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GHG Abatement Measures Technical Support Document 

Chapter 4: Cleaner Generation Sources 

4.1. Introduction 

Renewable energy is a cost-effective approach for reducing carbon dioxide (CO2) emissions from 

fossil fuel-fired electric generating units (EGUs) through the substitution of electricity generated from 

renewable resources, referred to in this document as renewable energy (RE). The portfolio of available 

RE sources encompasses a wide variety of technologies from utility-scale RE plants to smaller-scale 

distributed generation sited at residential, commercial, or industrial facilities. RE technologies are fueled 

by the sun, wind, water, organic matter, and other resources regularly replenished by physical and 

biological cycles. To integrate the rapidly increasing and evolving portfolio of RE into the Best System of 

Emission Reductions (BSER), the EPA has developed a best practices scenario that builds upon current 

state policy encouraging increased production of RE taking into account renewable potential in particular 

regions of the country. 

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

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

CO2 emissions at fossil fuel-fired EGUs by providing carbon-free generation that can replace generation 

at those EGUs. Increasing the amount of nuclear capacity relative to the amount that would otherwise be 

available to operate is a technically viable and economically efficient approach for reducing CO2

emissions from affected fossil fuel-fired EGUs. 

This TSD is intended to support discussion of cleaner generation sources (RE and nuclear) as a 

component of BSER in the preamble (most extensively in these sections: Building Blocks for Setting 

State Goals and Considerations, State Goals, State Plans, and Impacts of the Proposed Rule) and its 

representation within the RIA. Results from this chapter feed into the technical support document (TSD) 

on state goal setting. Cleaner generation is also addressed in TSDs on Survey of Existing State Actions, 

State Plan Considerations, Projecting EGU CO2 Emission Performance, and Legal Memorandum. 

4.2. “Best Practices” RE Targets 

To estimate the potential RE available for inclusion as part of BSER the EPA developed a “best 

practices” RE generation scenario. The best practices scenario is derived from state experience with 

policies that drive investment in RE and the generation that results from those efforts. The EPA focused 

on state-level RE policy for several reasons. Every state in the union is producing electricity from 

renewable resources, and some states have achieved significant levels of renewable generation, surpassing 
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a quarter of in-state generation. State-level RE requirements have been implemented in 29 states plus 

Washington, DC, representing all regions of the country. Eight states have voluntary goals.1

 These statelevel goals and requirements have been developed and implemented with technical assistance from statelevel regulatory agencies and utility commissions such that they reflect expert assessments of RE 

technical and economic potential that can be cost-effectively developed for that state’s electricity 

consumers. 

The best practices scenario focuses on RE requirements established through Renewable Portfolio 

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

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

states as part of BSER, using the RPS-based targets as a reasonable benchmark of regionally costeffective RE generation which states could grow towards over time. While EPA’s best practices scenario 

is derived from RPS data, states may also consider a broad variety of other RE policies to increase 

generation, such as performance-based incentives, financial assistance programs, regulatory changes to 

facilitate the development of renewable sources and their interconnection to the grid and “lead by 

example” strategies integrating RE generation into state properties.2

 Because the EPA did not quantify 

potential that could be tapped through any of those policy approaches, the agency believes that the RE 

targets derived from RPS mandates represent a conservative estimate of cost-effective generation that 

could actually be developed by states. 

While future RPS requirements will necessitate more RE generation and capacity beyond current 

levels, the EPA does not expect the anticipated rate of growth required to meet those requirements to 

exceed the historical rate of RE deployment. Full compliance with current RPS requirements through 

2035 would necessitate the deployment of approximately 3 to 5 GW of new renewable capacity per year 

through 2020 and 2 to 3 GW through 2035. Average deployment of RPS-supported renewable capacity 

from 2007-2012 has exceeded 6 GW per year.3

 In addition, recent improvements in RPS compliance rates 

indicate to the EPA the reasonableness of current RPS growth trajectories. Weighted average compliance 

rates among all states have improved in each of the past three reported years (2008 - 2011) from 92.1 

percent to 95.2 percent despite a 40 percent increase in RPS obligations during this period.4

 As the 

 

1

 Map: Renewable Portfolio Standard Policies, www.dsireusa.org, March 2013, can be located at: 

http://www.dsireusa.org/summarymaps/. 

2

 See State Plan Considerations TSD for a discussion of how states can incorporate such RE policies into their state 

plans for this rule. 

3

 Barbose, Galen, “Renewables Portfolio Standards in the United States: A Status Update,” Lawrence Berkeley 

National Lab, November 2013. 

4

 http://emp.lbl.gov/rps, retrieved March 2014. The RPS compliance measure cited is inclusive of credit multipliers 

and banked RECs utilized for compliance, but excludes alternative compliance payments, borrowed RECs, deferred 
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Lawrence Berkeley National Laboratory (LBNL) RPS Status Update found, in the period 1998-2012, 

67% of all non-hydro U.S. RE capacity additions, totaling roughly 46,000 MW, was built in states with 

RPS requirements.5

This scenario provides an estimate of an achievable level of total RE generation within 

states. It does not represent an EPA forecast of business-as-usual impacts of state policies or an 

EPA estimate of the full potential of RE available to the power system; rather, it is intended to 

represent a feasible development scenario that enables reductions of CO2 emissions from fossil 

fuel-fired EGUs in all states and that is generally consistent with ongoing trends in RE 

development. The scenario uses a level of performance that has already been demonstrated or 

required by policies of leading states, while considering each state’s unique existing level of RE 

performance and allowing appropriate time for each state to increase from their current level of 

performance to the identified best practice level. In the context of this rulemaking, RE 

“performance” and RE targets are measured as the share of total generation represented by nonhydro renewables, as explained further below. 

The following steps were taken to establish the inputs for development of the best practice scenario 

for each state: 

4.2.1 Determine current level of performance 

4.2.2 Determine best practice level of performance 

4.2.3 Determine start year for state efforts 

4.2.4 Determine pace at which states improve from start year to best practice level of 

performance 

4.2.5 Calculate RE targets for interim and final state goals 

 

4.2.1 Determine current level of performance 

 obligations, and excess compliance. This estimate does not represent official compliance statistics, which vary in 

methodology by state. 

5

 Barbose, Galen, “Renewables Portfolio Standards in the United States: A Status Update,” Lawrence Berkeley 

National Lab, November 2013. Slide 8. 
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The type and extent of current RE capacity varies significantly across states, and is influenced by 

the renewable resources available, the economics of the power sector to date in different regions, and the 

state policies that affect renewable sources specifically and energy production generally. The extent of 

that generation has also changed rapidly in the past few years, and states with RE policies have 

significantly increased their renewable capacity. To characterize the current level of RE use, we have 

used the most current state-level data on generation: 2012 net generation data by state. 6 

Definitions of qualifying RE vary across state RPS requirements. For the sake of comparing RPS 

requirements in order to derive RE targets for each region, the EPA adopted a broad interpretation of RE 

generation to include any non-fossil renewable fuel type, with the exception of generation from existing 

hydroelectric power facilities. Large existing hydroelectric facilities provide a large percentage of RE 

generation in a few states, and inclusion of this generation in current and projected levels of performance 

would distort the best practices scenario by presuming future development potential of large hydroelectric 

capacity in other states. These types of facilities have not been the focus of most RPS policies, and many 

RPS policies specifically exclude their use in compliance. No states are expected to significantly increase 

generation from existing large hydropower facilities nor develop any new large facilities. 7 The analysis of 

potential informing regional RE targets does not explicitly account for the potential of building new 

smaller hydroelectric facilities as a source under RPS policies; however, generation from such facilities 

would not be excluded from compliance with a state’s goal under this rule. 

The most recent 2012 performance data is shown in Table 4-1. Consistent with the design of a 

number RPS policies, RE “performance” is measured here as the share of total generation represented 

by non-hydro RE. 

Table 4-1. 2012 RE Performance by State 

State Non-Hydro RE 

Generation

Total 

Generation

Performance 

Level 

 Alabama 2,776,554 152,878,688 2% 

 Alaska 39,958 6,946,419 1% 

 Arizona 1,697,652 110,904,994 2% 

 Arkansas 1,660,370 65,005,678 3% 

 California 29,966,846 199,518,567 15% 

 Colorado 6,192,082 52,556,701 12% 

 

6

 U.S. EIA state level data available at http://www.eia.gov/electricity/data/state/. 7

 U.S. EIA, Annual Energy Outlook 2014, p. 121, available at 

http://www.eia.gov/forecasts/archive/aeo13/index.cfm.. 
DRAFT DELIBERATIVE 11 April 2014 

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 Connecticut 666,525 36,117,544 2% 

 Delaware 131,051 8,633,694 2% 

District of Columbia8 - 71,787 0% 

 Florida 4,523,798 221,096,136 2% 

 Georgia 3,278,536 122,306,364 3% 

 Hawaii 924,815 10,469,269 9% 

 Idaho 2,514,502 15,499,089 16% 

 Illinois 8,372,660 197,565,363 4% 

 Indiana 3,546,367 114,695,729 3% 

 Iowa 14,183,424 56,675,404 25% 

 Kansas 5,252,653 44,424,691 12% 

 Kentucky 332,879 89,949,689 0% 

 Louisiana 2,430,042 103,407,706 2% 

 Maine 4,098,795 14,428,596 28% 

 Maryland 898,152 37,809,744 2% 

 Massachusetts 1,843,419 36,198,121 5% 

 Michigan 3,785,439 108,166,078 3% 

 Minnesota 9,453,871 52,193,624 18% 

 Mississippi 1,509,190 54,584,295 3% 

 Missouri 1,298,579 91,804,321 1% 

 Montana 1,261,752 27,804,784 5% 

 Nebraska 1,346,762 34,217,293 4% 

 Nevada 2,968,630 35,173,263 8% 

 New Hampshire 1,381,285 19,264,435 7% 

 New Jersey 1,280,715 65,263,408 2% 

 New Mexico 2,573,851 36,635,909 7% 

 New York 5,192,427 135,768,251 4% 

 North Carolina 2,703,919 116,681,763 2% 

 North Dakota 5,280,052 36,125,159 15% 

 Ohio 1,738,622 129,745,731 1% 

 Oklahoma 8,520,724 77,896,588 11% 

 Oregon 7,207,229 60,932,715 12% 

 Pennsylvania 4,459,118 223,419,715 2% 

 Rhode Island 101,895 8,309,036 1% 

 South Carolina 2,143,473 96,755,682 2% 

 South Dakota 2,914,666 12,034,206 24% 

 Tennessee 836,458 77,724,264 1% 

 

8

 The District of Columbia has no utility-scale RE generation, but the District does have distributed RE resources 

contributing to the electrical grid. It can also be noted that the non-RE generation reported closed in 2012, so the 

District of Columbia no longer has any utility-scale generation. 
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 Texas 34,016,697 429,812,510 8% 

 Utah 1,099,724 39,402,961 3% 

 Vermont 465,169 6,569,670 7% 

 Virginia 2,358,444 70,739,235 3% 

 Washington 8,214,350 116,835,474 7% 

 West Virginia 1,296,563 73,413,405 2% 

 Wisconsin 3,223,178 63,742,910 5% 

 Wyoming 4,369,107 49,588,606 9% 

4.2.2 Determine best practice level of performance 

Achievable RE potential exists at significant and comparable levels in all regions of the country. 

While varied regional characteristics (e.g., the extent of renewable resources available, cost of competing 

sources of power, and level of past RE development) affect estimates of achievable potential, ongoing 

improvements in technologies and practices, and continually improving strategies for RE development are 

increasing the extent of economically utilized renewable resources across all regions of the United States. 

RE has been capturing a growing percentage of new capacity additions in the past few years. In 2012, RE 

accounted for more than 56% of all new electrical capacity installations in the U.S. – a major increase 

from 2004 when renewable installations captured only 2% of new capacity additions.9

 The economics of 

the fastest growing RE technologies – on-shore wind and solar photovoltaics (PV) – are improving. In 

2012, cumulative installed wind capacity increased by nearly 28% and cumulative installed solar PV 

capacity grew more than 83% from the previous year.10 In the United States, installed wind electricity 

capacity increased more than 23 fold between 2000 and 2012.11 Solar electricity generating capacity grew 

by a factor of over 21 between 2000 and 2012 and currently accounts for 0.3% of annual U.S. electricity 

generation.12 The National Renewable Energy Laboratory (NREL) has also found that the continental 

U.S. has solar potential that exceeds high solar generating countries like Germany, which now has the 

capacity to generate over 6% of their electricity from solar.13 Looking forward, the U.S. Department of 

Energy has found that 46 states would have substantial wind development by 2030 under a scenario in 

 

9

 U.S. Department of Energy. 2012 Renewable Energy Data Book. DOE/GO-102013-4291.October 2013. p. 3. 

10 U.S. Department of Energy. 2012 Renewable Energy Data Book. DOE/GO-102013-4291.October 2013. p. 18. 

11 Ibid. p. 53. 

12 Ibid. p. 63. 

13 NREL. Photovoltaic Solar Resource: The United States, Spain and Germany. 2009. Available at: 

http://www.nrel.gov/gis/images/us_germany_spain/pvmap_usgermanyspain%20poster-01.jpg. Also IEA. PVPS 

Snapshot of Global PV 1992-2013. Report IEA-PVPS T1-24:2014, March 31, 2014. http://www.ieapvps.org/fileadmin/dam/public/report/statistics/PVPS_report_-_A_Snapshot_of_Global_PV_-_1992-2013_-

_final_3.pdf. 
DRAFT DELIBERATIVE 11 April 2014 

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which 20% of national generation is provided by wind. The distribution of that deployment is shown in 

Figure 4.1.14 

The best practices scenario is also based upon an analysis of renewable portfolio standards, a 

policy that facilitates the quantification of RE targets. By only examining the impact of one type of 

policy, the analysis is inherently conservative, as many other policy options are also available to states in 

addition to RPS. 

Figure 4.1. DOE Projected Installed Wind Capacity by State under 20% National Generation 

Scenario 

 

4.2.2.1. Quantification of Effective RE Levels from State-Level RPS Requirements 

In order to apply the various RPS policies to the development of a best practice level of 

performance, the EPA used publicly-available quantitative information about mandatory state RPS 

requirements from the Database for State Incentives for Renewables and Efficiency (DSIRE).15 This 

 

14 U.S. Department of Energy. 20% Wind Energy by 2030: Increasing Wind Energy’s Contribution to U.S. 

Electricity Supply – Executive Summary. December 2008. http://www.nrel.gov/docs/fy09osti/42864.pdf. 15 Database of State Incentives for Renewables & Efficiency (DSIRE) is a very comprehensive source of 

information on incentives and policies that support renewables and energy efficiency in the United States. DSIRE is 

currently operated by the N.C. Solar Center at N.C. State University, with support from the Interstate Renewable 

Energy Council, Inc. DSIRE is funded by the U.S. Department of Energy. http://www.dsireusa.org/. 
DRAFT DELIBERATIVE 11 April 2014 

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information enabled the EPA to determine the effective RE levels in 2020 for states with mandatory RPS 

requirements.16 

DSIRE provides regularly-updated RPS Data Spreadsheets that detail state RPS requirements by 

year, resources, and other key component parts.17 The RPS compliance schedules are broken down into 

the specific annual percentages requirements for the years 2000 to 2030. Many states have multiple 

compliance requirements, including the main percentage requirements for eligible resources and 

additional resource-specific percentage requirements that states are increasingly using to promote the 

development of a particular set of resources or technologies (e.g., solar PV). DSIRE called each of these 

sets of resource requirements “tiers” and applied a standardized approach to them, “in order to compare 

RPS policies on equal footing.”18 The benefit of this approach is that state resource requirements become 

additive and facilitate a process of selection and exclusion. The EPA added together each state’s tiers, as 

standardized by DSIRE, to determine states’ effective RE levels for 2020, but excluded tiers, other than 

main tiers, that include energy efficiency or any fossil fuel. 

In addition, six states have established more than one set of RPS requirements for in-state 

utilities, including “secondary” and “tertiary” RPS requirements for smaller utilities, municipal utilities, 

or cooperative utilities. The EPA only included the primary RPS requirements to simplify the analysis of 

primary and secondary RPS requirements in determining states’ effective RE levels for 2020. By only 

considering primary requirements, there is additional inherent conservatism in the RPS estimates, as 

additional state-level RPS obligations are not included in the calculated targets. 

 

 

16 EPA did not include targets that were capacity-based. 17 DSIRE. RPS Data Spreadsheet. April 2013 version. http://www.dsireusa.org/rpsdata/index.cfm. 

18 DSIRE. DSIRE RPS Field Definitions. April 2011. 

http://www.dsireusa.org/rpsdata/RPSFieldDefinitionsApril2011.pdf. p. 1. 
DRAFT DELIBERATIVE 11 April 2014 

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Figure 4.2 RPS Data Structure19

 

The RPS compliance schedules in six states implement maximum requirements prior to 2020; 

their effective RE levels for 2020 are set to those maximum levels. In fact, most states maintain their 

percentage requirements indefinitely. 

TABLE 4.2. Effective RE Levels Derived from RPS Requirements 

RPS 

States 

Primary 

Target 

Target 

Year 

2020 

Effective 

RE 

Levels 

Exclusions 

AZ 15% 2025 10% 

CA 33% 2020 33% 

CO 30% 2020 30% Secondary RPS requirement 

CT 23% 2020 23% Class 3 includes non-RE 

DC 20% 2023 20% 

DE 25% 2027 19% 

HI 40% 2030 25% 

IL 25% 2025 16% Secondary RPS requirement 

KS 20% 2020 20% 

 

19 DSIRE. RPS Data Spreadsheet. April 2013 version.
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MA 33% 2030 22% 

MD 20% 2022 18% 

ME 40% 2017 40% 

MI 10% 2015 10% 

MN 30% 2020 30% Secondary RPS requirement 

MO 15% 2021 10% 

MT 15% 2015 15% 

NC 13% 2021 10% Secondary RPS requirement 

NH 25% 2025 20% 

NJ 24% 2021 22% 

NM 20% 2020 20% Secondary RPS requirement 

NV 25% 2025 22% 

NY 29% 2015 29% 

OH 13% 2024 9% 

OR 25% 2025 20% Secondary & tertiary RPS 

requirements 

PA 8% 2021 8% Class 2 includes non-RE 

RI 16% 2019 16% 

WA 15% 2020 15% 

WI 10% 2015 10% 

4.2.2.2. Development of Regional RE Generation Targets from State-level Effective RE Levels 

To take into account the varied availability of different renewable resources across regions of the 

United States, the EPA uses the state-level effective RE levels derived from RPS requirements to quantify 

regional RE targets consistent with states’ best practice in RE development. This methodology helps us to 

quantify RE potential in states which do not have an RPS policy from which the renewable resource 

potential can be inferred. Specifically, the scenario estimates each region’s RE potential by assuming all 

states in each region can achieve by 2030 the average of the 2020 requirements of RPS states in that 

region. 

The regions assigned to states to quantify their RE generation target are based upon North 

American Electric Reliability Corporation (NERC) regions and Regional Transmission Organizations 

(RTOs) and are the same as the regions used in the modeling of the “regional” compliance scenarios as 

outlined in the proposal RIA (see Figure 4-3).20 States within each region exhibit similar profiles of RE 

potential or have similar levels of renewable resources. The regional similarities can be inferred from the 

 

20 For more information on the structure of these regions, please refer to the Regulatory Impact Analysis Chapter 3. 
DRAFT DELIBERATIVE 11 April 2014 

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state-level technical potential reported in an NREL GIS-based analysis.21 The results show clear trends for 

the regions used to create the best practices scenario, with portfolios of particular technologies showing 

clear dominance in specific regions. North Central and South Central regions have strong on-shore wind 

resource potential. The East Central and Southeast regions show moderate to strong resources in both 

biopower and rooftop PV potential. The West has unique potential in geothermal (hydrothermal) power 

and concentrating solar power. The Northeast has strong resources in off-shore wind and moderate 

biopower and solar resources available. It should be noted that high technical potential in a particular 

renewable resource is not necessarily needed to reach the generation levels called for in this proposal. For 

example, Maine produced 28% of its electricity generation in 2012 from biopower and onshore wind, 

while it is estimated in this report to have moderate technical potential for biopower and low levels of 

onshore wind capacity. 

Figure 4.3. Regions for Development of Best Practices RPS Scenario 

 

21 NREL. U.S. Renewable Energy Technical Potentials: A GIS-Based Analysis. NREL/TP-A20-51946. July 2012. 

http://www.nrel.gov/docs/fy12osti/51946.pdf.
DRAFT DELIBERATIVE 11 April 2014 

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Table 4.3. List of States Included in Regions for Development of RE Best Practices Scenario22 

Region States 

East Central Delaware, District of Columbia, Maryland, New Jersey, Ohio, Pennsylvania, 

Virginia, West Virginia 

North Central Illinois, Indiana, Iowa, Michigan, Minnesota, Missouri, North Dakota, South 

Dakota, Wisconsin 

Northeast Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode 

Island, Vermont 

South Central Arkansas, Kansas, Louisiana, Nebraska, Oklahoma, Texas 

Southeast Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South 

Carolina, Tennessee 

West Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, 

Oregon, Utah, Washington, Wyoming 

The EPA compiled the state-level effective RE levels derived above, organized them by region, 

and determined an average percent generation target for that region. This average did not include any 

values for states in which there is no binding RPS requirement. This average regional RE generation 

target offers a basis for the determination of state-level RE targets for informing state goals, as described 

below. Given their unique locations, Alaska and Hawaii are not grouped with other states into these 

regions. As a conservative approach to estimating cost-effective RE generation potential in Alaska and 

Hawaii, the EPA developed RE generation targets for each of those states based on the lowest values for 

the six regions evaluated here, equivalent to the regional target for the Southeast region. 

 

 

22 Alaska and Hawaii are not grouped with other states into regions. 
DRAFT DELIBERATIVE 11 April 2014 

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Table 4.4. Regional RE Generation Targets 

Region 

Regional RE 

Generation Targets

Alaska 10% 

East Central 16% 

Hawaii 10% 

Northeast 25% 

North Central 15% 

South Central 20% 

Southeast 10% 

West 21% 

4.2.3 Determine start year for state efforts 

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

following the initial state plan submission deadline23, and continues through 2029, by which time the EPA 

assumes the regions can achieve the identified regional RE target level of performance. The EPA has set 

each state’s level of performance prior to the start year of the scenario (2017) to be equal to its current 

level of performance (as shown above using 2012 generation data). This approach assumes neither 

improvement nor decline in performance between 2012 and 2017. 

4.2.4 Determine pace at which states improve from start year to best practice level of performance 

In order to account for the time needed to plan and construct the required additional amounts of 

renewable capacity, the best practices scenario assumes an increasing trend over time of annual levels of 

RE generation that can carry the start year performance level of each region (in 2017, assumed to be 

equivalent to its 2012 observed performance level) to that region’s RE generation target by 2029. This 

2017-2029 trend yields an annual growth factor that is unique to each region and based upon each 

region’s current renewable generation level and its RE target level identified above. 

 

23 See Preamble Section 8.E – Process for State Plan Submittal and Review for further discussion of timing 

requirements for state plan submittals. 
DRAFT DELIBERATIVE 11 April 2014 

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To derive the annual growth factor, the EPA determined the amount of additional renewable 

generation (in megawatt-hours) that would be required beyond each region’s historic (2012) generation to 

reach that region’s RE target. The EPA then determined the constant rate at which each region would 

need to increase its generation each year to reach the regional RPS target, if these rates are applied in the 

period 2017-2029. The constant rate of annual RE generation increase calculated from this approach is 

called the growth factor in this context. Due to their unique location, the EPA used a different method to 

calculate growth factors for Alaska and Hawaii, calculating an annual growth factor based on the 

difference between both states’ historical 2005 and 2012 RE generation. Growth factors for each region 

are provided in Table 4.5. 

Table 4.5. Regional Annual RE Growth Factors 

Region Growth Factor 

Alaska 8%

East Central 17%

Hawaii 8%

North Central 6%

Northeast 10%

South Central 8%

Southeast 13%

West 6%

Then, for all states in a given region, that region’s annual growth factor was applied to each 

state’s historic (2012) RE generation level to calculate a new level of RE generation for that state in the 

initial year (2017). This calculation is then repeated for each year in the 2017-2029 time period. If, as the 

growth factor is applied annually, a state reaches an RE generation level that equals or exceeds the 

regional RE percent generation target, their RE generation target is made equal to the RE percent 

generation target and is no longer grown over the remainder of the time period. If a state’s RE generation 

in 2012 has already exceeded the regional RE target, their annual RE generation levels are held to the 

regional RE target for all years in the 2017-2029 time period. For all other states, the annual growth factor 

is applied through 2029. These annual RE generation estimates represent the realization of the best 

practice scenario for each state. These RE generation levels are provided in absolute and percentage 

(share of total generation) terms in Table 4.6 and Table 4.7. 

This approach imposes the same regional RE target in percentage (share of total generation) terms 

to all states in a given region; therefore, the absolute megawatt-hour target will be smaller for states 
DRAFT DELIBERATIVE 11 April 2014 

15 

starting with a lower absolute amount of RE generation and larger for a state starting with a higher 

absolute amount of RE generation. 

This approach applies the calculated growth factors and regional RE targets to state-level 

generation, whereas the state-level RPS requirements upon which they are based are not necessarily 

applied in practice to generation that is produced within the relevant state. However, the EPA notes that 

state-level RPS policies are often established with the aim of developing in-state renewables generation.24

This intention is evident in RPS policies that include minimum requirements for specific types of 

renewable resources whose development is desired in that state. Regional analysis by NREL has also 

shown that many states in the west are satisfying RPS requirements with in-state generation.25

Furthermore, the regional RE target is not applied directly as an immediate requirement of each state but 

is instead used to calculate a regional growth factor that is then applied to each state’s pre-existing RE 

generation, such that historic RE performance acts as a limiting factor on the extent to which a state is 

assumed to reach the regional target. Over the program period, several states do not reach the RE 

percentage target in the best practices scenario, such as Kentucky in the Southeast and Nevada in the 

West. Thus, this approach is designed to respect each state’s ability to improve toward the RE targets 

developed above. 

Table 4.6. State Best Practice RE Generation Levels (Thousand Megawatt-hours) 

State Historic 

RE Best Practice RE Generation Levels (thousand MWh) 

2012 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 

 AK 

40 43 47 50 54 58 63 68 73 79 85 92 100 107 

 AL 

2,777 

 

3,150 

 

3,573 

 

4,053 

 

4,597 

 

5,214 

 

5,915 

 

6,709 

 

7,611 

 

8,633 

 

9,793 

 

11,108 

 

12,600 

 

14,293 

 AR 

1,660 

 

1,799 

 

1,949 

 

2,112 

 

2,288 

 

2,479 

 

2,686 

 

2,911 

 

3,154 

 

3,417 

 

3,702 

 

4,011 

 

4,346 

 

4,709 

 AZ 

1,698 

 

1,807 

 

1,924 

 

2,048 

 

2,181 

 

2,322 

 

2,472 

 

2,632 

 

2,802 

 

2,983 

 

3,175 

 

3,381 

 

3,599 

 

3,832 

 CA 

29,967 

 

31,903 

 

33,965 

 

36,160 

 

38,497 

 

40,984 

 

41,151 

 

41,151 

 

41,151 

 

41,151 

 

41,151 

 

41,151 

 

41,151 

 

41,151 

 CO 

6,192 

 

6,592 

 

7,018 

 

7,472 

 

7,955 

 

8,469 

 

9,016 

 

9,598 

 

10,219 

 

10,840 

 

10,840 

 

10,840 

 

10,840 

 

10,840 

 CT 

667 

 

750 

 

845 

 

951 

 

1,071 

 

1,206 

 

1,358 

 

1,529 

 

1,721 

 

1,938 

 

2,182 

 

2,457 

 

2,766 

 

3,114 

 DE 

131 

 

154 

 

180 

 

211 

 

248 

 

291 

 

341 

 

399 

 

468 

 

549 

 

644 

 

755 

 

886 

 

1,038 

 FL 

 

24 Wiser, Ryan H., and Galen L. Barbose. 2008. Renewable Portfolio Standards in the United States: A Status 

Report with Data Through 2007. LBNL-154E. Berkeley, CA: Lawrence Berkeley National Laboratory, p. 7. 25 Hurlbut, David, Joyce McLaren, and Rachel Gelman. Beyond Renewable Portfolio Standards: An Assessment of 

Regional Supply and Demand Conditions Affecting the Future of Renewable Energy in the West. NREL/TP-6A20-

57830. Golden, CO: NREL, August 2013. 
DRAFT DELIBERATIVE 11 April 2014 

16 

4,524 5,131 5,821 6,603 7,490 8,496 9,637 10,931 12,400 14,066 15,955 18,098 20,529 22,110 

 
DRAFT DELIBERATIVE 11 April 2014 

17 

 GA 

3,279 

 

3,719 

 

4,219 

 

4,785 

 

5,428 

 

6,157 

 

6,984 

 

7,922 

 

8,987 

 

10,194 

 

11,563 

 

12,231 

 

12,231 

 

12,231 

 HI 

925 998 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 1,047 

 IA 

14,183 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 

8,566 

 ID 

2,515 

 

2,677 

 

2,850 

 

3,034 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 

3,197 

 IL 

8,373 

 

8,873 

 

9,404 

 

9,967 

 

10,563 

 

11,195 

 

11,864 

 

12,574 

 

13,326 

 

14,123 

 

14,968 

 

15,863 

 

16,812 

 

17,818 

 IN 

3,546 

 

3,758 

 

3,983 

 

4,222 

 

4,474 

 

4,742 

 

5,025 

 

5,326 

 

5,645 

 

5,982 

 

6,340 

 

6,719 

 

7,121 

 

7,547 

 KS 

5,253 

 

5,691 

 

6,166 

 

6,681 

 

7,239 

 

7,843 

 

8,498 

 

8,885 

 

8,885 

 

8,885 

 

8,885 

 

8,885 

 

8,885 

 

8,885 

 KY 

333 

 

378 

 

428 

 

486 

 

551 

 

625 

 

709 

 

804 

 

912 

 

1,035 

 

1,174 

 

1,332 

 

1,511 

 

1,714 

 LA 

2,430 

 

2,633 

 

2,853 

 

3,091 

 

3,349 

 

3,629 

 

3,931 

 

4,260 

 

4,615 

 

5,001 

 

5,418 

 

5,870 

 

6,361 

 

6,892 

 MA 

1,843 

 

2,076 

 

2,337 

 

2,631 

 

2,962 

 

3,335 

 

3,755 

 

4,228 

 

4,761 

 

5,360 

 

6,035 

 

6,795 

 

7,650 

 

8,613 

 MD 

898 

 

1,053 

 

1,235 

 

1,448 

 

1,698 

 

1,991 

 

2,335 

 

2,738 

 

3,210 

 

3,764 

 

4,414 

 

5,176 

 

5,982 

 

5,982 

 ME 

4,099 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 

3,612 

 MI 

3,785 

 

4,012 

 

4,252 

 

4,506 

 

4,776 

 

5,061 

 

5,364 

 

5,685 

 

6,025 

 

6,385 

 

6,767 

 

7,172 

 

7,601 

 

8,056 

 MN 

9,454 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 

7,889 

 MO 

1,299 

 

1,376 

 

1,459 

 

1,546 

 

1,638 

 

1,736 

 

1,840 

 

1,950 

 

2,067 

 

2,190 

 

2,322 

 

2,460 

 

2,608 

 

2,764 

 MS 

1,509 

 

1,712 

 

1,942 

 

2,203 

 

2,499 

 

2,834 

 

3,215 

 

3,647 

 

4,137 

 

4,692 

 

5,323 

 

5,458 

 

5,458 

 

5,458 

 MT 

1,262 

 

1,343 

 

1,430 

 

1,523 

 

1,621 

 

1,726 

 

1,837 

 

1,956 

 

2,082 

 

2,217 

 

2,360 

 

2,513 

 

2,675 

 

2,848 

 NC 

2,704 

 

3,067 

 

3,479 

 

3,946 

 

4,477 

 

5,078 

 

5,760 

 

6,534 

 

7,412 

 

8,407 

 

9,536 

 

10,817 

 

11,668 

 

11,668 

 ND 

5,280 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 

5,460 

 NE 

1,347 

 

1,459 

 

1,581 

 

1,713 

 

1,856 

 

2,011 

 

2,179 

 

2,361 

 

2,558 

 

2,771 

 

3,003 

 

3,254 

 

3,525 

 

3,819 

 NH 

 

1,381 

 

1,555 

 

1,751 

 

1,971 

 

2,220 

 

2,499 

 

2,814 

 

3,168 

 

3,567 

 

4,016 

 

4,522 

 

4,822 

 

4,822 

 

4,822 

 NJ 

 

1,281 

 

1,502 

 

1,761 

 

2,065 

 

2,421 

 

2,839 

 

3,329 

 

3,904 

 

4,577 

 

5,367 

 

6,294 

 

7,380 

 

8,654 

 

10,147 

 NM 

 

2,574 

 

2,740 

 

2,917 

 

3,106 

 

3,306 

 

3,520 

 

3,748 

 

3,990 

 

4,248 

 

4,522 

 

4,814 

 

5,125 

 

5,457 

 

5,809 

 NV 

 

2,969 

 

3,160 

 

3,365 

 

3,582 

 

3,814 

 

4,060 

 

4,322 

 

4,602 

 

4,899 

 

5,216 

 

5,553 

 

5,912 

 

6,294 

 

6,700 

 NY 

 

5,192 

 

5,846 

 

6,582 

 

7,411 

 

8,344 

 

9,395 

 

10,578 

 

11,910 

 

13,409 

 

15,098 

 

16,999 

 

19,139 

 

21,549 

 

24,262 

 OH 

 

1,739 

 

2,039 

 

2,391 

 

2,803 

 

3,287 

 

3,854 

 

4,519 

 

5,299 

 

6,214 

 

7,287 

 

8,544 

 

10,019 

 

11,748 

 

13,776 

 OK 

8,521 

 

9,232 

 

10,003 

 

10,838 

 

11,743 

 

12,723 

 

13,785 

 

14,936 

 

15,579 

 

15,579 

 

15,579 

 

15,579 

 

15,579 

 

15,579 

 OR 

7,207 

 

7,673 

 

8,169 

 

8,697 

 

9,259 

 

9,857 

 

10,494 

 

11,172 

 

11,894 

 

12,567 

 

12,567 

 

12,567 

 

12,567 

 

12,567 

 PA 

4,459 

 

5,229 

 

6,131 

 

7,189 

 

8,430 

 

9,885 

 

11,591 

 

13,592 

 

15,938 

 

18,688 

 

21,914 

 

25,696 

 

30,131 

 

35,331 

 RI 

102 

 

115 

 

129 

 

145 

 

164 

 

184 

 

208 

 

234 

 

263 

 

296 

 

334 

 

376 

 

423 

 

476 

 SC 

2,143 

 

2,431 

 

2,758 

 

3,128 

 

3,549 

 

4,025 

 

4,566 

 

5,180 

 

5,875 

 

6,665 

 

7,560 

 

8,575 

 

9,676 

 

9,676 

 SD 

2,915 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 

1,819 

 TN 

836 

 

949 

 

1,076 

 

1,221 

 

1,385 

 

1,571 

 

1,782 

 

2,021 

 

2,293 

 

2,601 

 

2,950 

 

3,346 

 

3,796 

 

4,306 

 TX 

34,017 

 

36,857 

 

39,934 

 

43,268 

 

46,880 

 

50,794 

 

55,034 

 

59,629 

 

64,607 

 

70,001 

 

75,845 

 

82,177 

 

85,963 

 

85,963 
DRAFT DELIBERATIVE 11 April 2014 

18 

 UT 

1,100 

 

1,171 

 

1,246 

 

1,327 

 

1,413 

 

1,504 

 

1,601 

 

1,705 

 

1,815 

 

1,932 

 

2,057 

 

2,190 

 

2,331 

 

2,482 

 VA 

2,358 

 

2,765 

 

3,243 

 

3,802 

 

4,459 

 

5,228 

 

6,131 

 

7,189 

 

8,429 

 

9,884 

 

11,192 

 

11,192 

 

11,192 

 

11,192 

 VT 

465 

 

524 

 

590 

 

664 

 

748 

 

842 

 

948 

 

1,067 

 

1,201 

 

1,353 

 

1,523 

 

1,645 

 

1,645 

 

1,645 

 WA 

8,214 

 

8,745 

 

9,310 

 

9,912 

 

10,552 

 

11,234 

 

11,960 

 

12,733 

 

13,556 

 

14,432 

 

15,365 

 

16,358 

 

17,415 

 

18,540 

 WI 

3,223 

 

3,416 

 

3,620 

 

3,837 

 

4,066 

 

4,310 

 

4,567 

 

4,841 

 

5,130 

 

5,437 

 

5,762 

 

6,107 

 

6,472 

 

6,859 

 WV 

1,297 

 

1,520 

 

1,783 

 

2,090 

 

2,451 

 

2,874 

 

3,370 

 

3,952 

 

4,634 

 

5,434 

 

6,372 

 

7,471 

 

8,761 

 

10,273 

 WY 

4,369 

 

4,651 

 

4,952 

 

5,272 

 

5,613 

 

5,975 

 

6,362 

 

6,773 

 

7,210 

 

7,676 

 

8,172 

 

8,700 

 

9,263 

 

9,861 

Table 4.7. State Best Practice RE Generation Levels (% of Total Generation) 

State 

Historic 

RE Best Practice RE Generation Levels 

2012 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 

 AK 0.6% 0.6% 0.7% 0.7% 0.8% 0.8% 0.9% 1.0% 1.1% 1.1% 1.2% 1.3% 1.4% 1.5% 

 AL 2% 2.1% 2.3% 2.7% 3.0% 3.4% 3.9% 4.4% 5.0% 5.6% 6.4% 7.3% 8.2% 9.3% 

 AR 3% 2.8% 3.0% 3.2% 3.5% 3.8% 4.1% 4.5% 4.9% 5.3% 5.7% 6.2% 6.7% 7.2% 

 AZ 2% 1.6% 1.7% 1.8% 2.0% 2.1% 2.2% 2.4% 2.5% 2.7% 2.9% 3.0% 3.2% 3.5% 

 CA 15% 16.0% 17.0% 18.1% 19.3% 20.5% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 

 CO 12% 12.5% 13.4% 14.2% 15.1% 16.1% 17.2% 18.3% 19.4% 20.6% 20.6% 20.6% 20.6% 20.6% 

 CT 2% 2.1% 2.3% 2.6% 3.0% 3.3% 3.8% 4.2% 4.8% 5.4% 6.0% 6.8% 7.7% 8.6% 

 DE 2% 1.8% 2.1% 2.4% 2.9% 3.4% 3.9% 4.6% 5.4% 6.4% 7.5% 8.7% 10.3% 12.0% 

 FL 2% 2.3% 2.6% 3.0% 3.4% 3.8% 4.4% 4.9% 5.6% 6.4% 7.2% 8.2% 9.3% 10.0% 

 GA 3% 3.0% 3.4% 3.9% 4.4% 5.0% 5.7% 6.5% 7.3% 8.3% 9.5% 10.0% 10.0% 10.0% 

 HI 9% 9.5% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 

 IA 25% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 

 ID 16% 17.3% 18.4% 19.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 20.6% 

 IL 4% 4.5% 4.8% 5.0% 5.3% 5.7% 6.0% 6.4% 6.7% 7.1% 7.6% 8.0% 8.5% 9.0% 

 IN 3% 3.3% 3.5% 3.7% 3.9% 4.1% 4.4% 4.6% 4.9% 5.2% 5.5% 5.9% 6.2% 6.6% 

 KS 12% 12.8% 13.9% 15.0% 16.3% 17.7% 19.1% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0% 

 KY 0% 0.4% 0.5% 0.5% 0.6% 0.7% 0.8% 0.9% 1.0% 1.2% 1.3% 1.5% 1.7% 1.9% 

 LA 2% 2.5% 2.8% 3.0% 3.2% 3.5% 3.8% 4.1% 4.5% 4.8% 5.2% 5.7% 6.2% 6.7% 

 MA 5% 5.7% 6.5% 7.3% 8.2% 9.2% 10.4% 11.7% 13.2% 14.8% 16.7% 18.8% 21.1% 23.8% 

 MD 2% 2.8% 3.3% 3.8% 4.5% 5.3% 6.2% 7.2% 8.5% 10.0% 11.7% 13.7% 15.8% 15.8% 

 ME 28% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 25.0% 

 MI 3% 3.7% 3.9% 4.2% 4.4% 4.7% 5.0% 5.3% 5.6% 5.9% 6.3% 6.6% 7.0% 7.4% 

 MN 18% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 

 MO 1% 1.5% 1.6% 1.7% 1.8% 1.9% 2.0% 2.1% 2.3% 2.4% 2.5% 2.7% 2.8% 3.0% 

 MS 3% 3.1% 3.6% 4.0% 4.6% 5.2% 5.9% 6.7% 7.6% 8.6% 9.8% 10.0% 10.0% 10.0% 

 MT 5% 4.8% 5.1% 5.5% 5.8% 6.2% 6.6% 7.0% 7.5% 8.0% 8.5% 9.0% 9.6% 10.2% 

 NC 2% 2.6% 3.0% 3.4% 3.8% 4.4% 4.9% 5.6% 6.4% 7.2% 8.2% 9.3% 10.0% 10.0% 
DRAFT DELIBERATIVE 11 April 2014 

19 

 ND 15% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 

 NE 4% 4.3% 4.6% 5.0% 5.4% 5.9% 6.4% 6.9% 7.5% 8.1% 8.8% 9.5% 10.3% 11.2% 

 NH 7% 8.1% 9.1% 10.2% 11.5% 13.0% 14.6% 16.4% 18.5% 20.8% 23.5% 25.0% 25.0% 25.0% 

 NJ 2% 2.3% 2.7% 3.2% 3.7% 4.4% 5.1% 6.0% 7.0% 8.2% 9.6% 11.3% 13.3% 15.5% 

 NM 7% 7.5% 8.0% 8.5% 9.0% 9.6% 10.2% 10.9% 11.6% 12.3% 13.1% 14.0% 14.9% 15.9% 

 NV 8% 9.0% 9.6% 10.2% 10.8% 11.5% 12.3% 13.1% 13.9% 14.8% 15.8% 16.8% 17.9% 19.0% 

 NY 4% 4.3% 4.8% 5.5% 6.1% 6.9% 7.8% 8.8% 9.9% 11.1% 12.5% 14.1% 15.9% 17.9% 

 OH 1% 1.6% 1.8% 2.2% 2.5% 3.0% 3.5% 4.1% 4.8% 5.6% 6.6% 7.7% 9.1% 10.6% 

 OK 11% 11.9% 12.8% 13.9% 15.1% 16.3% 17.7% 19.2% 20.0% 20.0% 20.0% 20.0% 20.0% 20.0% 

 OR 12% 12.6% 13.4% 14.3% 15.2% 16.2% 17.2% 18.3% 19.5% 20.6% 20.6% 20.6% 20.6% 20.6% 

 PA 2% 2.3% 2.7% 3.2% 3.8% 4.4% 5.2% 6.1% 7.1% 8.4% 9.8% 11.5% 13.5% 15.8% 

 RI 1% 1.4% 1.6% 1.8% 2.0% 2.2% 2.5% 2.8% 3.2% 3.6% 4.0% 4.5% 5.1% 5.7% 

 SC 2% 2.5% 2.9% 3.2% 3.7% 4.2% 4.7% 5.4% 6.1% 6.9% 7.8% 8.9% 10.0% 10.0% 

 SD 24% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 15.1% 

 TN 1% 1.2% 1.4% 1.6% 1.8% 2.0% 2.3% 2.6% 2.9% 3.3% 3.8% 4.3% 4.9% 5.5% 

 TX 8% 8.6% 9.3% 10.1% 10.9% 11.8% 12.8% 13.9% 15.0% 16.3% 17.6% 19.1% 20.0% 20.0% 

 UT 3% 3.0% 3.2% 3.4% 3.6% 3.8% 4.1% 4.3% 4.6% 4.9% 5.2% 5.6% 5.9% 6.3% 

 VA 3% 3.9% 4.6% 5.4% 6.3% 7.4% 8.7% 10.2% 11.9% 14.0% 15.8% 15.8% 15.8% 15.8% 

 VT 7% 8.0% 9.0% 10.1% 11.4% 12.8% 14.4% 16.2% 18.3% 20.6% 23.2% 25.0% 25.0% 25.0% 

 WA 7% 7.5% 8.0% 8.5% 9.0% 9.6% 10.2% 10.9% 11.6% 12.4% 13.2% 14.0% 14.9% 15.9% 

 WI 5% 5.4% 5.7% 6.0% 6.4% 6.8% 7.2% 7.6% 8.0% 8.5% 9.0% 9.6% 10.2% 10.8% 

 WV 2% 2.1% 2.4% 2.8% 3.3% 3.9% 4.6% 5.4% 6.3% 7.4% 8.7% 10.2% 11.9% 14.0% 

 WY 9% 9.4% 10.0% 10.6% 11.3% 12.0% 12.8% 13.7% 14.5% 15.5% 16.5% 17.5% 18.7% 19.9% 

4.2.5. Calculate RE targets for interim and final state goals 

The agency then translated the annual RE best practice performance levels for each state into 

state-level interim and final RE targets for informing this rule’s quantification of state goals. Separate 

interim and final RE targets were calculated for the proposed state goals and the alternate state goals in 

this proposed rulemaking. For the proposed state goals, the interim RE target for each state was calculated 

as the average of that state’s RE best practice performance level from 2020-2029, and the final target is 

equivalent to that state’s RE best practice performance level in the year 2029. For the alternate state goals, 

the interim RE target for each state was calculated as the average of that state’s RE best practice 

performance level from 2020-2024, and the final target is equivalent to that state’s RE best practice 

performance level in the year 2024. State-level RE targets, expressed in absolute (megawatt-hour) terms 

and as a percentage level of each state’s RE generation as a share of its total generation, along with 2012 

RE levels for each state, are provided in Table 4.8. For an explanation of how these state-level RE targets 

informed the calculations of state goals in this rule, please refer to the Goal Computation TSD. 
DRAFT DELIBERATIVE 11 April 2014 

20 

Table 4.8. Proposed and Alternate State Goals for RE Generation as a Percentage of Total Generation, 

with 2012 Historical RE Generation 

State 2012 Proposed Goals Alternate Goals 

Interim 

Level 

Final Level Interim 

Level 

Final Level 

 Alabama 2% 6% 9% 4% 5% 

 Alaska 1% 1% 2% 1% 1%

 Arizona 2% 3% 3% 2% 3% 

 Arkansas 3% 5% 7% 4% 5% 

 California 15% 20% 21% 20% 21% 

 Colorado 12% 19% 21% 17% 19% 

 Connecticut 2% 5% 9% 4% 5% 

 Delaware 2% 7% 12% 4% 5% 

 Florida 2% 6% 10% 4% 6% 

 Georgia 3% 8% 10% 6% 7% 

 Hawaii 9% 10% 10% 10% 10%

 Idaho 16% 21% 21% 21% 21% 

 Illinois 4% 7% 9% 6% 7% 

 Indiana 3% 5% 7% 4% 5% 

 Iowa 25% 15% 15% 15% 15% 

 Kansas 12% 19% 20% 19% 20% 

 Kentucky 0% 1% 2% 1% 1% 

 Louisiana 2% 5% 7% 4% 4% 

 Maine 28% 25% 25% 25% 25% 

 Maryland 2% 10% 16% 6% 8% 

 Massachusetts 5% 15% 24% 11% 13% 
DRAFT DELIBERATIVE 11 April 2014 

21 

State 2012 Proposed Goals Alternate Goals 

Interim 

Level 

Final Level Interim 

Level 

Final Level 

 Michigan 3% 6% 7% 5% 6% 

 Minnesota 18% 15% 15% 15% 15% 

 Mississippi 3% 8% 10% 6% 8% 

 Missouri 1% 2% 3% 2% 2% 

 Montana 5% 8% 10% 7% 7% 

 Nebraska 4% 8% 11% 6% 7% 

 Nevada 8% 15% 19% 12% 14% 

 New Hampshire 7% 19% 25% 15% 19% 

 New Jersey 2% 8% 16% 5% 7% 

 New Mexico 7% 12% 16% 10% 12% 

 New York 4% 11% 18% 8% 10% 

 North Carolina 2% 7% 10% 5% 6% 

 North Dakota 15% 15% 15% 15% 15% 

 Ohio 1% 6% 11% 4% 5% 

 Oklahoma 11% 19% 20% 18% 20% 

 Oregon 12% 19% 21% 17% 20% 

 Pennsylvania 2% 9% 16% 5% 7% 

 Rhode Island 1% 4% 6% 3% 3% 

 South Carolina 2% 7% 10% 5% 6% 

 South Dakota 24% 15% 15% 15% 15% 

 Tennessee 1% 3% 6% 2% 3% 

 Texas 8% 16% 20% 13% 15% 

 Utah 3% 5% 6% 4% 5% 
DRAFT DELIBERATIVE 11 April 2014 

22 

State 2012 Proposed Goals Alternate Goals 

Interim 

Level 

Final Level Interim 

Level 

Final Level 

 Virginia 3% 12% 16% 9% 12% 

 Washington 7% 12% 16% 10% 12% 

 West Virginia 2% 8% 14% 5% 6% 

 Wisconsin 5% 8% 11% 7% 8% 

 Wyoming 9% 15% 20% 13% 15% 

Table 4.9. Proposed and Alternate State Goals for RE Generation in Megawatt-hours, with 2012 

Historical RE Generation 

State 2012 

Proposed Goals Alternate Goals 

Interim 

Level Final Level Interim Level Final Level 

 Alabama 

2,776,554 

 

8,647,278 

 

14,292,801 

 

6,009,218 

 

7,610,632 

 Alaska 

39,958 78,090 107,370 63,422 73,413 

 Arizona 

1,697,652 

 

2,937,707 

 

3,831,642 

 

2,481,537 

 

2,801,621 

 Arkansas 

1,660,370 

 

3,370,253 

 

4,708,823 

 

2,703,555 

 

3,153,509 

 California 

29,966,846 

 

40,868,634 

 

41,150,704 

 

40,586,564 

 

41,150,704 

 Colorado 

6,192,082 

 

9,945,536 

 

10,839,820 

 

9,051,252 

 

10,218,740 

 Connecticut 

666,525 

 

1,934,220 

 

3,114,375 

 

1,376,991 

 

1,721,274 

 Delaware 

131,051 

 

561,909 

 

1,038,351 

 

349,356 

 

468,394 

 Florida 

4,523,798 

 

13,971,137 

 

22,109,614 

 

9,790,728 

 

12,399,889 

 Georgia 

3,278,536 

 

9,392,695 

 

12,230,636 

 

7,095,644 

 

8,986,583 

 Hawaii 

924,815 1,046,927 1,046,927 1,046,927 1,046,927 
DRAFT DELIBERATIVE 11 April 2014 

23 

 Idaho 

2,514,502 

 

3,196,687 

 

3,196,687 

 

3,196,687 

 

3,196,687 

 Illinois 

8,372,660 

 

13,910,775 

 

17,818,004 

 

11,904,488 

 

13,326,217 

 Indiana 

3,546,367 

 

5,892,120 

 

7,547,086 

 

5,042,327 

 

5,644,522 

 Iowa 

14,183,424 

 

8,565,921 

 

8,565,921 

 

8,565,921 

 

8,565,921 

 Kansas 

5,252,653 

 

8,577,482 

 

8,884,938 

 

8,270,026 

 

8,884,938 

 Kentucky 

332,879 

 

1,036,717 

 

1,713,556 

 

720,442 

 

912,434 

 Louisiana 

2,430,042 

 

4,932,549 

 

6,891,619 

 

3,956,800 

 

4,615,333 

 Maine 

4,098,795 

 

3,611,728 

 

3,611,728 

 

3,611,728 

 

3,611,728 

 Maryland 

898,152 

 

3,728,926 

 

5,982,069 

 

2,394,301 

 

3,210,129 

Massachusetts 

 

1,843,419 

 

5,349,504 

 

8,613,477 

 

3,808,366 

 

4,760,555 

 Michigan 

3,785,439 

 

6,289,326 

 

8,055,859 

 

5,382,246 

 

6,025,037 

 Minnesota 

9,453,871 

 

7,888,544 

 

7,888,544 

 

7,888,544 

 

7,888,544 

 Mississippi 

1,509,190 

 

4,272,197 

 

5,458,430 

 

3,266,297 

 

4,136,743 

 Missouri 

1,298,579 

 

2,157,527 

 

2,763,528 

 

1,846,357 

 

2,066,863 

 Montana 

1,261,752 

 

2,183,403 

 

2,847,804 

 

1,844,362 

 

2,082,259 

 Nebraska 

1,346,762 

 

2,733,684 

 

3,819,427 

 

2,192,912 

 

2,557,879 

 Nevada 

2,968,630 

 

5,137,075 

 

6,700,268 

 

4,339,384 

 

4,899,105 

 New 

Hampshire 

 

1,381,285 

 

3,727,303 

 

4,822,223 

 

2,853,632 

 

3,567,113 

 New Jersey 

1,280,715 

 

5,491,354 

 

10,147,466 

 

3,414,138 

 

4,577,463 

 New Mexico 

2,573,851 

 

4,453,928 

 

5,809,243 

 

3,762,317 

 

4,247,605 
DRAFT DELIBERATIVE 11 April 2014 

24 

 New York 

5,192,427 

 

15,068,148 

 

24,261,905 

 

10,727,168 

 

13,409,233 

 North 

Carolina 

 

2,703,919 

 

8,135,750 

 

11,668,176 

 

5,852,016 

 

7,411,538 

 North Dakota 

5,280,052 

 

5,459,957 

 

5,459,957 

 

5,459,957 

 

5,459,957 

 Ohio 

1,738,622 

 

7,454,735 

 

13,775,594 

 

4,634,830 

 

6,214,090 

 Oklahoma 

8,520,724 

 

14,666,348 

 

15,579,318 

 

13,753,378 

 

15,579,318 

 Oregon 

7,207,229 

 

11,551,256 

 

12,567,372 

 

10,535,140 

 

11,894,029 

 Pennsylvania 

4,459,118 

 

19,119,477 

 

35,330,855 

 

11,887,147 

 

15,937,543 

 Rhode Island 

101,895 

 

295,694 

 

476,110 

 

210,507 

 

263,140 

 South 

Carolina 

 

2,143,473 

 

6,534,613 

 

9,675,568 

 

4,639,057 

 

5,875,334 

 South Dakota 

2,914,666 

 

1,818,850 

 

1,818,850 

 

1,818,850 

 

1,818,850 

 Tennessee 

836,458 

 

2,605,058 

 

4,305,814 

 

1,810,322 

 

2,292,760 

 Texas 

34,016,697 

 

67,689,311 

 

85,962,502 

 

55,388,864 

 

64,607,260 

 Utah 

1,099,724 

 

1,903,020 

 

2,482,103 

 

1,607,517 

 

1,814,865 

 Virginia 

2,358,444 

 

8,608,808 

 

11,192,008 

 

6,287,155 

 

8,429,425 

 Washington 

8,214,350 

 

14,214,545 

 

18,539,981 

 

12,007,295 

 

13,556,072 

 West 

Virginia 

 

1,296,563 

 

5,559,307 

 

10,273,036 

 

3,456,386 

 

4,634,107 

 Wisconsin 

3,223,178 

 

5,355,156 

 

6,859,301 

 

4,582,807 

 

5,130,122 

 Wyoming 

4,369,107 

 

7,560,533 

 

9,861,177 

 

6,386,526 

 

7,210,300 
DRAFT DELIBERATIVE 11 April 2014 

25 

The annual rates used to set state RE goals under this best practices scenario are comparable to 

rates that leader states have been able to approach in the past. Eleven states across four regions have 

already achieved over 10% of total generation from RE, surpassing the lowest regional target applied in 

the Southeast. Two states, Maine and Iowa, have already equaled or surpassed the highest regional target 

of 25% of generation, with South Dakota close behind at 24%. Finally, five states have already reached 

their region’s required target. 

4.3 Cost Effectiveness of RE 

The costs of building new RE capacity and generating more RE have changed significantly in the 

past decade, particularly for wind and solar. According to an EPA analysis based on EIA levelized costs, 

costs of new RE, particularly on-shore wind, are becoming comparable to the cost-effectiveness of other 

re-dispatch technologies such as new NGCC plants.26 

The economics of the fastest growing RE technologies – on-shore wind and solar PV – are 

improving. According to recent analyses of wind and solar project costs and pricing trends by U.S. 

Department of Energy, levelized long-term power purchase agreement (PPA) prices have been declining. 

PPA prices, in general, reflect actual agreements to pay for power from wind or solar projects over a longterm and cover the cost of installing, operating, and maintaining a wind or solar project, along with a 

profit margin.27 For utility-scale solar PV, those levelized PPA prices have fallen by more than two-thirds 

in the past five years “driven primarily by lower installed PV project prices (which, in turn, have been 

driven primarily by declining module prices), as well as expectations for further cost reductions in future 

years.”28 More recent PPAs in the West are reporting levelized PPA prices in the range of $50-60/MWh 

(in 2012 dollars).29 For wind, PPA prices have fallen since 2009 despite a trend within the wind industry 

to build projects at lower-quality wind resource sites.30 “The average levelized long-term price from wind 

 

26 EPA calculations of estimated dollar per tonne costs, based on EIA AEO 2013 levelized costs of electricity. 27 Bolinger, Mark, and Samantha Weaver. Utility-Scale Solar 2012: An Empirical Analysis of Project Cost, 

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

September 2013. p. 19. 

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

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

September 2013. p. ii. 

29 Ibid. 

30 Wiser, Ryan H., and Mark Bolinger. 2012 Wind Technologies Market Report. Lawrence Berkeley National 

Laboratory. August 2013. p. viii. 
DRAFT DELIBERATIVE 11 April 2014 

26 

PAs signed in 2011/2012—many of which were for projects built in 2012—fell to around $40/MWh 

nationwide.”31 

Examining RE resource availability regionally, several recent studies have found cost-effective or 

economic RE resources are available to serve future needs. The National Renewable Energy Laboratory 

(NREL) examined the future availability of RE in the West after Western state RPS requirements level off 

in 2025.32 The study compares the cost of RE generation from the West's most productive RE resource 

areas—including any needed transmission and integration costs—with the cost of energy from a new 

natural gas-fired generator built near the customers it serves. The report indicates that by 2025 wind and 

solar PV generation could become cost-competitive, if new RE development occurs in the most 

productive locations.33 It also has shown that a cost decrease of 10% in 2025 would bring solar power to 

cost parity with NGCC in the West, with similar possibilities for utility scale geothermal. In 2010, the 

Southeast Energy Efficiency Alliance published a report by Marilyn Brown et al. titled Renewable 

Energy in the South.34 In addition to highlighting significant RE resources in different parts of the region, 

it stated, “Under realistic renewable expansion and policy scenarios, the region could economically 

supply a large proportion of its future electricity needs from both utility-scale and customer-owned RE 

sources.”35 This study suggested that increased RE utilization should not necessarily lead to significant 

rate increases in part because RE resources may moderate forecasted rate increases in the next decade or 

two.36

Several studies have found the cost of RPS-driven RE deployment to be modest. One 

comparative analysis that "synthesize[d] and analyze[d] the results and methodologies of 28 distinct state 

or utility-level RPS cost impact analyses" found the median change in retail electricity price to be $0.0004 

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

$0.82, and the median CO2 reduction cost to be $3 per metric ton.37 This finding has been confirmed with 

 

31 Ibid. 

32 Hurlbut, David, Joyce McLaren, and Rachel Gelman. Beyond Renewable Portfolio Standards: An Assessment of 

Regional Supply and Demand Conditions Affecting the Future of Renewable Energy in the West. NREL/TP-6A20-

57830. Golden, CO: NREL, August 2013. 

33 Ibid. p. xvi. 

34 Brown, Marilyn A., Etan Gumerman, Youngsun Baek, Joy Wang, Cullen Morris, and Yu Wang. 2010. Renewable 

Energy in the South. Atlanta, GA: Southeast Energy Efficiency Alliance, December 2010. See also Brown, Marilyn 

A., Etan Gumerman, Xiaojing Sun, Kenneth Sercy, and Gyungwon Kim. 2012. “Myths and Facts about Clean 

Electricity in the U.S. South,” Energy Policy, 40: 231-241. 

35 Ibid. p. xxii. 

36 Ibid., p. 109. 

37 Chen et al., "Weighing the Costs and Benefits of State Renewable Portfolio Standards: A Comparative Analysis of 

State-Level Policy Impact Projections," Lawrence Berkeley National Laboratory, March 2007, available at 
DRAFT DELIBERATIVE 11 April 2014 

27 

more recent RPS cost data, including a report that determined 2010-2012 retail electricity price impacts 

due to state RPS policies to be less than two percent, with only two states experiencing price impacts of 

greater than three percent.38

4.4. Cost Effectiveness of Nuclear Energy 

Nuclear generating capacity facilitates CO2 emission reductions at fossil fuel-fired EGUs by 

providing carbon-free generation that can replace generation at those EGUs. Increasing the amount of 

nuclear capacity relative to the amount that would otherwise be available to operate is therefore a 

technically viable approach for reducing CO2 emissions from affected fossil fuel-fired EGUs. 

 One way to increase the amount of available nuclear capacity is to build new nuclear EGUs. 

However, nuclear generating capacity is relatively expensive to build compared to other types of 

generating capacity, and little new nuclear capacity has been constructed in the U.S. in recent years. 

Nevertheless, five new nuclear EGUs at three plants are currently under construction: Watts Bar 2 in 

Tennessee, Vogtle 3-4 in Georgia, and Summer 2-3 in South Carolina. The EPA believes that since the 

decisions to construct these units were made prior to this proposal, it is reasonable to view the incremental 

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

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

cost-effective opportunity to reduce CO2 emissions from affected fossil fuel-fired EGUs. For this reason, 

we are proposing that the emission reductions achievable at affected sources due to the generation 

provided at the identified new nuclear units should be factored into the state goals for the respective states 

where these new units are located. 

 Another way to increase the amount of available nuclear capacity is to preserve existing nuclear 

EGUs that would otherwise be retired. While each retirement decision is based on the unique 

circumstances of that individual unit, the EPA believes that increased fixed costs associated with unit age 

play a role, particularly as the units approach the point of deciding whether to apply for renewal of their 

initial operating licenses (which have 40-year terms). Of the existing fleet of nuclear EGUs, units with 7.8 

GW of capacity, representing approximately eight percent of total existing U.S. nuclear generating 

capacity, have not yet submitted applications for license renewal to the Nuclear Regulatory Commission. 

Without making any judgment about the likelihood that any individual EGU will retire, we view this eight 

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

38 Galen Barbose, “Renewables Portfolio Standards in the United States: A Status Update,” Lawrence Berkeley 

National Lab, November 2013. 
DRAFT DELIBERATIVE 11 April 2014 

28 

percent share of nuclear capacity as a reasonable proxy for the amount of nuclear capacity at risk of 

retirement for reasons including, but not limited to, additional fixed costs related to age and relicensing. 

We believe that, based on available information regarding the cost and performance of the 

nuclear fleet, preserving the operation of this existing, at-risk nuclear capacity is likely to be a relatively 

cost-effective approach to achieving CO2 reductions from affected EGUs. According to a recent report, 

nuclear units may be experiencing up to a $6/MWh shortfall in covering their operating costs with 

electricity sales.39 Assuming that such a revenue shortfall is representative of the incentive to retire the 

estimated eight percent of at-risk nuclear capacity, one can estimate the value of offsetting the revenue 

loss at these at-risk nuclear units to be about $12 to $17 per metric ton. The EPA views this cost as 

reasonable. We therefore propose that the emission reductions achievable by retaining in operation eight 

percent of each state’s existing nuclear capacity should be factored into the state goals for the respective 

states. 

 

39 “Nuclear... The Middle Age Dilemma?” Eggers, et al., Credit Suisse, February 2013