EPA’S ASSUMPTIONS FOR RENEWABLES, NUCLEAR AND ENERGY EFFICIENCY n Increased use of Renewable and Nuclear Plants (Building Block 3): • EPA’s assumptions for the expansion of renewable energy are very modest and based on what states in each region have already committed to do. State renewable portfolio standard (RPS) commitments vary significantly, and as a result the scale of the renewables building block also varies by region. The EPA proposal also counts existing renewables towards the target, so in many cases the emissions reduction opportunity from new renewable resources is not considered. • The proposal adjusts state targets to account for 6% of the existing nuclear fleet. It does this by adding 6% of current nuclear electricity generation, in megawatt hours (MWh), to the denominator of each state’s target. This creates an incentive for states to retain existing nuclear plants. The proposal does not address the safety or the economic status of particular nuclear plants at risk of closing. n Increased use of End-use Energy Efficiency (Building Block 4): • The energy efficiency building block assumes states expand programs at a very modest rate to achieve energy savings levels that 12 leading states have already committed to reach today – 1.5% annual savings. For states that are not already achieving this level, EPA ramps-up the expected energy efficiency savings slowly, at 0.2% per year.
• The proposal assumes very high energy efficiency program costs (almost double what most experts report) and assumes a short life-span for energy efficiency measures. Even with these very conservative assumptions, efficiency remains an important and low-cost tool in EPA’s analysis. More reasonable assumptions, reflecting established market trends and empirical state program results, would significantly increase the projected emissions reductions delivered by this building block, thereby resulting in stronger state-by-state emissions reduction targets for 2020 and 2030.
EPA IS PROPOSING A TWO-PART GOAL STRUCTURE: n an “interim goal” that a state must meet on average over the ten-year period from 2020-2029 and n a “final goal” that a state must meet at the end of that period in 2030 and thereafter. A state could adopt the rate-based form of the goal established by the EPA or an equivalent mass-based form of the goal.1 A multi-state approach incorporating either a rate- or mass-based goal would also be approvable based upon a demonstration that the state’s plan would achieve the equivalent in stringency, including compliance timing, to the state-specific rate-based goal set by the EPA.