noticeably lower electricity 

price, reaching about 5% below the other scenarios in the mid-2020s. In this scenario, 

less new capacity needs to be built and operated to supply the load; but, again, we did not 

consider any costs for the energy efficiency measures required to achieve the electricity 

savings. 

The analysis also considers the impact of the proposed RES legislation on state-level 

electricity prices. Figure 8 shows that in the Markey scenario in 2022, more states see a 

reduction in calculated electricity prices than an increase compared to the base case. This 

scenario is chosen in isolation from the others because it has the greatest impact on 

renewable energy, and thus represents the largest price impacts. No state sees an increase 

in calculated electricity prices of greater than 5% in 2022, the year of peak increase in 

new renewable demand in that scenario. States that see the largest increases in calculated 

prices are generally those that have electricity prices significantly below the national 

average. It is important to note that data in this figure represent a snapshot at one point in 

time. Additionally, the model may skew results in states where a large portion of 

electricity is traded across borders, such as in the Pacific Northwest. 
13

Impact on Calculated State Electricity Prices in 2022 under the Markey Scenario

0

2

4

6

8

10

12

14

16

18

more than -3% between -3% and 0% between 0% and+3% between 3 and 5% more than 5%

Change in Calculated State Electricity Prices in 2022 in the Markey Scenario 

(Compared to the base case)

Number of States

Figure 8. Impact of Markey scenario on state electricity prices in 2022

Figure 9 shows an estimated price of federal RECs during each time period. The model 

derives the estimate by tracking the marginal cost of generating the last unit of qualifying 

renewable power when the RES target is met. All REC prices are zero before 2016 and 

after 2032. The analysis does not consider transaction costs, which results in assumed

“frictionless” trading of RECs among utilities. Based on these assumptions, REC prices 

are forecasted to peak in 2022 in the Waxman case at just less than $25/MWh, or 2.5 

cents/kWh; and in the Markey case, at $15/MWh, or about 1.5 cents/kWh. In the 

Bingaman case, REC prices remain at zero through the analysis because the legislation 

would not require any new renewable sources, based on the assumptions used. Realworld conditions would likely result in higher REC prices. Note that REC prices in all 

years are lower than the alternative compliance payment, reinforcing the assertion that 

the ACP option is never taken in these scenarios.

Figure 9. Simulated national price of renewable energy credits 
14

Geographical Differences: Data in Appendix B summarize the calculated impacts, at 

the state level, of the Markey RES legislation. We present the Markey results here 

because that legislation mandates greater use of renewables than any of the other bills. 

The table shows the amount of renewable energy generation that comes from wind, solar, 

biomass, and geothermal. 

In summary, the western half of the country provides more than its share of renewable 

electricity, and is positioned to sell RECs to other states that opt not to meet the RES with 

their own generation. Obligated electricity suppliers that meet less than their RES 

requirements need to either purchase RECs from utilities in other states or pay an 

alternative compliance payment. In general, our modeling results indicate that it is more 

cost-effective for many of the southeastern states, in particular, to purchase low-cost 

RECs on the national market than to construct their own renewable energy generation 

sources. All states in the Southeast use biopower to some extent, either through co-firing 

at coal plants or dedicated biomass plants. Other studies suggest that this region has more 

cost-effective renewable resources than traditionally acknowledged.20

This analysis simulates the least-cost construction of new electricity transmission lines as 

needed during the capacity build-outs. This build-out allows transfer of electricity 

(notably, variable generation from renewables) to other regions of the country, although 

energy transfers would not necessarily occur directly between the West and Southeast. 

Rather, utilities in the Southeast would likely purchase only the RECs from projects in 

the West and other regions. 

 

Based on data in Appendix B, Texas, California, Indiana, and Michigan each construct 

more than 10 GW of wind capacity in the Markey RES case, while New York, 

Pennsylvania, Nebraska, New Hampshire, Iowa, the Dakotas, Oklahoma, Idaho, New 

Mexico, Oregon, and Washington are projected to see rapid expansion as well. 

Finally, Appendix B also illustrates calculated solar power (PV and concentrating solar 

power) generation in the Markey case. Again, ReEDS did not calculate PV deployment 

endogenously in these scenarios, but instead used the UCS forecast at the NERC 

region/subregion level. Because California is one of the NERC regions/subregions for 

which external estimates of distributed PV were available, its large deployment of 

distributed PV was entirely exogenously specified. For other states such as Texas, 

Nevada, North Carolina, and New Jersey, ReEDS allocated a significant portion of the 

distributed PV from their NERC region/subregion to them because of the favorable 

distributed-PV economics in those states relative to other states in the same NERC 

regions/subregions. 

Modeling Conclusions: In summary, the Bingaman RES case has only a minor impact 

on the national electricity sector because it requires no increase in renewable generation 

 

20 See, for example, “Local Clean Power,” World Resources Institute, April 2009; or “Yes We Can: 

Southern Solutions for a National Renewable Energy Standard,” presentation from Southern Alliance for 

Clean Energy, February 12, 2009, at 

http://www.cleanenergy.org/images/files/SERenewables022309rev.pdf. 
15

over the base case in 2021, according to the assumptions used. The Markey RES 

legislation requires significantly greater renewable power deployment and the 

construction of new transmission infrastructure in a timely manner. The Waxman RES 

lies between the two, encouraging a significantly higher proportion of renewable energy 

than Bingaman, but less in absolute terms than Markey; this is due to the assumption that 

energy efficiency would play a more prominent role. The state and regional impacts will 

depend, to a significant extent, on whether this new transmission capacity can be 

deployed without delay. Although the assumptions used in this analysis show that it is, on 

balance, usually less costly for the southeastern region to purchase RECs than to build 

their own generation, some states in and near the region do have significant renewable 

supply to contribute, at least in the Markey scenario. Texas develops both wind and solar; 

Florida, solar; North Carolina, solar; many states, biopower. 

4. Potential Follow-on Work

Potential follow-on work for this analysis could include:

• Conducting sensitivity analysis on the RES legislation. Key sensitivities that could 

be considered include different energy efficiency allowance penetrations, gas price 

trajectories, power plant costs, RE technology improvements over time, and policy 

assumptions on PTC extensions and/or carbon caps/taxes. Additionally, it might be 

useful to explore the extent to which excess federal RECs, accrued as a result of state 

RES compliance, are retired rather than sold. 

• Comparing past and ongoing work. Several other organizations—including the 

Union of Concerned Scientists, the Energy Information Administration, and 

Lawrence Berkeley National Laboratory—have published findings from similar RES 

analyses. Follow-on work could include more comprehensive comparisons of these 

findings with those from other organizations. 

• Analyzing proposed RES legislation in combination with other climate and 

energy policies. In addition to the RES proposed in the Waxman discussion draft, the 

bill also includes a national cap-and-trade system to mitigate greenhouse gases as 

well as many other energy measures. Follow-on analysis will evaluate the combined 

impacts of the RES and cap-and-trade policies on the electricity sector. NREL’s 

methodological framework offers advantages by simulating renewable electric 

technologies at a level of detail not yet available in other models. However, it is 

important to note that the NREL model is not economy-wide, nor does it handle 

feedback effects in as detailed a manner as some general equilibrium models. This 

type of analysis could still provide useful insights into how the electricity sector is 

impacted by overlapping energy and climate policies. 
16

5. REC Market Design Issues in the Proposed Legislation 

This section compares the REC market design and implementation features of the 

Bingaman, Markey, and Waxman bills. Based on our analysis, both the Waxman and 

Markey bills are clearer than the Bingaman discussion draft21 on the issue of REC market 

design and state RES interactions and, thus, may be easier to implement. However, all of 

the bills raise some questions regarding the issuance and treatment of RECs and the 

interaction with existing state RES policies. Table 5 summarizes key differences in 

policy design and REC market issues in the bills. 

Table 5. Key Differences in REC Market Issues in the Three Proposed RES Bills

Issue Bingaman Markey Waxman

Definition of a 

federal REC

Not defined Federal REC “means a credit, 

representing one kWh of 

renewable electricity”

Federal REC “means a credit, 

representing one MWh of 

renewable electricity” with 

unique serial number

REC Tracking 

Systems 

Calls for federal “trading” 

systems; silent on use of 

existing tracking systems 

“Rely upon” existing state/regional 

REC tracking systems

“Rely upon” existing 

state/regional REC tracking 

systems

REC Market 

Administrator

“An appropriate marketmaking entity”Authority can be delegated by DOE 

to existing “market-making 

entities... for purposes of creating 

a transparent and efficient national 

market”; FERC given oversight

Not addressed

Issuance of 

Federal RECs 

Issued to generators. Issued 

to utilities if complied with 

state RES, or paid state 

ACP, or other fees. For 

existing power contracts, 

retail electric provider gets 

credit. Language unclear. 

Issued to generators. Exceptions 

for states with central RES 

procurement and, in some cases, 

for state ACP payments. For 

existing power contracts with retail 

electricity provider, provider gets 

credit.

Issued to generators. Exceptions 

for states with central RES 

procurement and, in some 

cases, for state ACP payments. 

For existing power contracts with 

retail electricity provider, provider 

gets credit.

Banking Allowed 3 Years 3 years 3 years 

Provisions for 

“Excess” Federal 

RECs (if state 

target is higher)

Silent on issue (or covered 

by general state saving 

clause)

States have authority to determine 

whether excess state RECs can be 

used for federal compliance in 

other states

States have authority to 

determine whether excess state 

RECs can be used for federal 

compliance in other states

Voluntary Green 

Power

Not specifically addressed Not specifically addressed Not specifically addressed

Alternative 

Compliance 

Payment (ACP)

3¢/kwh (inflation adjusted) Lesser of: 5¢/kwh (inflation 

adjusted) or 200% of prior year 

average market value of federal 

RECs

Lesser of: 5¢/kwh (inflation 

adjusted) or 200% of average 

market value of federal RECs for 

previous compliance period

Use of ACP 

Revenues 

Allocated to state energy 

offices with preference to 

states with small share of 

economic RE capacity

Returned proportionately to all 

utilities that met federal 

requirement 

Returned proportionately to all 

utilities that met federal 

requirement 

State/federal 

penalties

Federal penalties reduced 

by state penalties paid if 

state RES is higher 

Federal penalties not reduced by 

state penalties

Federal penalties not reduced by 

state penalties

Contributions from Ed Holt & Associates 

 

21 Issues related to the Bingaman RES policy design and REC market were discussed in an earlier NREL report, 

“Evaluating a Proposed 20% National Renewable Portfolio Standard,” http://www.nrel.gov/docs/fy09osti/45161.pdf
17

Dual RECs System: All three proposed bills create a dual RECs system, with federal 

RECs separate from state renewable electricity standard RECs. While this method may 

be required, based on other elements of the legislation, it may also create tracking 

problems and confusion over appropriate claims, because there could be two RECs 

(federal and state) issued for a single megawatt hour of renewable generation. Because 

state RECs generally specify that they contain renewable energy attributes and establish a 

basis for claiming renewable energy, the federal REC cannot also contain these attributes.

To accommodate the presence of both federal RECs and state RECs, the federal REC 

would need to be defined in a way to avoid confusion (e.g., for federal RES compliance 

purposes only). Another option for addressing potential confusion with state REC 

programs is to adopt a single RECs system, or require that federal RECs travel with and 

remain bundled with any available state RECs; however, this approach is not used in any 

of the three bills. 

State RES Interaction: All of the bills call for preserving the integrity of existing state 

RES standards, although the Markey and Waxman bills contain more specific language to 

that effect. One key issue is whether state RES standards can be more stringent than the 

federal standard. For example, utilities in states with higher RES targets than the federal 

target in a given year may be allowed to sell “excess” RECs to utilities in other states for 

federal compliance. If this is allowed, state targets would not necessarily be more 

stringent than the federal RES. Both the Markey and Waxman bills include language that 

gives states the authority to decide how to address this issue. The Bingaman bill is less 

clear and includes only a generic state savings clause that does not directly address the 

issue. Other approaches that could be used to address this issue (but not included in any 

of the bills) would be to either: 1) directly ensure that utilities are not able to trade federal 

RECs that are used to meet a higher state RES standard, or 2) adjust the utility’s federal 

requirement to be the greater of the state requirement, or the level required under federal 

law. 

Similarly, small utilities that are exempted from the federal RES—but that are subject to 

state RES policies—could also sell RECs they use for state compliance to entities in other 

states for federal compliance, unless precluded from doing so at the state level. Again, 

this would mean that state standards would not, absent state policy precluding the sale of 

excess federal RES, be additional to the federal standard. 

Distributed Generation and Tribal Credit Multipliers: All three bills call for the 

issuance of three federal renewable energy credits (RECs) for each kilowatt hour of 

renewable electricity generated by distributed generation facilities. Bingaman also calls 

for the issuance of two federal renewable energy credits (RECs) for each kilowatt hour of 

renewable electricity generated on tribal lands. It would be preferable to issue a single 

REC for each megawatt hour of generation from these applications, and provide “triple 

federal compliance credit” for distributed generation sources, and double federal 

compliance credit for projects on tribal lands. It would create confusion in the 

marketplace and tracking difficulties to issue multiple RECs for the same megawatt hour 

of generation. For this reason, states that have developed credit multipliers have not 
18

actually provided multiple RECs for each MWh of generation; instead, each such REC 

that is retired is deemed to count toward a utility’s RES obligation based on the multiplier 

value. 

Definition of REC: The Waxman bill defines a federal renewable electricity credit as a 

credit that represents 1 MWh of renewable electricity; Markey defines a REC as 1 kWh 

of renewable electricity. The Bingaman bill does not explicitly define a REC, but 

describes it in kilowatt hours throughout the text. REC tracking systems and state RES 

policies define RECs as 1 MWh of renewable electricity, rather than 1 kWh. For 

consistency, it would be preferable to use the same units currently used by states and 

tracking systems. As discussed above, under a dual state-federal RECs system, it is also 

important that the renewable and environmental "attributes" travel with the state REC—

the federal REC should only be a compliance demonstration tool. 

Nontradability of RECs from Existing Renewable Generation: The Bingaman bill 

establishes nontradable RECs for existing generation that would likely pose 

implementation challenges. This provision is not included in either the Markey or 

Waxman bills. The nontradability of RECs from existing generators could pose problems 

because generators that came online prior to 2006 may have already traded their state 

RECs (and potentially any future federal RECs) in transactions conducted for state RES 

compliance. Under the draft legislation, these purchases (because they are traded) may 

not count toward the federal RES. In addition, defining “nontradability” may be difficult 

given that RECs can be combined with electricity, and sold in various ways. Furthermore, 

the provision requires complicated regulatory processes to define incremental generation 

from existing renewable generation. 

Alternative Compliance Payments: The Bingaman bill calls for an alternative 

compliance payment of 3 cents/kWh. The Waxman and Markey bills call for the ACP to 

be the lesser of 5 cents/kWh or 200% of the average market value of federal RECs from 

the previous compliance period (Waxman) or prior year (Markey). By including the 

provision that the ACP may be based on prior market value, it would create some 

uncertainty in the market and would be more difficult to implement than simply having a 

fixed ACP payment. 

All of the bills call for the federal government to issue federal RECs to retail electric 

suppliers making alternative compliance payments under certain defined circumstances. 

Because payments to state ACPs do not directly and immediately get translated to 

renewable megawatt hours, allocating federal RECs in this instance to the utility making 

the ACP payment will be a challenge. Additionally, by giving the federal REC to the 

utility, the generator is left with a state REC that does not include the federal REC. The 

generator, however, may already have sold its state REC to another party under a longterm contract. In states requiring that state RES policies be met by retiring both the state 

and federal REC, this generator will no longer be selling a state-qualifying REC. This 

issue could be addressed if federal RECs were only issued on the basis of eligible 

renewable generation and not ACP payments. 
19

Interaction with State Penalties: The Bingaman bill calls for state “penalties” to be 

deducted from the federal penalty, in cases where a utility is in noncompliance of both a 

state and federal RES, and the state RES requirement is “greater than” the federal RES. 

This provision is not included in the Markey or Waxman bills. This may be difficult to 

implement in practice because state and federal RES policies differ in many ways, not 

just the percentage obligation—it is not immediately clear on what basis “greater than” 

will be determined. In addition, states have developed a wide range of financial 

compliance mechanisms, not all of which may be classified as penalties per se. 

Double-Counting: The double-counting language in all of the bills addresses only 

double-counting of the same megawatt hour for federal compliance. The potential gaming 

between federal RES compliance and voluntary sales is not directly addressed. This is 

potentially harmful to consumers who expect voluntary REC purchases to represent use 

of renewable power beyond what would have occurred without the voluntary purchase. 

Renewable Electricity Deployment Fund Allocation: The Markey and Waxman bills 

call for distributing all federal ACPs and penalties to utilities in proportion to the share of 

federal RECs that those utilities have procured. The intent of this is likely to be rewarding 

those utilities that have complied with the federal RES, but it may not directly advance 

renewable energy project deployment. In contrast, the Bingaman bill calls for these funds 

to be directed to state energy offices to be used to support additional renewable energy 

development, with preference given to states with a small proportion of cost-effective 

renewables. 
20 

Appendix A – Attributes of Modeling Renewable Electricity: ReEDS vs. NEMS

(Most important differences are in bold.)

Attribute Details ReEDS: Electric-Sector ONLY (Capacity 

Expansion Model)

NEMS: ALL Energy Sectors (Energy-Economic 

Model – EMM )

Costs dominated by 

capital costs

Finance, depreciation, materials costs, 

learning/decreasing costs

ReEDS base case capital costs are intended to 

represent “mainstream” industry expectations 

(largely from Black and Veatch)

EIA staff draws on various sources of expert opinion 

to select capital cost assumptions

Operating costs are 

fixed and small

Risks, variability Does not address risk Does not address risk

Modular plant size Reduces over/under capacity problems 

and transmission requirements

Assumes all plants (including conventionals) can 

be built in a modular fashion

Assumes all plants (including conventionals) can be 

built in a modular fashion

Environmental 

impacts are generally 

minimal

Air emissions, life-cycle analysis of 

materials 

Includes air emissions Includes air emissions

Resource sites vary in 

quality

Resource level, time of availability, 

access to infrastructure, terrain

Models resource site-quality issues at relatively 

fine geographic resolution (more than 350 

regions); models use of existing grid and new 

transmission construction necessary to 

obtain resource

Applies long-term multipliers, based in part on 

geospatial analysis of access to infrastructure and, 

in part, on expert judgment. Geographic resolution at 

NEMS region level (13). Due to coarse geographic 

resolution, only four new transmission lines are 

considered, and their use is limited to new 

generators

Conversion to usable 

energy must occur 

near resource site

Transmission, siting High spatial resolution enables relatively 

detailed modeling of transmission and siting 

(see above)

Transmission cost is represented by a regional

adder to the cost of every KWh (e.g., wind 

transmission cost is same as gas-fired power 

transmission cost with the exception noted 

immediately above)

Resource variability Backup requirements, ancillary service 

requirements, curtailments, forecasting, 

diversity

Represents variability and diversity through 

stochastic treatment of capacity value, 

operating reserve requirements, and 

curtailments.

Represents variability in resource and has some 

decrease in capacity value as a function of amount 

of wind installed, but not as a function of diversity

Distributed capability -

solar, biomass, wind

Competition at the retail level, 

interaction with owner’s loads

Can allocate exogenous estimates of distributed 

PV at the 13 NERC region/subregion level to 

ReEDS 134 balancing areas based on 

distributed PV economics and resource 

Represents load at the 13 region levels of the EMM 

and distributed PV.

Immature industry Comfort/experience of investors, 

uncertainty in future cost and 

performance, supply/demand 

imbalances

Includes learning.

Includes growth penalties (rapid growth causes 

price increases)

Includes learning.

Includes growth penalties.
21 

Appendix B – State-Level 2030 Renewable Generation Totals from Markey 

Scenario (TWh)

Wind Solar Bio Geo Wind Solar Bio Geo

Alabama 0.0 0.0 1.4 0.0 Nebraska 10.6 0.4 0.2 0.0

Arizona 13.8 2.0 0.0 0.0 Nevada 15.0 7.7 0.0 2.0

Arkansas 0.4 0.0 0.7 0.0 New Hampshire 2.6 0.8 0.6 0.0

California 78.1 112.2 3.8 39.6 New Jersey 22.4 5.2 0.6 0.0

Colorado 9.9 0.3 0.1 0.0 New Mexico 16.0 1.3 0.1 0.0

Connecticut 7.0 0.8 0.8 0.0 New York 7.0 3.1 0.2 0.0

Delaware 1.3 0.3 0.0 0.0 North Carolina 10.8 7.0 7.0 0.0

Florida 2.9 3.2 11.0 0.0 North Dakota 6.4 0.0 0.6 0.0

Georgia 2.1 0.0 1.6 0.0 Ohio 18.1 0.5 1.3 0.0

Idaho 9.2 0.0 0.1 0.0 Oklahoma 20.5 0.0 1.5 0.0

Illinois 19.4 1.4 0.7 0.0 Oregon 21.7 0.0 0.3 0.0

Indiana 18.1 1.7 0.6 0.0 Pennsylvania 30.4 0.0 1.1 0.0

Iowa 15.5 0.2 0.3 0.0 Rhode Island 2.2 0.0 0.0 0.0

Kansas 12.2 1.0 1.3 0.0 South Carolina 0.4 1.5 2.2 0.0

Kentucky 1.7 0.9 0.8 0.0 South Dakota 4.8 0.0 0.2 0.0

Louisiana 3.9 2.8 0.7 0.0 Tennessee 1.0 0.0 1.5 0.0

Maine 4.1 0.0 1.4 0.0 Texas 56.6 13.9 4.6 0.0

Maryland 9.0 0.0 0.3 0.0 Utah 11.9 0.3 0.0 0.5

Massachusetts 6.4 0.0 1.6 0.0 Vermont 2.1 0.1 0.4 0.0

Michigan 27.0 0.0 0.9 0.0 Virginia 2.5 1.7 1.4 0.0

Minnesota 35.6 0.3 0.6 0.0 Washington 14.5 2.0 1.1 0.0

Mississippi 0.0 0.0 1.2 0.0 West Virginia 1.6 0.0 0.4 0.0

Missouri 13.4 0.0 0.8 0.0 Wisconsin 12.8 0.0 0.9 0.0

Montana 6.3 0.4 0.0 0.0 Wyoming 5.2 0.0 0.0 0.0

United States 594.1 173.3 57.0 42.2
F1147-E(10/2008) 

REPORT DOCUMENTATION PAGE Form Approved

OMB No. 0704-0188

The public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, 

gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this 

collection of information, including suggestions for reducing the burden, to Department of Defense, Executive Services and Communications Directorate (0704-0188). Respondents 

should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a 

currently valid OMB control number.

PLEASE DO NOT RETURN YOUR FORM TO THE ABOVE ORGANIZATION.

1. REPORT DATE (DD-MM-YYYY)

May 2009

2. REPORT TYPE

Technical Report

3. DATES COVERED (From - To)

 

4. TITLE AND SUBTITLE

Comparative Analysis of Three Proposed Federal Renewable 

Electricity Standards

5a. CONTRACT NUMBER

DE-AC36-08-GO28308

5b. GRANT NUMBER

5c. PROGRAM ELEMENT NUMBER

6. AUTHOR(S)

P. Sullivan, J. Logan, L. Bird, and W. Short

5d. PROJECT NUMBER

NREL/TP-6A2-45877

5e. TASK NUMBER

SAO7.9C50

5f. WORK UNIT NUMBER

7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES)

National Renewable Energy Laboratory

1617 Cole Blvd.

Golden, CO 80401-3393

8. PERFORMING ORGANIZATION

REPORT NUMBER

NREL/TP-6A2-45877

9. SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES) 10. SPONSOR/MONITOR'S ACRONYM(S)

NREL

11. SPONSORING/MONITORING

AGENCY REPORT NUMBER

12. DISTRIBUTION AVAILABILITY STATEMENT

National Technical Information Service

U.S. Department of Commerce

5285 Port Royal Road

Springfield, VA 22161

13. SUPPLEMENTARY NOTES

14. ABSTRACT (Maximum 200 Words)

This paper analyzes potential impacts of proposed national renewable electricity standard (RES) legislation. An RES is a 

mandate requiring certain electricity retailers to provide a minimum share of their electricity sales from qualifying 

renewable power generation. The analysis focuses on draft bills introduced individually by Senator Jeff Bingaman and 

Representative Edward Markey, and jointly by Representative Henry Waxman and Markey. The analysis uses NREL’s 

Regional Energy Deployment System (ReEDS) model to evaluate the impacts of the proposed RES requirements on the 

U.S. energy sector in four scenarios.

15. SUBJECT TERMS

NREL; renewable portfolio standard; RPS; Regional Energy Deployment System model; ReEDS; renewable energy 

certificates; RECs; generation capacity; National Energy Modeling System; NEMS; renewable electricity standard; 

RES

16. SECURITY CLASSIFICATION OF: 17. LIMITATION 

OF ABSTRACT

UL

18. NUMBER 

OF PAGES

19a. NAME OF RESPONSIBLE PERSON

a. REPORT

Unclassified

b. ABSTRACT

Unclassified

c. THIS PAGE

Unclassified 19b. TELEPHONE NUMBER (Include area code)

Standard Form 298 (Rev. 8/98)

Prescribed by ANSI Std. Z39.18