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# Translating Rate - Based Goals to Mass - Based Goals:

EPA’s GDC Methodology with Load Growth

October 17, 2014

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# INTRODUCTION These materials review an approach to translating rate
- based into mass
- based goals that builds on EPA’s goal data computation (GDC) methodology and load growth expectations.
The methodology is intended to: 1. Be a simple and transparent method for quickly providing provisional mass goals to states and allowing those goals to be updated for state challenges or other EPA modifications. 2. Preserve the environmental integrity of the rule while facilitating state choice of mass goals. 3. Be fully consistent with EPA’s definition of BSER and GDC process

• The GDC process calculates emission rate goals using assumptions for each of the 4 BSER building blocks

• This translation methodology uses the same GDC process, calculations and 

## assumptions to estimate mass goals

• Because it relies on the same process, calculations and assumptions, the mass goals resulting from this methodology are equivalent to the emission rate goals.
These materials:

 Review a translation methodology that covers both existing and new sources

 Benchmark the national results to IPM and other data

 Compare state
- by
- state emission goal results

 Discuss issues related to restricting the mass goal to existing sources 1

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# Illustrative U.S. Calculation METHODOLOGY Illustrative 2030 Mass - Based Calculation for Existing and New Sources (Total U.S.) *

0 500 1,000 

### 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000

2012 Retail

Sales, Plus1.0751x Grossup (From GDC) + 0.84%

Average Annual Load Growth 2030 Retail

Sales, Plus1.0751x Grossup (BAU) 2030 EE

Potential (BB 4) 2030 Total

MWh Net of EE 2030 Total

Renewables (BB 3) Nuc.,

Uncovered Res., Net Imp., & Other Gen. at 2012 Levels Demand for

Covered Fossil Generation (Existing & New) NGCC (E/U)

Redispatched up to 70% CF (BB 2) Redispatched

Coal and O/G Steam

Coal O/G Steam NGCC Other Covered 111(d) Nuclear + Uncovered 111(d) + Net Imports/(Exports) Renewables Energy Efficiency Energy Efficiency and Renewable Energy (BB 3 & 4) are deployed

per GDC

Nuclear, uncovered and

net imports are assumed to remain at 2012 levels The residual demand is left for fossil generation to meet in each state In each state, NGCC runs up to a 70% capacity factor, with coal and oil/gas steam providing the last increment of generation TWH 2012 state retail sales grow at the regional rate imbedded in the 2030 BAU IPM run (similar to NOx SIP call)



## 2 * Note: This is an illustration of calculations that are performed on a state
- by
- state basis.

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# National Results METHODOLOGY Summing the state
- specific mass goals implies a national mass goal (for both existing and new sources) that is 19% below 2012 levels.



# U.S. Generation Mix by Source

1474 1044 

## 100 33 959 1402 80 80 1123 1123 218 523



## 381

0 1,000 2,000 3,000 4,000 5,000



## 2012 2030 Results (Existing & New) TWH Energy Efficiency
Renewables
Nuclear + Uncovered Sources + Net Imports/(Exports) Other Covered Generation NGCC
O/G Steam
Coal 

### 1480 982 66

23 

### 377
548 29 

### 29 

# 1,953 1,582

0 500 1,000 1,500 2,000 2,500

2012 2030 Results (Existing & New) Covered Emissions (MM tonnes) 19% Reduction in Covered Emissions 

# U.S. Covered Emissions by Source

3

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# BENCHMARK U.S. RESULTS With IPM derived load growth, sector emissions are very close to the Option 1 State case.

1,953 2,139 1,600 1,582 2,381 2,039 2,256

1,701 1,669

0 500 1,000 1,500 2,000 2,500

2005 (EIA) 2012 (EIA, EPA G.D.C.) 2030 (EPA

R.I.A. BAU) 2030 (EPA

Option 1 State) 2030 (MassBased) Million Metric Tonnes 

# U.S. Electric Sector Emissions: Historical and Projected

Note: EPA data from Regulatory Impact Analysis (R.I.A.). Covered sources are approximated by emissions totals from all units >25 MW excluding Indian Country units. 

## 4 Uncovered Sources

C overed Sources (Existing & New)

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# GDC/LG compared to Rate STATE - BY

- STATE RESULTS

Percent Change in Emissions and Emission Rates Relative to 2012 Levels (2012 Covered Emissions = 100)

Note: Mass
- based goal data is a comparison to 2012 on a tonnage basis, while the rate
- based goal is a comparison to 2012 on a ra te basis. 

### 2012 Actual = 100

0 20 40 60 80 100 120 140 160

CT MA ME NH NY RI AL AR AZ CO DE FL GA IA IL IN KS LA MD MI MN MO MS MT NC ND NE NJ NM NV OH OK OR PA SC TX UT VA WA WI WV WY CA ID KY SD TN 

### 2012 Covered Emissions 2030 Mass-Based Spreadsheet Emissions vs 2012 Covered Emissions 2030 Rate-Based Goal vs 2012 Covered Emissions Rate

States with mass - based reductions exceeding rate - based reductions due to low load growth and little/no coal “Typical” States: Mass - based reduction is between 2012 levels and rate - based reduction States with mass - based goal above 2012 levels due to load growth and

limited abatement options 

## For most states, the percentage reduction in tonnes under a mass
- based goal would be less than the percentage reduction in rate
- based goals.

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# GDC/LG compared to IPM STATE - BY

- STATE RESULTS

Percent Change in Emissions Relative to 2012 Levels

(2012 Covered Emissions = 100)

States with mass - based reductions exceeding rate - based reductions due to low load growth and little/no coal “Typical” States: Mass - based reduction is between 2012 levels and rate - based reduction States with mass - based goal above 2012 levels due to load growth and

limited abatement options 

## The variability of mass
- based goals, on a percentage basis, is lower under this method than under IPM; reducing it further would require modifications to the underlying GDC process

.

7 0 20 40 60 80 100 120 140 160

CT MA ME NH NY RI AL AR AZ CO DE FL GA IA IL IN KS LA MD MI MN MO MS MT NC ND NE NJ NM NV OH OK OR PA SC TX UT VA WA WI WV WY CA ID KY SD TN 

### 2012 Covered Emissions 2030 Mass-Based Spreadsheet Emissions vs 2012 Covered Emissions 2030 Opt1-State (IPM Modeled Policy) vs 2012 Covered Emissions

2012 Actual = 100

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# GDC/LG compared to IPM STATE - BY

- STATE RESULTS

Absolute Change in Emissions Relative to 2012 Levels The variability of mass
- based goals, on an absolute basis, is lower under this method than under IPM. Allowing states to choose between methods affects overall reductions.

8 States with mass - based reductions exceeding rate - based reductions due to low load growth and little/no coal “Typical” States: Mass - based reduction is between 2012 levels and rate - based reduction States with mass - based goal above 2012 levels due to load growth and

limited abatement options CO2 Emissions Reductions, Relative to 2012 Levels (MMmtCO2)

(100) (80) (60) (40) (20) 0 20 40 60

CT MA ME NH NY RI AL AR AZ CO DE FL GA IA IL IN KS LA MD MI MN MO MS MT NC ND NE NJ NM NV OH OK OR PA SC TX UT VA WA WI WV WY CA ID KY SD TN 

## 2030 Mass-Based Spreadsheet Emissions vs 2012 Covered Emissions 2030 Opt1-State (IPM Modeled Policy) vs 2012 Covered Emissions % Reduction from 2012 %

Reduction from 2005 States w/

Higher Emissions IPM 17% 29% 25 GDC/LG 18% 30% 22 Higher of 2 12% 25%

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## - 50 

## 100 150 200 250

TX OH FL PA IN IL KY GA WV AL MO MI NC NY TN AZ OK WI WY LA CA VA CO SC KS UT MN IA MD NM ND NV AR MS MA NE NJ MT WA CT OR NH ME SD RI DE ID DC VT CO2 (MMmtCO2) 

# Mass - based CO2 Emission Targets by State

Increase from 2005 to 2012 

# GDC/LG compared to 2005 STATE - BY

- STATE RESULTS

2005 Historic Level 2012 Historic Level

Target: IPM Modeling Results, Option1
- State Scenario Target: Mass
- Based Spreadsheet Calculation



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