Navigant Research Blog

Impacts of the Clean Power Plan, Revisited

— September 22, 2016

AnalyticsOral arguments in the litigation of the US Environmental Protection Agency’s (EPA’s) Clean Power Plan (CPP) are upon us. Let’s revisit what the CPP could mean for power generation in the United States.

Navigant’s Energy Market Outlook (NEMO) includes a regional CPP policy with the mass targets and compliance deadlines laid out by the EPA in the final rule. NEMO shows that impacts of the CPP are regional in nature, and in many regions are not as drastic in the early years of compliance as one might expect. In fact, most states do not see additional costs driven by the policy in the first few years of implementation. This is partly due to the fact that the EPA’s final rule includes a glidepath where targets are not as steep in the early years, partly due to expected changes that lower CO2 emissions before CPP compliance begins.

Coal Retirements

Navigant continues to forecast the retirement of significant coal capacity over the next few decades. Our current modeling shows approximately 73 MW going offline between 2017 and 2035. About 40% of these retirements have already been announced, and just over 20% are forecast based on plant age. These two categories can be ruled out as being “driven” by the CPP. The remaining 40% is shown to be uneconomic and is therefore shown to retire in our modeling.

Retiring Coal Capacity by Region, United States: 2017-2035

CPP Retirements

(Source: Navigant)

A decision to retire a plant before the end of its useful life is very complicated, and it is very rare that a single driver can be identified as causing such a decision. The more influential factors we have seen include competition with cheap natural gas and increases in costs caused by environmental regulations (including the CPP). NEMO shows that the largest shares of announced coal retirements are located in MISO and WECC, while the largest share of modeled coal retirements are located in SERC territory.

Renewable Growth

On the other side of the equation, NEMO also includes continued low natural gas prices due to shale abundance, as well as continued growth in large-scale renewables, distributed energy resources, and energy efficiency. Large-scale solar capacity additions continue to grow due to falling costs, with additions on par with wind in some regions. Early in the forecast, solar becomes the renewable of choice in California, driven by the state’s aggressive renewable and carbon goals, which go above what the CPP requires. Wind continues to be installed in areas with high potential, helping states like Texas meet their CPP targets.

Low-Cost Compliance in Early Years

NEMO includes over 29 GW of coal coming offline in the Eastern Interconnection before the CPP targets begin, making compliance in the first interim compliance period (2022-2024) relatively painless. Our modeling of the CPP uses a cap-and-trade mechanism to approximate a compliance framework. Across most of the country, carbon allowance prices are forecast to be zero for the first 2 years of compliance, meaning no additional costs are needed to meet the targets. As others have found, compliance costs are lower when regional trading is allowed. Our modeling confirms that states that go it alone tend to have higher compliance costs overall.


Take Control of Your Future, Part IV: Power Generation Shift

— May 20, 2016

Oil and Gas ProductionDale Probasco and Rob Patrylak also contributed to this post.

In the initial blog of this series, I discussed seven megatrends that are fundamentally changing how we produce and use power. Here, I discuss how the shift in the power generation fuel mix is changing our industry.

Generation Fuel Mix Shift Is Accelerating

The electric grid in the United States has relied heavily on nuclear and coal-fired plants to serve as baseload generation for the overall system. According to the U.S. Energy Information Administration (EIA), U.S. electric generating facilities expect to add 26.1 GW of utility-scale generating capacity in 2016. Most of these additions come from three resources: natural gas (8 GW), solar (9.5 GW), and wind (6.8 GW), which together make up almost 93% of total planned additions.

The Navigant Energy Market Outlook has projected this level of expansion in natural gas and renewable assets for several years. For 2016, Navigant expects higher natural gas (16.3 GW) and solar (13.2 GW) expansions than EIA is projecting. Navigant forecasts wind expansion will be lower at 6.1 GW, suffering a bit from extremely low natural gas prices and the ongoing decreases in installed costs for solar (decreasing faster than the installed cost of wind).

This shift toward natural gas and renewables will continue as many different factors affect generation fuel strategies, resource plans, and decision-making. Among these factors are sustained low natural gas prices (see Navigant’s natural gas price forecast), state and federal renewable incentives, the implementation of environmental regulations such as the Mercury and Air Toxics Standard, and the threat of new carbon legislation such as the Clean Power Plan (see also my earlier blog in this series on this topic). Today, this shift is accelerating even more because of increased interest from customers in renewable power (customer choice) and the rapidly declining installed costs, which are making renewables more competitive with traditional fuel sources (including coal and nuclear).

What Does This Mean to Generators?

As a result, the economics have changed and some of the existing (coal and nuclear) assets are experiencing eroded profit margins. These margins, in turn, are resulting in challenging economics and, in some cases, significant devaluation. Increasingly more generation assets are at risk of becoming stranded investments, as the fuel mix is shifting more quickly than anybody envisioned. Coal-to-gas switching has caused coal plants to consider retirements and, with low gas prices and the impact of renewables off peak, there is more pressure to decommission nuclear assets. There have been several early shutdowns, confirmed announcements, and threatened early shutdowns in recent years, including the recommendation from Omaha Public Power District (OPPD) management last week to discontinue operations at its Fort Calhoun nuclear station. Generators are reevaluating the role of each of their plants, as well as how and if the plants should fit into their portfolio, leading us to the following observations:

  1. Coal and nuclear plants operate at reduced revenue while still required to maintain system reliability/stability as long as their required economics are met.
  2. Coal plants (designed as baseload) are required to operate more as cycling units. This requirement drives up cost and reduces efficiencies, which may mitigate some of the environmental gains made as a result of more off-design operations.
  3. These economic pressures are driving numerous coal plants out of the market and increasing the possibility of stranded assets.
  4. Nuclear assets have been hurt as well and are requesting market assistance and incentives to keep operating. Savings measures such as Capacity Resource Adequacy payments and even state legislatures have been looking at approaches that can improve the economics for both nuclear and coal in order to maintain fuel diversity and keep these baseload plants running.
  5. Efficient gas plants are operating more in areas of ample gas supply and infrastructure.
  6. All generating plants are seeking ways to reduce operations and maintenance (O&M) costs while maintaining reliability.

As evidenced by Navigant’s Generation Knowledge Service (GKS), the average capacity factor of coal plants has declined by 20%-30%, which translates to a 20%-30% drop in gross revenue opportunity. Very few companies can easily adapt to this type of drop in gross revenue. At the same time, driven largely by increasing amounts of variable renewable generation, these coal plants have been asked to perform more as cycling plants, which drives up overall operating costs and reduces efficiency. To deal with the combination of lower realized revenue and higher operating costs, companies are evaluating their plants to determine if they can survive in the new world or if they should be repowered or retired. They are actively seeking new ways to reduce costs through fewer planned outages and higher operating efficiencies while maintaining high reliability to support the increased use of variable generation.

And to Make Things Worse: The Move from Big to Small Power

Additionally, with the rapid growth of distributed generation (DG), all central generation (coal, gas, nuclear, and wind) will face more changes in their role on the grid. DG installations are expected to reach 19 GW in 2016; thus, DG is growing faster than central station generation (26.1 GW additions, minus 7.9 GW retirements, using the referenced EIA forecast). On a 5-year basis (2015-2019), DG in the United States, with some variance by region, will grow almost twice as fast as central generation (98.4 GW vs. 57 GW).

Path Forward

As a path forward, generators must clearly define the mission of each generating unit to understand their new role and how to survive economically. To succeed, companies must do the following:

  1. Conduct a strategic review of generating assets and determine what, if any, changes need to be made in generation portfolio and/or in how these assets are managed under several regulatory and commodity pricing scenarios.
  2. Find ways to reduce O&M costs while maintaining the reliability required by the independent system operators during target operating periods (for plants that will continue to run in the near term).
  3. Have a strategy to manage significant reductions in staffing levels and loss of critical experience across the board, including dealing with the impacts on funding pensions and local economies when plants are retired.
  4. Plan for a changing workforce that will need to include deeper knowledge of digital technology and an understanding of how to optimize operations in a more variable power market.
  5. Aim to operate fossil assets globally, as companies that do so may find it easier to survive than generators focused solely on North America or Western Europe.
  6. Seek new sources of revenue to replace the capital-intensive position for large generating plants by considering investments in renewables and distributed energy resources.

An understanding of the above data points and how they affect your company and the rest of the industry is crucial to shaping our energy future. Navigant can help you develop and use this information to influence the key decision makers, regional transmission organizations, and state agencies that are shaping the future of the industry. If you’re not sitting at the dinner table shaping a future that works best for your company and your customers, then you just might be the entrée.

This post is the fourth in a series in which I will discuss each of the megatrends and the impacts (“so what?”) in more detail. My next blog will be about delivering shareholder value through mergers and acquisitions. Stay tuned.

Learn more about our clients, projects, solution offerings, and team at Navigant Energy Practice Overview.


Compliance Strategies for Satisfying Clean Power Plan Requirements

— July 23, 2015

Next month, the U.S. Environmental Protection Agency (EPA) is expected to release the final Clean Power Plan (CPP) rule, which regulates carbon dioxide emissions from existing power plants. While states may comply independently or work together to achieve CPP goals, Navigant Consulting has found that states can substantially reduce compliance costs by banding into trading blocs, and we have focused on regional trading in our modeling. The proposed rule is modeled in Navigant Consulting’s recent white paper,  Anticipating Compliance: Strategies and Forecasts for Satisfying Clean Power Plan Requirements, and highlights our finding that focusing on energy efficiency (EE), coal retirements, and targeted renewable expansion represents the least-cost compliance option.

Energy Efficiency

EE represents the lowest-cost compliance option in almost all areas, but it cannot single-handedly achieve compliance.  Expanding EE programs also helps ease interim compliance targets because EE can be rolled out more rapidly than new generators, reducing the near-term need to build large amounts of new low-carbon capacity. Navigant Consulting found that the expansion of EE programs in response to the CPP can save nearly $250 billion above business-as-usual EE through 2030.

Coal Retirements

The Northeastern, Southeastern, and Midwestern United States are expected to rely heavily on coal retirements for compliance. Since EE and renewables are less carbon-intensive than gas generation, higher penetration of these technologies helps keep more coal generators online.

Regional Least-Cost Compliance Options

(Source: Navigant Consulting)

Natural Gas

New gas generation plays an important role in compliance, and it is necessary to help maintain capacity and energy resource adequacy after coal retirements.  The Northeast and Southeast, in particular, will likely rely heavily on new natural gas combined-cycle plants to supplement EE in replacing retiring coal plants, and building these plants will be a large portion of their compliance costs.  The central and western United States will also rely heavily on gas to maintain capacity margins, but will likely see more simple-cycle peaking gas plants than the Northeast and Southeast due to a high rate of renewable expansion as well as EE growth.


Adding renewables is a cost-effective compliance option where renewable potential is high, especially in the central and western United States.  Navigant found wind expansion to be economic throughout the western and central United States, and it plays a particularly important role in compliance in Texas, the Southwest Power Pool (SPP), and Midcontinent Independent System Operator (MISO).  California, which has little coal left to retire, has to rely on EE and renewable resources almost exclusively for compliance. Solar and wind both play critical roles in ensuring low-emission generation in California.  Navigant Consulting found that areas that rely more heavily on renewables tend to need to spend less on replacing capacity than other areas, but also tend to see higher carbon allowance prices (which help make large-scale renewable buildout economic).

Glide Path

Many commenters to the EPA focused on the difficulty of meeting near-term interim targets.  Navigant Consulting’s analysis has shown that the implementation of a glide path with less stringent initial targets results in savings of over $200 billion when compared to a non-glide path scenario.


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