The most cost-effective and accessible way for states to replace retiring coal plants and comply with the U.S. EPA’s proposed carbon regulation (the Clean Power Plan, or CPP, released in June 2014) is through demand-side measures. These include the energy efficiency programs that the EPA uses to calculate emissions rate targets in the CPP as well as other measures, such as demand response. Analysis by Navigant and others shows that measures that cut demand growth will cut compliance costs. However, most states cannot meet their targets by energy efficiency alone.
It’s in electricity customers’ best interest for states and utilities to implement the CPP with as much emphasis on energy efficiency and demand response as they are physically and financially able to. For this primary reason, states and utilities will expand programs where they already exist and introduce new programs where there are gaps.
The costs to comply with the CPP, in addition to costs to comply with other environmental regulations as well as competition with low-cost natural gas, will drive approximately 45 GW of additional coal retirements by 2025, beyond anticipated retirements without the CPP (according to Navigant’s analysis). The aging U.S. coal fleet already faces troubled times, with low natural gas prices expected to continue and the Mercury and Air Toxics Standards (MATS) requiring hundreds of coal plants to install costly emissions controls or shut down. As coal plant owners look ahead to a carbon-constrained future, they are weighing complex decisions about whether it makes sense to invest in improvements in the near term when the long-term future of their coal fleets is uncertain. Much depends on what the EPA’s final regulation will look like and how states will choose to implement it.
While the discussion around coal retirements tends to center on replacement by natural gas, wind and solar will also play a role. The CPP will drive solar and wind generation above and beyond existing renewable targets, even in states that do not currently have a Renewable Portfolio Standard. Growth will be particularly strong in areas that have high potential for solar and wind, such as the Desert Southwest and the Texas Panhandle, and where higher power prices make renewables more cost-effective. Although much of the new solar capacity will be distributed customer-scale generation, wind installations will continue to be larger, utility-scale deployments.
New Questions Raised
The power sector has been expecting federal-level climate change policy or regulations for years. This has been a major area of uncertainty for future generation planning. However, the release of the proposed CPP has not led to any concrete assumptions for the future, and it has likely generated more uncertainty than it has quelled. How will the EPA fashion its final regulation? Will states choose to band together to implement the regulation, and will the basis for their implementation be rate-based or mass-based targets? How will energy efficiency be measured and verified? How will differences between states be reconciled in a system where electricity is constantly moving across state lines? The answers to these questions will drive broad changes in the power sector and have ripple effects across the national economy. These ripples will be felt by all industry players that are electricity customers (i.e., everyone) and, indirectly, by the healthcare industry (handling fewer conditions brought on by poor air quality) and the insurance industry (facing lessened impacts of climate change).
It’s not surprising that the CPP will transform the domestic power generation landscape, reducing coal use, lowering demand growth (due to energy efficiency and conservation programs), and increasing gas-fired and renewable generation. Thinking globally, the plan could be just what the international community has been calling for: leadership on climate change from the United States that will push other nations (notably China and India) to follow suit.
Tags: Carbon Emissions, Coal, Distributed energy, Energy Efficiency, Policy & Regulation, Renewable Energy, Smart Energy Program
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