## From: Szabo, Aaron <Aaron_L_Szabo@omb.eop.gov> Sent: Wednesday, July 29, 2015 3:12 PM To: Vasu, Amy; Culligan, Kevin; Harvey, Reid Cc: Frey, Nathan J.; Grossman, Andrea Subject: Summary of Interagency Comments Under EO 12866 and 13563 -- Clean Power Plan Documents

Attached please find a summary of interagency comments under EO 12866 and 13563 on related documents to support EPA’s draft final rule entitled “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units.” The summary of interagency comments are on the following related documents: 1. Summary of Interagency Comments on the GHG Mitigation TSD; 2. Summary of Interagency Comments on the New Source Complements TSD; 3. Summary of Interagency Comments on the Resource Adequacy TSD; 4. Summary of Interagency Comments on the CPP Regulatory Impact Analysis. Thank you and please let me know if you have any questions.
Aaron L. Szabo Policy Analyst Office of Management and Budget 202-395-3621 Aaron_L_Szabo@omb.eop.gov

<< Summary of Interagency Comments under EO12866_EO13563_CPP_GHGMitigationT....docx >> << Summary of Interagency Comments under EO12866_EO13563_CPP_NewSourceCompl....docx >> << Summary of Interagency Comments EO 12866_EO13563_Resource Adequacy TSD.DOCX >> << Summary of Interagency Commen ts under EO12866_EO13563_CPP_RIA.DOCX >>

# Summary	of	Interagency	Working	Com ments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

GHG Mitigation TSD for EPA’s Clean Power Plan

BB2 Section (Chapter 3):

1. Page 3-2, sentence stating “Other generating technologies, like rene wables, hydroelectric, and nuclear, have little or no variable costs and are generally dispatched to the extent possible.” Reviewer recomme nds clarifying including nuclear within the discussion as there are current economic concerns for merchant nuclear. Reviewer recommends providing a footnote discussing interim capital costs for upgrades and maintenance that can impact dispatch cost. 2. Page 3-15. Reviewer recommends changing th e sentence to state “According to EIA, natural gas prove n reserves have doubled between 2000 and 2012.”

# Summary	of	Interagency	Working	Com ments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

EPA’s New Source Complements to Mass Goals TSD for CPP Final Rule

1. Excel Spreadsheet, New Source Complements Tab. Reviewer notes that the increase in the “Affected EGU and RE Generation Growth Inco rporated in Mass Goal Calculation (GWh)” (found in columns AB-AJ) from 2027 to 2028 is equivalent to the increase from 2022 to 2026. Reviewer recommends clarifying the reason for this yearly increase. 2. Page 2. Reviewer recommends m odifying the sentence to state:
a. Convert state-level incremental generation to state-level incremental emissions by assuming the New Source Performance Standard emission rate for NGCC of 1,030 lbs/MWh- net

. 3. Page 4. Reviewer recommends additional clar ification to confirm that the 55% to 75% NGCC ratio relates to understand the con cept of assigning some portion of an underconstruction EGU generation to past closings or need short-falls, a nd not the assumed BB2 baseline and ramp-up potential applicable to under construction NGCC units. Is this coincidental? 4. Page 8. Reviewer recommends adding a foot note in the sentence, “Each state-level new source complement generation level is multip lied by the NSPS NGCC emission rate standard of 1,030 lbs/MWh to produce a mass value” to stat e that the same mathematical concept can be applied partially or in full to future new coal units with CCS.
a. Reviewer recommends: “This concept and the ma thematical procedures can be modified in state plans to account for new 111(b) comp liant fossil steam generation EGUs not yet planned, should these be constructed, in combination with the 111(b) compliant new NGCC units.”

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### Technical Support Document: Resource Adequacy and Reliability Analysis

This document describes resource adequacy and reliability impacts of the two illustrative state plan scenarios that are reflected in the Regulatory Impact Analysis (RIA) that supports the final rule emission guidelines issued under sec tion 111(d) of the Clean Air Act, also known as the Clean Power Plan. As used here, the term resource adequacy is defined as the provision for adequate generating resources to meet projected load and generating reserve requirements in each power region 1 

### , while reliability includes the ability to deliver the resources to the loads, such that the overall power grid remains stable. The focus of the analysis is on the impact of the illustrative scenarios, in the context of a base case (absent the rule requirements) that is assumed to be adequate and reliable. In this framework, the emphasis is on the incremental changes in the power system that are projected to occur under the presence of the rule. 2 

### The EPA uses the Integrated Planning Model (IPM) to project likely future electricity market conditions with and without the proposed rule. 3


### It is important to recognize that the final rule provides flexibility in the context of state plan development that preserves the ability of responsible authorities to maintain electric reliability, as well as a provision to ensure that electric reliability is adequately maintained in the case of extreme circumstances, amongst other changes to the final rule that will assist states and other authorities with ensuring adequate supplies of electricity and maintain electric reliability. For more detail on how the final CPP addresses reliability, see Section VIII of the final rule preamble. The results presented in this document show that power system impacts of the final rule on system operations, under conditions preserving resource adequacy, are modest and manageable.

1 As analyzed in this document, power regions correspond to aggregates of IPM regions corresponding to NERC assessment areas. 2 Both the base and policy cases start from input data on the expected state of the fleet of power plants in 2016 and assume certain planned retirements and additions happen by the end of 2015; the analysis focuses on the impacts of retirements that are projected by the IPM model in the 2025 and 2030. See the documentation of the NEEDS data base at epa.gov/powersectormodeling for information on what retirements and additions are assumed to occur by the end of 2015.
3 See final rule Regulatory Impact Analysis for more detail on the power sector impacts of the final CPP.

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### IPM is a multi-regional, dynamic, deterministic linear programming model of the U.S. electric power sector. It provides forecasts of least cost capacity expansion, electricity dispatch, and emission control strategies while meeting energy demand and environmental, transmission, dispatch, and reliability constraints. The model is designed to reflect electricity markets as accurately as possible. The EPA uses the best available information from utilities, industry experts, gas and coal market experts, financial institutions, and government statistics as the basis for the detailed power sector modeling in IPM. The model documentation provides additional information on the assumptions discussed here as well as all other model assumptions and inputs. 4


### IPM’s least-cost dispatch solution, under any scenario, will ensure generation resource adequacy, either by using existing resources or through the construction of new resources. IPM addresses reliable delivery of generation resources for the delivery of electricity between the 64 IPM regions, based on current and planned transmission capacity, by setting limits to the ability to transfer power between regions using the bulk power transmission system. Within each model region, IPM assumes that adequate transmission capacity exists to deliver any resources located in, or transferred to, the region. This document focusses on key regional results important to management of the power system. For a more complete presentation of the broad power sector impacts of the proposed rule, see the Regulatory Impact Analysis.

Overview
In the final rule, the EPA is establishing emission guidelines for states in developing plans to address greenhouse gas emissions from existing fossil fuel-fired electric generating units. Specifically, the EPA is proposing category-specific performance rates for CO 2 

### emissions from power plants, as well goals for states to use in developing plans to meet the guidelines . See final rule preamble for more detail on the final CPP structure and rule requirements. This TSD uses the same scenarios and years of analysis contained in the RIA. 5 

### The scenarios include a base case (no CPP), a rate-based state plan scenario and a mass-based state plan scenario. For

4 Detailed information and documentation of EPA’s Base Case using IPM (v5.13), including all the underlying assumptions, data sources, and architecture parameters can be found on EPA’s website at: http://www.epa.gov/powersectormodeling/BaseCasev513.html
5 See Chapter 3 of the RIA for additional detail on the scenarios analyzed. Deleted:

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### purposes of the resource adequacy and reliability assessment, estimates and projections are taken from the same scenarios and years as shown in the RIA (2020, 2025, and 2030).



### CPP Rate-Based Scenarios

Summary of Changes in Operational Capacity
Total operational capacity is lower in the CPP scenario, primarily from reduced need for existing and new capacity as a result of increases in energy efficiency. These increases in energy efficiency make possible increases in retirements compared to the base case. Since most regions currently have capacity above their target reserve margins, most of these retirements are absorbed by a reduction in excess reserves in the early years. For illustrative purposes, the 2025 projection period, the first period to fall entirely within the compliance period of, is discussed first, followed by discussion of 2020 and 2030. Operational generating capacity 6 

### changes from the base case in 2025 are summarized below:

Table 1. Operational Capacity Summary in 2025 Base case operational capacity (MW) 1,037,223

Minus Retirements in CPP Rate Case: (-) Coal -22,984 (-) Oil-Gas Steam -9,264 (-) Combustion Turbine -1,942 (-) Combined Cycle -1,643 (-) Nuclear -1,128

Plus New Capacity Change from EE Reduction -12,626
Equals Policy Case Operational Capacity 988,764 7



### Since the model must maintain adequate reserves in each region, a portion of the reduced operational capacity in the CPP case is taken from reduced need for reserves compared to the

6 Operational capacity is any existing, new or retrofitted capacity that is not retired. 7 Numbers in this table may not sum to numbers in Table A1 due to independent rounding and small classification differences between the base and policy cases. Deleted:

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### base case. In order to maintain resource adequacy in each region where existing resources retire, the model relies on any excess reserve that ar e available from continuing to operate existing capacity, additions of new capacity, reduced total resource requirements from increases in energy efficiency, and the ability to shift transmission among regions as the generating capacity mix changes. As the table shows, the reduced resource needs permit lower capacity additions even though there are substantial increases in retirements. Each of these CPP case changes is discussed further below.
Reduction in Reserve Requirements and Excess Reserves
IPM uses a target reserve margin in each region 8 

### as the basis for determining how much capacity to keep operational in order to preserve resource adequacy. IPM retires capacity if it is no longer needed to provide energy for load or to provide capacity to meet reserve margin during the planning horizon of the projections. Since current regional reserves are generally higher than the target reserve margin for the region, and increased energy efficiency will reduce the need for reserves, IPM may retire reserve capacity in 2025 if it is not economic to use it to maintain adequate reserve margins. Existing resources may also be more expensive, compared to alternatives such as building new capacity or transferring capacity from another region. As a result, many of the plants that are projected to retire in 2025 will not need to be replaced. Because existing plants eventually retire in most regions, and IPM builds no more than what it needs to maintain a target reserve margin in each region, the actual reserve margins tend to approach the target reserve margins over time.
Table 1 above shows that operational generating capacity is reduced by 48,459MW (4.7 percent) nationwide in 2025 under the policy. 9 

### The majority of this reduction is the result of decreases the reserve requirements from energy efficiency under the final rule; in 2025 new energy efficiency under the final rule contributes 45,085 MW to reserve capacity 10 

### (see Table B1 for regional detail). Moreover, these reductions are from energy efficiency that is available in all

8 Reserve margin targets are generally based on the NERC 2010 10 Year Assessments for the region, except in cases where there are more stringent state requirements or other exceptions. 9 Regional data on operational capacity is shown in Table A1 of the Appendix.
10 The reserve contribution to reserve capacity requirements from energy efficiency is determined by the reduced peak demand and the target reserve margin in each region. For example, if peak demand in reduced by 100 MW and the reserve margin percentage in a region is 15%, the reduction in reserve capacity requirements is 115MW.

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### hours, not just at peak, so it can substitute for existing or new baseload capacity. A reduction of 4.7 percent in 2025 will therefore have little overall impact, particularly given the length of time available to plan for any system changes. Moreover, retirements are distributed throughout the power grid, so there will be only small impacts at the regional level. 11


### Although there are substantial existing regional variations in reserve margin, IPM adjusts regional operating capacities in 2025 to meet the specific target reserve margin in each region, through changes in the level of retirements, construction of new generating capacity, or transfers of capacity among regions to meet the specific reserve margin in each region. Each of these adjustments in the 2025 projections is described below.
Changes in Retirements and New Capacity Additions in the CPP Scenarios 12


### There are significant levels of fossil steam – coal and oil/gas – retiring in 2025 in both the base and CPP scenario. The incremental final rule case retirements are shown above in Table 1; the 36,931 MW of retirements are in addition to 69,254MW of coal and 12,973MW of oil/gas retirements already occurring in the base case.
By 2025, the increased level of energy efficiency in the CPP case, compared to the base case, leads to lower levels of new overall new capacity additions (Shown regionally in Table A5). Renewable additions are approximately the same in both the base and policy cases. The largest decreases are in NGCC (7,808MW) and CT (3,131MW). Although there can be local grid reliability issues in replacing some of the retiring units shown in Table 1 above and in Table A4, these can be managed within the normal reliability planning and management time frames provided by the flexible resource options and time frames in the rule. These retirements and additions in the projections are the result of economic planning for energy and capacity needs modeled in the projections, they are not forced on individual units. In particular, new additions in a base case scenario might that do not occur in the policy scenario projections might, in

11 See maps of IPM regions and NERC Assessment Regions, and the table of target and projected reserve margins in the Appendix C. IPM regions are based on the regions NERC uses for regional assessments. These Assessment Regions are used for the Appendix tables in this document.
12 Retirement and additions in this section are all incremental to the base case in 2025; the MW values represent model projections of responses to the imposition of the policy, not currently announced retirements or additions that are currently planned or under construction.

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### reality, be retained under a policy if local reliability conditions rendered this the most appropriate choice. This rule does not prevent generation owners from shifting retirements and additions among specific sources to ensure reliability in such circumstances.

Reserve Transfers
In cases where it is economic to transfer reserves from a neighboring region, rather than supply reserves from within a region, IPM will transfer reserves, subject to summer and winter limits that are designed to ensure that these rese rves can be transferred re liably. The transfer of reserves can occur, for example, if a region retires capacity that was used in the base case to meet reserve requirements, but a neighboring region has lower cost reserves that are not needed for its own reserve requirements. To examine these transfers, the EPA analyzed the change in net transfers from each region, where the net transfer for the base and policy cases is measured by the reserves sent to neighboring regions. In these cases, a positive value signifies the reserve capacity sent to other regions is larger than the reserve capacity received from other regions (sending and receiving regions can be different), while a negative value signifies that the capacity received is larger than the capacity sent. Thus, the value measures the degree to which resources in the region were reserved for use by other regions (positive value), or where the capacity to meet load in the region was served by resources in other regions (negative value). In each case these reserve transfers represent the use of the transmission system on a firm basis for at least a season.
To look at the impact of the CPP case on transfers, the measure used was the change in the summer reserves sent in the policy case compared to the base case. To develop a relative measure of the impact of the policy, the change in reserves was measured as a percentage of load in the sending region. This percentage gives an indication of the significance of the policy for changes in the grid. In general, the percentage changes in the final rule are below the changes in the proposed rule, and all are below 5%. 13

13 See the Resource Adequacy and Reliability Analysis for the proposed rule. A level of 5% was used as a screen in that analysis; there were three regions above 5% identified in the proposed rule TSD. Deleted: in the

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### Using this measure, the largest percentage changes in reserve transfers are in the Northwest (4.3%), SERC-North (-3.5%), and FRCC (3.1%). The change in the Northwest is attributable primarily to change in transfers from the Pacific Northwest IPM region to California, where an additional 2000MW are transferred to Northern California, including 1000MW shifted from Southern California (LADWP). The net change of 1,134(MW) occurs, in part, as a result of additional operating capacity made available by increased energy efficiency in the policy case compared to the base case. This shift does not indicate any reliability challenges, as the total transfers of 3,499MW in the policy case remain substantially below the transfer limit of 4,200MW.
The SERC regions and FRCC have shifts around three percent, with some areas increasing net transfers and others decreasing. These areas also saw shifts in transfers in the modeling for the proposed rule, but the changes in this final rule have reduced th e s e shifts to modest transfers compared to the shifts under the proposal. In general, the shifts under the final rule show transfers from the Southeastern areas with greater natural gas resources available – FRCC and SERC-SE – toward northern areas with greater amounts of coal -- TVA and Kentucky. These transfers in the modeling remain well below the interregional transfers limits and 3 percent or less of the regional load in each case, and it is reasonable to expect them to be manageable, if needed, given the length of time available.

CPP Rate Scenario in 2020 and 2030
There are other model projection periods that include years that fall in the period for compliance with the rule. The 2020 projections include the years 2019 through 2022, so one of the years in the period falls in the compliance period. EPA examined the information for the rate scenario for 2020 corresponding to the rate scenario in 2025. This information is shown the tables in Appendix A, which correspond to the tables for the 2025 case in Appendix B. Since the projections are representative of the entire four year period, it is difficult to draw conclusions with regard to firm impacts on reliability resulting from the rule. This is because most of the period is outside the compliance period of the final rule, and there can be no direct conflict with the rule except in the very last year of the projection period. The results are compared below with the 2025 results for purposes of illustration. Deleted: i

Deleted: be

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### The differences between 2020 and 2025 in the CPP rate scenario are driven by the fact that IPM modeling retires capacity from the start of the modeling period in 2016, based on projections that assume complete information about the future and precise economic planning. It thus assumes that capacity retires at the earliest possible moment, so that excess reserves are used up and reserve margins can fall to target levels earlier than expected in practice. Nevertheless, in 2020, seven regions maintain margins above their levels in 2025 (See Table A3). This is consistent with the lower level of overall retirements in 2020 compared to 2025 (24,567MW compared to 36,961MW in 2025), so that the modeling confirms that the major potential resource adequacy pressures from the final rule are not seen until the projections for 2025.
Results for the rate scenario in 2030 are contained in Appendix C. Reserve margins in the policy case in 2030 are essentially unchanged (less than 0.5% difference in all regions) from 2025, reflecting the fact that most regions were already at thei r target margins in the 2025 rate scenario. Base case margins decline from 2025 to 2030, as margins above targets are reduced, so that the base and policy overall national margins are less than 1 percent different (Table C3). There continue to be more retirements in the policy case relative to the base case in 2030 ( i ncremental retirements of 41,009MW in 2030 compared to 36,961MW in 2025, an increase of 5,048 MW). These retirements are offset by a corresponding combination of new energy efficiency and changes in new capacity. In 2025, there were 12,626 MW fewer new capacity additions in the CPP case; in 2030 there were 16,964 MW fewer: a net decrease new of an incremental 4,338 MW (over the base case) in the 2030 case compared to the comparable 2025 figure. However, the increase in the contribution of energy efficiency to reserve margin capacity was considerably greater than the combined decrease in new capacity additions and increase in retirements in 2030: the contribution of new energy efficiency to reserve margin in 2030 was 77,741 MW compared to 45,085 MW in 2025 (See Tables B1 and C1 in the Appendices), an increase of 22,656 MW. Given the long planning horizon of 2030, there will be adequate time to plan for potential shifts in the mix of demand and supply resources as these evolve over time. None of these results suggest there will be reasons for concern over the management of resource adequacy Deleted: I

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### CPP Mass-Based Scenarios
The EPA also examined the mass scenario modeling results to identify differences with rate scenario potential impacts. The results for the CPP mass-based scenarios are contained in Appendices D through F for the projection years 2020, 2025 and 2030. These tables correspond to the tables for the CPP Rate-Based scenarios in Appendices A through C.
As expected, rate and mass cases showed very similar patterns in total operating and reserve capacity, since the IPM model must serve the same loads and ensure the same reserve margins in each case. In 2025, total operating capacity between rate and mass cases differs by less than one percent and regional operating capacities are within 5 percent except for the BASN regions, where the percentage difference is 8.6%, the result of retirement of a resource (coal) in Utah, which is offset by increased transmission capacity transfers. Reserve capacity and projected reserve margins for the mass scenario (Tables E2 and E3) follow a pattern similar to operating capacity: totals are within 1% of the projections for the corresponding outputs rate scenario and regional reserve capacities are under 5 percent.
Differences between the scenarios develop in the types of capacity that are retired and in the amount and types of new capacity built in 2025. The mass scenario results show more incremental retirements of coal capacity (29,319 MW compared to 22,984 MW in the rate scenario) and in Oil-Gas capacity (10,421 MW compared to 9,264 MW). The mass scenario also results in more new NGCC and CT capacity, and less new wind and solar capacity. The mass scenario still is projected to have a decrease new capacity compared to the base case, but the decrease is only 9,971 MW compared to the 12,626 MW in the rate scenario. No reliability concerns are raised by these differences.
The patterns of transfers are also similar. In the mass scenario, there is somewhat more variation in net transfers than in the rate case. In particular there are two regions with shifts of more than 5% in the mass scenario: the Northwest and BASN, both in WECC. These two shifts are linked. The Northwest reserve transfers include the transfers in the rate scenario discussed above, plus additional transfers from the Northwest to BASN to compensate for the coal retirements in BASN discussed above. The two cases with the largest percentage shift examined Deleted:

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### above are reduced in magnitude. These transfers in the mass scenario remain below the interregional transfer limits in the modeling and do not appear to present significant reliability related concerns.
The same general patterns noted here for 2025 are also present in 2020 and 20 30 : only minor variations in total operating capacity, somewhat higher fossil steam retirements, and more NGCC and CT capacity. These differences do not raise further issues of resource adequacy. Details can be found in the Appendices. Deleted: 25 Commented [A1]: Did you mean 2030?

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### Appendix A: Tables by IPM Region for CPP Rate-Based Scenario in 2020
A1. Projected Operational Capacity
A2. . Summary of Summer Peak Loads and Reserve Capacity
A3. Summary of Target and Projected Reserve Margins
A4. Policy Case Retired Capacity Incremental to Base Case
A5. New Capacity in Policy Case Incremental to Base Case
A6. Net Reserves Sent by NERC Assessment Region Commented [A2]: 1. The Appendices A following do not match this order. 2. For all appendices, the titles of the appendices have strange centering if they run to a second line. 3. Check titles for a space before (MW), some have it, some don’t.

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13 A4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2020

CC Coal CT NU OG Steam Total Basin (BASN) 180

‐ 179 0 0 108 109 Desert Southwest (DS W 616 162 0 0 513 1,290 ERCOT 0 0 0 0 0 0 FRCC 59 317 0 0 288 664 ISO

‐ NE 0 0 0 0 1,725 1,725 MAPP 0 679 0 0 0 679 MISO 0 2,822 0 0 0 2,822 Northern California (C A 0 0 1,898 0 0 1,898 Northwest (NORW) 1,465 52 0 867 0 2,383 NYISO 81

‐ 68 0 0 1,674 1,687 PJM 0 408 0 0 29 437 Rockies (Rock) 39 963 0 0 55 1,057 SERC

‐ E 0 434 0 0 0 434 SERC

‐ N 0 1,443 0 0 0 1,443 SERC

‐ SE 0 2,171 0 0 0 2,171 SERC

‐ W

‐ 434 1,328 0 0

‐ 92 802 Southern California (C A 0 0 43 0 2,440 2,484 SPP

‐ 362 2,619 0 0 226 2,483 Grand Total 1,643 13,149 1,942 867 6,966 24,567

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14 A2. Summer Peak Loads and Reserve Capacity in 2020 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 11,953 11,880 13,926 13,567 Desert Southwest ( 29,612 29,352 34,074 33,314 ERCOT 73,948 73,806 84,116 83,955 FRCC 44,324 44,253 56,200 55,193 ISO-NE 26,475 26,248 30,446 30,185 MAPP 5,330 5,324 6,603 6,123 MISO 90,719 89,895 106,505 104,548 Northern California 21,282 21,090 25,399 24,193 Northwest (NORW ) 25,414 25,175 39,507 34,859 NYISO 30,058 29,744 34,868 34,503 PJM 150,553 149,437 173,738 172,450 Rockies (Rock) 14,156 14,042 17,609 16,654 SERC-E 42,195 41,966 48,524 48,261 SERC-N 38,518 38,398 44,296 44,158 SERC-SE 48,110 48,014 55,327 55,217 SERC-W 29,095 29,052 37,890 34,798 Southern California 28,108 27,797 33,588 32,085 SPP 51,995 51,865 63,790 60,946 US T otal 761,845 757,338 906,407 885,008

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15 A3. Summary of Target and Projected Reserve Margins in 2020 Projected Reserve Margins

NERC Assessment Re g io n Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Policy Change from Base Basin (BASN) 12.60% 16.51% 14.21% 1.6% -2.3% Desert Southwest (DSW) 13.50% 15.07% 13.50% 0.0% -1.6% ERCOT 13.75% 13.75% 13.75% 0.0% 0.0% FRCC 19.25% 26.79% 24.72% 5.5% -2.1% ISO-NE 15.00% 15.00% 15.00% 0.0% 0.0% MAPP 15.00% 23.87% 15.00% 0.0% -8.9% MISO 16.30% 17.40% 16.30% 0.0% -1.1% Northern California ( CALN ) 14.71% 19.35% 14.71% 0.0% -4.6% Northwest (NORW) 17.90% 31.61% 25.25% 7.4% -6.4% NYISO 16.00% 16.00% 16.00% 0.0% 0.0% PJM 15.40% 15.40% 15.40% 0.0% 0.0% Rockies (Rock) 14.65% 24.39% 18.60% 3.9% -5.8% SERC-E 15.00% 15.00% 15.00% 0.0% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% 0.0% SERC-W 15.00% 30.23% 19.78% 4.8% -10.5% S outhern California ( CALS ) 15.14% 19.50% 15.42% 0.3% -4.1% SPP 13.60% 22.69% 17.51% 3.9% -5.2% Grand Total 15.30% 18.98% 16.86% 1.6% -2.1%

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16 A4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2020

CC Coal CT NU OG Steam Total Basin (BASN) 180

‐ 179 0 0 108 109 Desert Southwest (DS W 616 162 0 0 513 1,290 ERCOT 0 0 0 0 0 0 FRCC 59 317 0 0 288 664 ISO

‐ NE 0 0 0 0 1,725 1,725 MAPP 0 679 0 0 0 679 MISO 0 2,822 0 0 0 2,822 Northern California (C A 0 0 1,898 0 0 1,898 Northwest (NORW) 1,465 52 0 867 0 2,383 NYISO 81

‐ 68 0 0 1,674 1,687 PJM 0 408 0 0 29 437 Rockies (Rock) 39 963 0 0 55 1,057 SERC

‐ E 0 434 0 0 0 434 SERC

‐ N 0 1,443 0 0 0 1,443 SERC

‐ SE 0 2,171 0 0 0 2,171 SERC

‐ W

‐ 434 1,328 0 0

‐ 92 802 Southern California (C A 0 0 43 0 2,440 2,484 SPP

‐ 362 2,619 0 0 226 2,483 Grand Total 1,643 13,149 1,942 867 6,966 24,567

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

17 A5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2020 Region CC CT Wind Solar Other Total Basin (BASN) 0 0 0 0 0 0 Desert Southwest (DSW) 0 0 3 0 0 3 ERCOT

‐ 196 0 323 0 0 127 FRCC 0 0 0 0 0 0 ISO

‐ NE 0 0 334 0 0 334 MAPP 0 0 247 0 0 247 MISO 320 0

‐ 38

‐ 6 305 581 Northern California (CALN) 0 0 12 0 0 12 Northwest (NORW) 0 0 10 0 0 10 NYISO 0 0

‐ 386 0

‐ 213

‐ 599 PJM 767

‐ 1,692 175 12

‐ 115

‐ 852 Rockies (Rock) 0 0 0

‐ 54 0

‐ 54 SERC

‐ E 612 0 0

‐ 29 0 583 SERC

‐ N 1,203 0 3 0 23 1,229 SERC

‐ SE 0 0 0 0 0 0 SERC

‐ W 0 0 0 00 0 Southern California (CALS) 0 0

‐ 270 0 0

‐ 270 SPP 0 0 1,110 0 0 1,110 Grand Total 2,705

‐ 1,692 1,523

‐ 78 0 2,459

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

18 

### A6. Net Reserves Sent by NERC Assessment Region(MW) i n 2020

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -1,772 -1,522 251 2.1% Desert Southwest (DS W 3,869 3,340 -529 -1.8% ERCOT -1,942 -1,942 0 0.0% FRCC 0 342 342 0.8% ISO-NE -1,823 -3,212 -1,388 -5.2% MISO -2,775 -3,249 -474 -0.5% Northern California (CAL 0 -692 -692 -3.3% Northwest (NORW) 407 2,675 2,268 8.9% NYISO 320 -1,303 -1,623 -5.4% PJM -4,614 -4,702 -88 -0.1% Rockies (Rock) 1,417 1,298 -118 -0.8% SERC-E -981 -547 434 1.0% SERC-N 1,502 1,435 -67 -0.2% SERC-SE 3,800 1,739 -2,061 -4.3% SERC-W 1,112 3,416 2,304 7.9% Southern California (CA L -3,761 -4,884 -1,124 -4.0% SPP 2,191 2,872 682 1.3%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

19 

### Appendix B: Tables by IPM Region for CPP Rate-Based Scenario in 2025
B1. Projected Operational Capacity
B2 . Summary of Summer Peak Loads and Reserve Capacity

B3. Summary of Target and Projected Reserve Margins
B4. Policy Case Retired Capacity Incremental to Base Case
B5. New Capacity in Policy Case Incremental to Base Case
B6. Net Reserves Sent by NERC Assessment Region

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

20 

### B1. Projected Operational Capacity Year= 2025

All Generation Sources EE Capacity Overall Coal Only Region Base Policy Contribution Change Base Policy Basin (BASN) 14,293 13,888 687 282 4,802 4,685 Desert Southwest (DSW) 42,265 40,855 2,300 890 8,380 8,096 ERCOT 99,864 96,751 3,345 232 17,937 17,647 FRCC 56,336 55,672 2,080 1,417 7,479 7,162 ISO

‐ NE 32,685 31,294 1,644 252 0 0 MAPP 9,627 8,993 207

‐ 428 3,007 2,190 MISO 125,625 118,165 6,127

‐ 1,333 45,036 39,567 Northern California (CALN ) 29,389 27,503 1,321

‐ 565 71 71 Northwest (NORW) 51,181 48,711 2,036

‐ 434 2,406 2,354 NYISO 38,484 36,082 2,173

‐ 229 0 0 PJM 188,212 179,396 9,367 551 50,144 44,546 Rockies (Rock) 23,663 22,284 1,041

‐ 339 9,216 8,363 SERC

‐ E 55,904 52,022 2,556

‐ 1,326 11,045 9,478 SERC

‐ N 50,217 46,755 2,051

‐ 1,411 13,141 11,557 SERC

‐ SE 57,354 56,571 2,192 1,409 11,655 10,871 SERC

‐ W 40,012 37,823 1,069

‐ 1,121 4,733 3,418 Southern California (CALS) 43,405 39,826 2,159

‐ 1,420 57 50 SPP 78,704 75,121 2,733

‐ 850 22,966 19,113 Grand Total 1,037,223 987,713 45,085

‐ 4,425 212,075 189,169

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

21 B2. Summer Peak Loads and Reserve Capacity in 2025 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 12,466 11,856 14,036 13,349 Desert Southwest ( 31,887 29,861 36,192 33,892 ERCOT 77,606 74,665 88,276 84,932 FRCC 46,355 44,611 55,279 53,199 ISO-NE 26,701 25,272 30,706 29,063 MAPP 5,539 5,360 6,370 6,164 MISO 93,625 88,356 108,885 102,758 Northern California 22,305 21,155 25,592 24,301 Northwest (NORW ) 26,489 24,955 36,672 33,098 NYISO 30,051 28,179 34,860 32,687 PJM 154,841 146,724 178,686 169,319 Rockies (Rock) 15,223 14,315 17,676 16,412 SERC-E 44,263 42,040 50,902 48,346 SERC-N 40,450 38,666 46,517 44,466 SERC-SE 50,430 48,524 57,994 55,802 SERC-W 30,589 29,660 35,644 34,109 Southern California 29,473 27,605 34,006 31,922 SPP 54,332 51,926 62,673 58,988 US T otal 792,624 753,693 920,969 872,809

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

22 B3. Summary of Target and Projected Reserve Margins in 2025 Projected Reserve Margins

NERC Assessment Re g ion Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Basin (BASN) 12.60% 12.60% 12.60% 0.0% Desert Southwest (DSW) 13.50% 13.50% 13.50% 0.0% ERCOT 13.75% 13.75% 13.75% 0.0% FRCC 19.25% 19.25% 19.25% 0.0% ISO-NE 15.00% 15.00% 15.00% 0.0% MAPP 15.00% 15.00% 15.00% 0.0% MISO 16.30% 16.30% 16.30% 0.0% Northern California ( CALN ) 14.71% 14.74% 14.87% 0.2% Northwest (NORW) 17.90% 27.05% 25.71% 7.8% NYISO 16.00% 16.00% 16.00% 0.0% PJM 15.40% 15.40% 15.40% 0.0% Rockies (Rock) 14.65% 16.12% 14.65% 0.0% SERC-E 15.00% 15.00% 15.00% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% SERC-W 15.00% 16.52% 15.00% 0.0% S outhern California ( CALS ) 15.14% 15.38% 15.64% 0.5% SPP 13.60% 15.35% 13.60% 0.0% Grand Total 15.29% 16.19% 15.80% 0.5%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

23 B4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2025

CC Coal CT NU OG Steam Total Basin (BASN) 180 118 0 0 108 405 Desert Southwest (DS W 616 284 0 0 513 1,412 ERCOT 0 291 0 0 0 291 FRCC 59 317 0 0 288 664 ISO

‐ NE 0 0 0 0 1,725 1,725 MAPP 0 817 0 0 0 817 MISO 0 5,484 0 0 0 5,484 Northern California (C A 0 0 1,898 0 0 1,898 Northwest (NORW) 1,465 52 0 867 0 2,383 NYISO 81 0 0 261 1,674 2,016 PJM 0 5,601 0 0 19 5,620 Rockies (Rock) 39 855 0 0 55 949 SERC

‐ E 0 1,566 0 0 0 1,566 SERC

‐ N 0 1,603 0 0 0 1,603 SERC

‐ SE 0 783 0 0 0 783 SERC

‐ W

‐ 434 1,328 0 0 1,309 2,203 Southern California (C A 0 7 43 0 2,514 2,565 SPP

‐ 362 3,878 0 0 1,060 4,576 Grand Total 1,643 22,984 1,942 1,128 9,264 36,961

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

24 B5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2025 Region CC CT Wind Solar Other Total Basin (BASN) 0 0 0 0 0 0 Desert Southwest (DSW) 0 0 3 0 0 3 ERCOT

‐ 2,003

‐ 1,142 323 0 0

‐ 2,823 FRCC 0 0 0 0 0 0 ISO

‐ NE 0 0 334 0 0 334 MAPP 0 0 182 0 0 182 MISO

‐ 1,534 0

‐ 404

‐ 53 0

‐ 1,991 Northern California (CALN) 0 0 12 0 0 12 Northwest (NORW) 0 0 10 0

‐ 96

‐ 86 NYISO 0 0

‐ 386 0 0

‐ 386 PJM

‐ 382

‐ 1,988

‐ 696

‐ 133 0

‐ 3,199 Rockies (Rock) 0 0 0

‐ 432 0

‐ 432 SERC

‐ E

‐ 2,008 0 0

‐ 308 0

‐ 2,316 SERC

‐ N

‐ 1,881 0 3 0 0

‐ 1,878 SERC

‐ SE 0 0 0 0 0 0 SERC

‐ W 0 0 0 00 0 Southern California (CALS) 0 0

‐ 270

‐ 706

‐ 39

‐ 1,015 SPP 0 0 965 4 0 969 Grand Total

‐ 7,808

‐ 3,131 75

‐ 1,628

‐ 135

‐ 12,626

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

25 

### B6. Net Reserves Sent by NERC Assessment Region(MW) in 2025

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -2,052 -1,769 283 2.3% Desert Southwest (DS W 1,846 2,734 888 2.8% ERCOT -1,931 -1,942 -11 0.0% FRCC 838 2,254 1,417 3.1% ISO-NE -2,009 -1,999 10 0.0% MISO -2,502 -4,017 -1,515 -1.5% Northern California (CAL -1,490 -2,095 -606 -2.7% Northwest (NORW) 3,345 4,480 1,134 4.3% NYISO 249 296 47 0.2% PJM -6,877 -5,637 1,240 0.8% Rockies (Rock) 1,419 1,619 201 1.3% SERC-E -402 -1,492 -1,091 -2.5% SERC-N 2,141 728 -1,413 -3.5% SERC-SE -1,213 196 1,409 2.8% SERC-W 3,806 3,149 -657 -2.1% Southern California (CA L -3,309 -4,091 -782 -2.7% SPP 3,631 3,059 -572 -1.1%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

26 

### Appendix C: Tables by IPM Region for CPP Rate-Based Scenario in 2030
C1. Projected Operational Capacity
C2. Summary of Summer Peak Loads and Reserve Capacity

C3. Summary of Target and Projected Reserve Margins
C4. Policy Case Retired Capacity Incremental to Base Case
C5. New Capacity in Policy Case Incremental to Base Case
C6. Net Reserves Sent by NERC Assessment Region

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

27 

### C1. Projected Operational Capacity Year= 2030

All Generation Sources EE Capacity Overall Coal Only Region Base Policy Contribution Change Base Policy Basin (BASN) 14,346 13,942 1,135 731 4,802 4,685 Desert Southwest (DSW) 42,265 40,855 3,911 2,501 8,380 8,096 ERCOT 107,231 111,864 6,856 11,490 17,937 17,339 FRCC 61,471 55,847 4,357

‐ 1,267 7,414 6,325 ISO

‐ NE 32,688 31,294 2,518 1,124 0 0 MAPP 9,627 9,322 464 159 3,007 2,190 MISO 126,164 119,045 9,389 2,269 45,036 39,567 Northern California (CALN ) 29,389 27,503 1,976 90 71 71 Northwest (NORW) 51,415 49,030 3,171 786 2,406 2,354 NYISO 39,032 35,323 3,220

‐ 489 0 0 PJM 203,408 185,630 15,258

‐ 2,519 50,129 43,483 Rockies (Rock) 24,105 22,666 1,777 337 9,216 8,363 SERC

‐ E 59,039 53,920 4,304

‐ 814 11,045 7,952 SERC

‐ N 52,505 48,091 3,916

‐ 498 13,141 11,084 SERC

‐ SE 60,658 60,265 4,470 4,076 11,655 10,692 SERC

‐ W 40,602 40,391 2,247 2,037 4,733 3,418 Southern California (CALS) 49,260 44,898 3,238

‐ 1,124 57 50 SPP 79,238 74,663 5,534 958 22,506 18,653 Grand Total 1,082,444 1,024,551 77,741 19,847 211,536 184,322

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

28 C2. Summer Peak Loads and Reserve Capacity in 2030 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 12,961 11,953 14,594 13,459 Desert Southwest ( 34,589 31,144 39,259 35,348 ERCOT 82,455 76,428 93,793 86,936 FRCC 49,145 45,491 58,606 54,248 ISO-NE 27,433 25,243 31,547 29,029 MAPP 5,732 5,329 6,592 6,128 MISO 96,428 88,354 112,145 102,756 Northern California 23,372 21,650 26,810 24,834 Northwest (NORW ) 27,515 25,023 33,947 31,852 NYISO 30,694 27,918 35,605 32,385 PJM 160,273 147,051 184,955 169,696 Rockies (Rock) 16,419 14,869 18,824 17,047 SERC-E 46,801 43,058 53,821 49,517 SERC-N 42,204 38,799 48,534 44,619 SERC-SE 52,944 49,057 60,886 56,416 SERC-W 32,436 30,482 37,301 35,054 Southern California 30,929 28,127 35,684 32,494 SPP 57,092 52,221 64,857 59,323 US T otal 829,421 762,176 957,760 881,143

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

29 C3. Summary of Target and Projected Reserve Margins in 2030 Projected Reserve Margins

NERC Assessment Re g io n Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Policy Change from Base Basin (BASN) 12.60% 12.60% 12.60% 0.0% 0.0% Desert Southwest (DSW) 13.50% 13.50% 13.50% 0.0% 0.0% ERCOT 13.75% 13.75% 13.75% 0.0% 0.0% FRCC 19.25% 19.25% 19.25% 0.0% 0.0% ISO-NE 15.00% 15.00% 15.00% 0.0% 0.0% MAPP 15.00% 15.00% 15.00% 0.0% 0.0% MISO 16.30% 16.30% 16.30% 0.0% 0.0% Northern California ( CALN ) 14.71% 14.71% 14.71% 0.0% 0.0% Northwest (NORW) 17.90% 23.38% 25.07% 7.2% 1.7% NYISO 16.00% 16.00% 16.00% 0.0% 0.0% PJM 15.40% 15.40% 15.40% 0.0% 0.0% Rockies (Rock) 14.65% 14.65% 14.65% 0.0% 0.0% SERC-E 15.00% 15.00% 15.00% 0.0% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% 0.0% SERC-W 15.00% 15.00% 15.00% 0.0% 0.0% S outhern California ( CALS ) 15.14% 15.37% 15.53% 0.4% 0.2% SPP 13.60% 13.60% 13.60% 0.0% 0.0% Grand Total 15.28% 15.47% 15.61% 0.3% 0.1%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

30 C4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2030

CC Coal CT NU OG Steam Total Basin (BASN) 180 118 0 0 108 405 Desert Southwest (DS W 616 284 0 0 513 1,412 ERCOT 0 600 0 0 0 600 FRCC 59 1,089 0 0 288 1,436 ISO

‐ NE 0 0 0 0 1,725 1,725 MAPP 0 817 0 0 0 817 MISO 0 5,484 0 0 0 5,484 Northern California (C A 0 0 1,898 0 0 1,898 Northwest (NORW) 1,465 52 0 867 0 2,383 NYISO 81 0 0 1 1,674 1,756 PJM 0 6,652 0

‐ 1 19 6,669 Rockies (Rock) 39 855 0 0 55 949 SERC

‐ E 0 3,093 0 0 0 3,093 SERC

‐ N 0 2,076 0 0 0 2,076 SERC

‐ SE 0 962 0 0 0 962 SERC

‐ W

‐ 434 1,328 0 0 1,309 2,203 Southern California (C A 0 7 43 0 2,514 2,565 SPP

‐ 362 3,878 0 0 1,060 4,576 Grand Total 1,643 27,294 1,942 867 9,264 41,009

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

31 C5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2030 Region CC CT Wind Solar Other Total Basin (BASN) 0 0 1 0 0 1 Desert Southwest (DSW) 0 0 3 0 0 3 ERCOT

‐ 6,330

‐ 4,182 323 15,421 0 5,232 FRCC

‐ 4,189 0 0 0 0

‐ 4,189 ISO

‐ NE 0 0 331 0 0 331 MAPP 0 0 497 0 15 511 MISO

‐ 1,234 0

‐ 330

‐ 86 0

‐ 1,650 Northern California (CALN) 0 0 12 0 0 12 Northwest (NORW) 0 0

‐ 2 00

‐ 2 NYISO

‐ 1,567 0

‐ 386 0 0

‐ 1,953 PJM

‐ 6,179

‐ 2,899

‐ 864

‐ 1,172 0

‐ 11,114 Rockies (Rock) 0 0 0

‐ 529 37

‐ 492 SERC

‐ E

‐ 1,838 0 0

‐ 188 0

‐ 2,026 SERC

‐ N

‐ 2,360 0 3 0 0

‐ 2,357 SERC

‐ SE

‐ 3,304 0 0 3,873 0 569 SERC

‐ W

‐ 589 0 0 2,569 0 1,979 Southern California (CALS)

‐ 1,603 0

‐ 270 79

‐ 3

‐ 1,797 SPP

‐ 887 0 859 4 0

‐ 24 Grand Total

‐ 30,080

‐ 7,081 177 19,970 50

‐ 16,964

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

32 

### C6. Net Reserves Sent by NERC Assessment Region(MW) in 2030

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -2,563 -1,826 738 5.7% Desert Southwest (DS W -1,245 1,269 2,514 7.3% ERCOT -40 -389 -349 -0.4% FRCC 2,646 1,379 -1,267 -2.6% ISO-NE -2,848 -1,949 900 3.3% MISO -5,473 -3,076 2,397 2.3% Northern California (CAL -2,709 -2,630 80 0.3% Northwest (NORW) 6,225 5,945 -279 -1.0% NYISO 26 -63 -90 -0.3% PJM -5,123 -6,100 -977 -0.6% Rockies (Rock) 399 1,097 698 4.3% SERC-E -506 -1,177 -670 -1.4% SERC-N 2,412 1,912 -500 -1.2% SERC-SE -800 326 1,126 2.1% SERC-W 2,732 2,844 112 0.3% Southern California (CA L -2,124 -3,120 -997 -3.2% SPP 1,933 2,271 337 0.6%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

33 

### Appendix D: Tables by IPM Region for CPP Mass-Based Scenario in 2020
D1. Projected Operational Capacity
D2. Summary of Summer Peak Loads and Reserve Capacity

D3. Summary of Target and Projected Reserve Margins
D4. Policy Case Retired Capacity Incremental to Base Case
D5. New Capacity in Policy Case Incremental to Base Case
D6. Net Reserves Sent by NERC Assessment Region

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

34 

### D1. Projected Operational Capacity Year= 2020

All Generation Sources EE Capacity Overall Coal Only Region Base Policy Contribution Change Base Policy Basin (BASN) 14,448 14,475 84 111 5,064 5,244 Desert Southwest (DSW) 42,114 40,168 296

‐ 1,650 8,380 7,501 ERCOT 95,496 95,339 162 4 17,937 17,550 FRCC 56,419 55,636 88

‐ 695 7,479 7,131 ISO

‐ NE 32,558 30,383 262

‐ 1,914 0 0 MAPP 9,545 9,022 7

‐ 516 3,007 2,545 MISO 122,247 118,757 958

‐ 2,533 45,045 39,926 Northern California (CALN ) 30,690 28,522 220

‐ 1,948 71 71 Northwest (NORW) 51,014 49,408 330

‐ 1,276 2,406 2,354 NYISO 38,484 36,626 365

‐ 1,494 0 0 PJM 183,187 181,488 1,288

‐ 411 50,144 49,784 Rockies (Rock) 23,250 22,246 135

‐ 869 9,327 8,407 SERC

‐ E 52,103 52,109 262 269 11,045 11,176 SERC

‐ N 47,143 47,672 138 667 13,722 12,696 SERC

‐ SE 59,679 57,662 110

‐ 1,907 14,035 12,018 SERC

‐ W 39,074 38,826 52

‐ 196 4,733 3,918 Southern California (CALS) 40,576 38,137 358

‐ 2,082 57 57 SPP 77,768 75,481 153

‐ 2,135 22,966 20,139 Grand Total 1,015,797 991,956 5,267

‐ 18,575 215,416 200,515

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

35 D2. Summer Peak Loads and Reserve Capacity in 2020 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 11,953 11,878 13,926 13,375 Desert Southwest ( 29,612 29,352 34,074 33,314 ERCOT 73,948 73,806 84,116 83,955 FRCC 44,324 44,253 56,200 55,045 ISO-NE 26,475 26,248 30,446 30,185 MAPP 5,330 5,324 6,603 6,123 MISO 90,719 89,895 106,505 104,548 Northern California 21,282 21,090 25,399 24,193 Northwest (NORW ) 25,414 25,181 39,507 35,702 NYISO 30,058 29,744 34,868 34,503 PJM 150,553 149,437 173,738 172,450 Rockies (Rock) 14,156 14,045 17,609 16,994 SERC-E 42,195 41,966 48,524 48,261 SERC-N 38,518 38,398 44,296 44,158 SERC-SE 48,110 48,014 55,327 55,217 SERC-W 29,095 29,053 37,890 35,696 Southern California 28,108 27,797 33,588 32,053 SPP 51,995 51,864 63,790 60,300 US T otal 761,845 757,343 906,407 886,072

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

36 D3. Summary of Target and Projected Reserve Margins in 2020 Projected Reserve Margins

NERC Assessment Re g io n Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Policy Change from Base Basin (BASN) 12.60% 16.51% 12.60% 0.0% -3.9% Desert Southwest (DSW) 13.50% 15.07% 13.50% 0.0% -1.6% ERCOT 13.75% 13.75% 13.75% 0.0% 0.0% FRCC 19.25% 26.79% 24.39% 5.1% -2.4% ISO-NE 15.00% 15.00% 15.00% 0.0% 0.0% MAPP 15.00% 23.87% 15.00% 0.0% -8.9% MISO 16.30% 17.40% 16.30% 0.0% -1.1% Northern California ( CALN ) 14.71% 19.35% 14.71% 0.0% -4.6% Northwest (NORW) 17.90% 31.61% 28.79% 10.9% -2.8% NYISO 16.00% 16.00% 16.00% 0.0% 0.0% PJM 15.40% 15.40% 15.40% 0.0% 0.0% Rockies (Rock) 14.65% 24.39% 21.00% 6.4% -3.4% SERC-E 15.00% 15.00% 15.00% 0.0% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% 0.0% SERC-W 15.00% 30.23% 22.87% 7.9% -7.4% S outhern California ( CALS ) 15.14% 19.50% 15.31% 0.2% -4.2% SPP 13.60% 22.69% 16.27% 2.7% -6.4% Grand Total 15.30% 18.98% 17.00% 1.7% -2.0%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

37 D4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2020

CC Coal CT NU OG Steam Total Basin (BASN) 43

‐ 179 0 0 108

‐ 28 Desert Southwest (DS W 553 881 0 0 513 1,948 ERCOT 0 391 0 0 0 391 FRCC 148 348 0 0 288 784 ISO

‐ NE 0 0 0 0 1,910 1,910 MAPP 0 462 0 0 0 462 MISO 0 5,146 0

‐ 1,112 0 4,034 Northern California (C A 141 0 1,898 0 0 2,039 Northwest (NORW) 675 52 0 860 0 1,588 NYISO 81 0 0 0 1,330 1,411 PJM 0 363 0 0 377 740 Rockies (Rock) 0 921 0 0 0 921 SERC

‐ E 0

‐ 132 0 0 0

‐ 132 SERC

‐ N 0 1,042 0 0 0 1,042 SERC

‐ SE 0 2,017 0 0 0 2,017 SERC

‐ W

‐ 434 823 0 0

‐ 92 297 Southern California (C A 2 0 75 0 2,942 3,019 SPP

‐ 206 2,845 0

‐ 554 98 2,184 Grand Total 1,004 14,981 1,974

‐ 806 7,474 24,627

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

38 D5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2020 Region CC CT Wind Solar Other Total Basin (BASN) 0 0

‐ 1 00

‐ 1 Desert Southwest (DSW) 0 0

‐ 1 00

‐ 1 ERCOT 233 0

‐ 3 0 0 230 FRCC 0 0 0 0 0 0 ISO

‐ NE 0 0

‐ 265 0 0

‐ 265 MAPP 0 0

‐ 62 0 0

‐ 62 MISO 905 0

‐ 688

‐ 6 305 516 Northern California (CALN) 0 0

‐ 19 0

‐ 110

‐ 128 Northwest (NORW) 0 0

‐ 19 0 0

‐ 19 NYISO 0 0

‐ 448 0 0

‐ 448 PJM 1,380

‐ 1,797

‐ 292

‐ 16

‐ 237

‐ 962 Rockies (Rock) 0 0 0

‐ 84 0

‐ 84 SERC

‐ E 0 00

‐ 125 0

‐ 125 SERC

‐ N 1,554 0 0 0 0 1,554 SERC

‐ SE 0 0 0 0 0 0 SERC

‐ W 0 0 0 0 41 41 Southern California (CALS) 834 0

‐ 255 0 0 580 SPP 0 0

‐ 121 0 0

‐ 121 Grand Total 4,906

‐ 1,797

‐ 2,172

‐ 231 0 706

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

39 

### D6. Net Reserves Sent by NERC Assessment Region(MW) i n 2020

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -1,772 -1,194 579 4.8% Desert Southwest (DS W 3,869 2,684 -1,185 -4.0% ERCOT -1,942 -1,942 0 0.0% FRCC 0 371 371 0.8% ISO-NE -1,823 -3,534 -1,710 -6.5% MISO -2,775 -3,958 -1,183 -1.2% Northern California (CAL 0 -909 -909 -4.3% Northwest (NORW) 407 2,617 2,210 8.7% NYISO 320 -906 -1,226 -4.1% PJM -4,614 -4,697 -84 -0.1% Rockies (Rock) 1,417 1,091 -325 -2.3% SERC-E -981 -616 365 0.9% SERC-N 1,502 2,169 667 1.7% SERC-SE 3,800 1,893 -1,907 -4.0% SERC-W 1,112 3,043 1,931 6.6% Southern California (CA L -3,761 -4,543 -782 -2.8% SPP 2,191 3,440 1,250 2.4%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

40 

### Appendix E: Tables by IPM Region for CPP Mass-Based Scenario in 2020
E1. Projected Operational Capacity
E2. Summary of Summer Peak Loads and Reserve Capacity

E3. Summary of Target and Projected Reserve Margins
E4. Policy Case Retired Capacity Incremental to Base Case
E5. New Capacity in Policy Case Incremental to Base Case
E6. Net Reserves Sent by NERC Assessment Region

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

41 

### E1. Projected Operational Capacity Year= 2025

All Generation Sources EE Capacity Overall Coal Only Region Base Policy Contribution Change Base Policy Basin (BASN) 14,293 12,687 687

‐ 919 4,802 3,345 Desert Southwest (DSW) 42,265 40,374 2,300 409 8,380 7,501 ERCOT 99,864 96,691 3,345 171 17,937 16,950 FRCC 56,336 55,647 2,080 1,391 7,479 7,131 ISO

‐ NE 32,685 30,497 1,644

‐ 545 0 0 MAPP 9,627 9,028 207

‐ 393 3,007 2,407 MISO 125,625 118,290 6,127

‐ 1,209 45,036 37,169 Northern California (CALN ) 29,389 27,278 1,321

‐ 791 71 17 Northwest (NORW) 51,181 48,752 2,036

‐ 393 2,406 1,513 NYISO 38,484 36,517 2,173 205 0 0 PJM 188,212 178,002 9,367

‐ 843 50,144 43,013 Rockies (Rock) 23,663 21,906 1,041

‐ 717 9,216 7,797 SERC

‐ E 55,904 52,622 2,556

‐ 727 11,045 10,907 SERC

‐ N 50,217 48,098 2,051

‐ 68 13,141 11,405 SERC

‐ SE 57,354 56,885 2,192 1,722 11,655 11,185 SERC

‐ W 40,012 38,007 1,069

‐ 936 4,733 3,918 Southern California (CALS) 43,405 39,745 2,159

‐ 1,501 57 57 SPP 78,704 74,286 2,733

‐ 1,685 22,966 18,522 Grand Total 1,037,223 985,310 45,085

‐ 6,828 212,075 182,836

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

42 E2. Summer Peak Loads and Reserve Capacity in 2025 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 12,466 11,856 14,036 13,349 Desert Southwest ( 31,887 29,861 36,192 33,892 ERCOT 77,606 74,665 88,276 84,932 FRCC 46,355 44,611 55,279 53,199 ISO-NE 26,701 25,272 30,706 29,063 MAPP 5,539 5,360 6,370 6,164 MISO 93,625 88,356 108,885 102,758 Northern California 22,305 21,155 25,592 24,301 Northwest (NORW ) 26,489 24,909 36,672 32,084 NYISO 30,051 28,179 34,860 32,687 PJM 154,841 146,724 178,686 169,319 Rockies (Rock) 15,223 14,315 17,676 16,412 SERC-E 44,263 42,040 50,902 48,346 SERC-N 40,450 38,666 46,517 44,466 SERC-SE 50,430 48,524 57,994 55,802 SERC-W 30,589 29,660 35,644 34,109 Southern California 29,473 27,604 34,006 31,897 SPP 54,332 51,927 62,673 58,997 US T otal 792,624 753,649 920,969 871,777

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

43 E3. Summary of Target and Projected Reserve Margins in 2025 Projected Reserve Margins

NERC Assessment Re g io n Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Policy Change from Base Basin (BASN) 12.60% 12.60% 12.60% 0.0% 0.0% Desert Southwest (DSW) 13.50% 13.50% 13.50% 0.0% 0.0% ERCOT 13.75% 13.75% 13.75% 0.0% 0.0% FRCC 19.25% 19.25% 19.25% 0.0% 0.0% ISO-NE 15.00% 15.00% 15.00% 0.0% 0.0% MAPP 15.00% 15.00% 15.00% 0.0% 0.0% MISO 16.30% 16.30% 16.30% 0.0% 0.0% Northern California ( CALN ) 14.71% 14.74% 14.87% 0.2% 0.1% Northwest (NORW) 17.90% 27.05% 25.96% 8.1% -1.1% NYISO 16.00% 16.00% 16.00% 0.0% 0.0% PJM 15.40% 15.40% 15.40% 0.0% 0.0% Rockies (Rock) 14.65% 16.12% 14.65% 0.0% -1.5% SERC-E 15.00% 15.00% 15.00% 0.0% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% 0.0% SERC-W 15.00% 16.52% 15.00% 0.0% -1.5% S outhern California ( CALS ) 15.14% 15.38% 15.55% 0.4% 0.2% SPP 13.60% 15.35% 13.62% 0.0% -1.7% Grand Total 15.29% 16.19% 15.67% 0.4% -0.5%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

44 E4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2025

CC Coal CT NU OG Steam Total Basin (BASN) 43 1,458 0 0 108 1,609 Desert Southwest (DS W 553 881 0 0 513 1,948 ERCOT 0 991 0 0 0 991 FRCC 148 348 0 0 288 784 ISO

‐ NE 0 0 0 0 1,910 1,910 MAPP 0 600 0 0 0 600 MISO 0 7,895 0

‐ 1,112 0 6,783 Northern California (C A 141 54 1,898 0 0 2,093 Northwest (NORW) 675 893 0 860 0 2,429 NYISO 81 0 0 109 1,330 1,520 PJM 0 7,134 0 0 367 7,501 Rockies (Rock) 0 1,421 0 0 0 1,421 SERC

‐ E 0 137 0 0 0 137 SERC

‐ N 0 1,753 0 0 0 1,753 SERC

‐ SE 0 470 0 0 0 470 SERC

‐ W

‐ 434 823 0 0 1,957 2,346 Southern California (C A 2 0 75 0 3,016 3,093 SPP

‐ 206 4,462 0

‐ 554 932 4,635 Grand Total 1,004 29,319 1,974

‐ 697 10,421 42,021

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

45 E5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2025 Region CC CT Wind Solar Other Total Basin (BASN) 0 0 3 0 0 3 Desert Southwest (DSW) 0 0 55 0 0 55 ERCOT

‐ 52

‐ 2,134 0 0 0

‐ 2,185 FRCC 94 0 0 0 0 94 ISO

‐ NE 0 0

‐ 265 0

‐ 13

‐ 278 MAPP 0 0 0 0 0 0 MISO

‐ 948 0 416

‐ 48 0

‐ 581 Northern California (CALN) 0 0

‐ 19 0 0

‐ 19 Northwest (NORW) 0 0 73 0

‐ 73 0 NYISO 0 0

‐ 448 0 0

‐ 448 PJM 1,447

‐ 2,094

‐ 1,933

‐ 133 0

‐ 2,713 Rockies (Rock) 0 0 0

‐ 375 37

‐ 338 SERC

‐ E

‐ 2,620 0 0

‐ 525 0

‐ 3,145 SERC

‐ N

‐ 383 0 0 0 0

‐ 383 SERC

‐ SE 0 0 0 0 0 0 SERC

‐ W 333 0 0 0 0 333 Southern California (CALS) 834 0

‐ 255

‐ 1,114

‐ 32

‐ 567 SPP 0 0

‐ 66

‐ 1 267 200 Grand Total

‐ 1,295

‐ 4,228

‐ 2,439

‐ 2,197 187

‐ 9,971

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

46 

### E6. Net Reserves Sent by NERC Assessment Region(MW) in 2025

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -2,052 -2,971 -919 -7.4% Desert Southwest (DS W 1,846 2,219 372 1.2% ERCOT -1,931 -1,760 172 0.2% FRCC 838 2,229 1,391 3.0% ISO-NE -2,009 -2,345 -337 -1.3% MISO -2,502 -4,422 -1,920 -1.9% Northern California (CAL -1,490 -2,298 -808 -3.6% Northwest (NORW) 3,345 5,486 2,141 8.1% NYISO 249 834 585 1.9% PJM -6,877 -6,098 779 0.5% Rockies (Rock) 1,419 1,175 -243 -1.6% SERC-E -402 -727 -325 -0.7% SERC-N 2,141 2,074 -68 -0.2% SERC-SE -1,213 509 1,722 3.4% SERC-W 3,806 3,330 -476 -1.6% Southern California (CA L -3,309 -3,860 -552 -1.9% SPP 3,631 2,846 -785 -1.4%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

47 

### Appendix F: Tables by IPM Region for CPP Mass-Based Scenario in 2020
F1. Projected Operational Capacity
F2. Summary of Summer Peak Loads and Reserve Capacity

F3. Summary of Target and Projected Reserve Margins
F4. Policy Case Retired Capacity Incremental to Base Case
F5. New Capacity in Policy Case Incremental to Base Case
F6. Net Reserves Sent by NERC Assessment Region

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

48 

### F1. Projected Operational Capacity Year= 2030

All Generation Sources EE Capacity Overall Coal Only Region Base Policy Contribution Change Base Policy Basin (BASN) 14,346 13,573 1,135 361 4,802 3,172 Desert Southwest (DSW) 42,265 40,844 3,911 2,490 8,380 7,115 ERCOT 107,231 113,686 6,856 13,312 17,937 16,619 FRCC 61,471 57,489 4,357 375 7,414 6,324 ISO

‐ NE 32,688 30,510 2,518 340 0 0 MAPP 9,627 9,288 464 125 3,007 2,171 MISO 126,164 117,707 9,389 931 45,036 35,626 Northern California (CALN ) 29,389 27,278 1,976

‐ 136 71 17 Northwest (NORW) 51,415 48,834 3,171 589 2,406 1,332 NYISO 39,032 35,605 3,220

‐ 207 0 0 PJM 203,408 185,441 15,258

‐ 2,709 50,129 39,667 Rockies (Rock) 24,105 24,184 1,777 1,855 9,216 7,657 SERC

‐ E 59,039 53,149 4,304

‐ 1,585 11,045 10,405 SERC

‐ N 52,505 49,374 3,916 785 13,141 10,953 SERC

‐ SE 60,658 56,487 4,470 298 11,655 10,221 SERC

‐ W 40,602 38,739 2,247 385 4,733 3,918 Southern California (CALS) 49,260 46,137 3,238 114 57 57 SPP 79,238 75,215 5,534 1,510 22,506 18,036 Grand Total 1,082,444 1,023,537 77,741 18,833 211,536 173,291

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

49 F2. Summer Peak Loads and Reserve Capacity in 2030 Projected Reserve Margins

Assessment Re g io n Peak Demand

Base Peak Demand

Polic y Reserve Capacity

Base Reserve Capacity

Polic y Basin (BASN) 12,961 11,953 14,594 13,459 Desert Southwest ( D 34,589 31,144 39,259 35,348 ERCOT 82,455 76,428 93,793 86,936 FRCC 49,145 45,491 58,606 54,248 ISO-NE 27,433 25,243 31,547 29,029 MAPP 5,732 5,329 6,592 6,128 MISO 96,428 88,354 112,145 102,756 Northern California 23,372 21,652 26,810 24,867 Northwest (NORW ) 27,515 25,057 33,947 32,335 NYISO 30,694 27,918 35,605 32,385 PJM 160,273 147,051 184,955 169,696 Rockies (Rock) 16,419 14,869 18,824 17,047 SERC-E 46,801 43,058 53,821 49,517 SERC-N 42,204 38,799 48,534 44,619 SERC-SE 52,944 49,057 60,886 56,416 SERC-W 32,436 30,482 37,301 35,054 Southern California 30,929 28,127 35,684 32,494 SPP 57,092 52,245 64,857 59,639 US T otal 829,421 762,235 957,760 881,975

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

50 F3. Summary of Target and Projected Reserve Margins in 2030 Projected Reserve Margins

NERC Assessment Re g io n Target Reserve Mar g in Base Case Polic y Case Policy % A bove Mar g i n Policy Change from Base Basin (BASN) 12.60% 12.60% 12.60% 0.0% 0.0% Desert Southwest (DSW) 13.50% 13.50% 13.50% 0.0% 0.0% ERCOT 13.75% 13.75% 13.75% 0.0% 0.0% FRCC 19.25% 19.25% 19.25% 0.0% 0.0% ISO-NE 15.00% 15.00% 15.00% 0.0% 0.0% MAPP 15.00% 15.00% 15.00% 0.0% 0.0% MISO 16.30% 16.30% 16.30% 0.0% 0.0% Northern California ( CALN ) 14.71% 14.71% 14.85% 0.1% 0.1% Northwest (NORW) 17.90% 23.38% 25.23% 7.3% 1.9% NYISO 16.00% 16.00% 16.00% 0.0% 0.0% PJM 15.40% 15.40% 15.40% 0.0% 0.0% Rockies (Rock) 14.65% 14.65% 14.65% 0.0% 0.0% SERC-E 15.00% 15.00% 15.00% 0.0% 0.0% SERC-N 15.00% 15.00% 15.00% 0.0% 0.0% SERC-SE 15.00% 15.00% 15.00% 0.0% 0.0% SERC-W 15.00% 15.00% 15.00% 0.0% 0.0% S outhern California ( CALS ) 15.14% 15.37% 15.53% 0.4% 0.2% SPP 13.60% 13.60% 14.15% 0.6% 0.6% Grand Total 15.28% 15.47% 15.71% 0.4% 0.2%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

51 F4. Policy Case Retired Capacity Incremental to the Base Case (MW) Year= 2030

CC Coal CT NU OG Steam Total Basin (BASN) 43 1,630 0 0 108 1,782 Desert Southwest (DS W 553 1,267 0 0 513 2,334 ERCOT 0 1,321 0 0 0 1,321 FRCC 148 1,089 0 0 288 1,525 ISO

‐ NE 0 0 0 0 1,910 1,910 MAPP 0 836 0 0 0 836 MISO 0 9,437 0

‐ 521 0 8,916 Northern California (C A 141 54 1,898 0 0 2,093 Northwest (NORW) 675 1,074 0 860 0 2,610 NYISO 81 0 0 1 1,330 1,412 PJM 0 10,469 0

‐ 1 367 10,835 Rockies (Rock) 0 1,561 0 0 0 1,561 SERC

‐ E 0 639 0 0 0 639 SERC

‐ N 0 2,205 0 0 0 2,205 SERC

‐ SE 0 1,433 0 0 0 1,433 SERC

‐ W

‐ 434 823 0 0 1,957 2,346 Southern California (C A 2 0 75 0 3,016 3,093 SPP

‐ 206 4,488 0

‐ 554 932 4,660 Grand Total 1,004 38,328 1,974

‐ 215 10,421 51,512

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

52 F5. New Capacity Policy Case Incremental to Base Case(MW) Year= 2030 Region CC CT Wind Solar Other Total Basin (BASN) 479 0 6 523 0 1,008 Desert Southwest (DSW) 0 0 57 853 0 911 ERCOT

‐ 4,378

‐ 5,173 0 17,325 0 7,773 FRCC

‐ 2,458 0 0 0 0

‐ 2,458 ISO

‐ NE 0 0

‐ 268 0 0

‐ 268 MAPP 0 0 497 0 0 497 MISO

‐ 543 0 1,054

‐ 80 0 431 Northern California (CALN) 0 0

‐ 19 0 0

‐ 19 Northwest (NORW) 0 0 28 0 0 28 NYISO

‐ 1,567 0

‐ 448 0 0

‐ 2,015 PJM

‐ 325

‐ 3,004

‐ 2,207

‐ 1,602 0

‐ 7,139 Rockies (Rock) 0 0 0 1,601 37 1,638 SERC

‐ E

‐ 4,418 0 0

‐ 833 0

‐ 5,250 SERC

‐ N

‐ 943 0 0 0 0

‐ 943 SERC

‐ SE

‐ 2,739 0 0 0 0

‐ 2,739 SERC

‐ W 476 0 0 0 0 476 Southern California (CALS) 117 0

‐ 255 79 29

‐ 30 SPP

‐ 505 0 859

‐ 2 267 619 Grand Total

‐ 16,804

‐ 8,177

‐ 696 17,864 334

‐ 7,479

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

53 

### F6. Net Reserves Sent by NERC Assessment Region(MW) in 2030

NERC Assessment Region Base Policy Change from Base to Policy Change as Percent of Summer Peak Basin (BASN) -2,563 -2,563 1 0.0% Desert Southwest (DS W -1,245 631 1,877 5.4% ERCOT -40 260 301 0.4% FRCC 2,646 3,021 375 0.8% ISO-NE -2,848 -2,282 567 2.1% MISO -5,473 -5,470 2 0.0% Northern California (CAL -2,709 -2,864 -154 -0.7% Northwest (NORW) 6,225 5,246 -979 -3.6% NYISO 26 301 275 0.9% PJM -5,123 -4,891 232 0.1% Rockies (Rock) 399 1,114 715 4.4% SERC-E -506 -1,455 -948 -2.0% SERC-N 2,412 3,197 785 1.9% SERC-SE -800 -503 298 0.6% SERC-W 2,732 3,122 390 1.2% Southern California (CA L -2,124 -1,859 264 0.9% SPP 1,933 2,389 456 0.8%

### Summary	of	Interagency	Working	Co mments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

54 

### Appendix C: Maps

C1. IPM Regions
C2. . NERC Assessment RegionsSummary	of	Interagency	Working	Comments	on	Draft	Language	underEO12866/13563	InteragencyReview.		Subject	to	Further	Policy	Review.55C1: IPM v5.13 RegionsSummary	of	Interagency	Working	Comments	on	Draft	Language	underEO12866/13563	InteragencyReview.		Subject	to	Further	Policy	Review.56C2:NERCAssessmentAreasinLongTermReliabilityAssessment.Source:NERC2012LongTermReliabilityAssessmentSummary	of	Interagency	Working	Comments	on	Draft	Language	underEO12866/13563	InteragencyReview.		Subject	to	Further	Policy	Review.57

# Summary	of	Interagency	Working	Com ments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

EPA’s Clean Power Plan Regu latory Impact Analysis

1. Reviewer recommends providing additional discussion related to the cost for EE on page 3- 15. Specifically, the costs for EE may be too high and thus overly conservative. To ensure completeness within the RIA, reviewer recomm ends providing a footnote after the sentence on 3-15: “The total levelized cost of saved en ergy was calculated based upon the same inputs and using a 3 percent discount ra te resulted in national average values of 9.2 cents per kWh in 2020, 8.6 cents per kWh in 2025, and 8.1 cents per kWh in 2030.”
a. The footnote should state: EPA has take n a conservative approach to avoid underestimating the costs of saved energy. This result is higher than what has been observed in many retrospective evaluations of energy efficiency cost effectiveness, implying actual costs may be significantly le ss. Estimates using the same method with large programs and the average of reviewed co sts would result in lower estimated costs of saved energy. Additionally, historical st udies reviewed in TSD Section 4.3.2 find program costs averaging between 2.1 - 3 cents /kWh (approximately 4.2 - 6 cents/kWh if individual costs are also included).