Curtis Davis, Chief Operating Officer, Generation and Marketing Allegheny Energy Supply. Governor s Energy Summit 2010

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1 Curtis Davis, Chief Operating Officer, Generation and Marketing Allegheny Energy Supply Governor s Energy Summit 2010

2 Allegheny Energy Service Area and Generation Plants - 2 -

3 Allegheny & FirstEnergy Combined Service Territory PA OH MD NJ WV VA FirstEnergy (FE) Service Area Allegheny Energy (AYE) Service Area Potomac Edison/TrAILCo VA Transmission Zone 3 FirstEnergy Power Plants Allegheny Power Plants - 3 -

4 Challenges to the Generator Electricity demand is down Power prices are down Capacity prices are down Coal prices are up Environmental regulations are increasing and unclear, thus creating uncertainty - 4 -

5 Coal is the Dominant Source of Electricity Source: U.S. Department of Energy, Energy Information Administration

6 - 6 - West Virginia Generation

7 Pending EPA Regulations The maze of regulations over the next five years Ozone SO2/NO2 CAIR Water Revised Ozone NAAQS Beginning CAIR Phase I Seasonal NOx Cap CAIR Vacated CAIR Remanded Reconsidered Ozone NAAQS NO2 Primary NAAQS SO2 Primary NAAQS Proposed CAIR Replacement Rule Expected CO2 Regulation Final CAIR Replacement Rule Expected Effluent Guidelines proposed rule expected SO2/NO2 Secondary NAAQS 316(b) final rule expected Effluent Guidelines Final rule expected Next Ozone NAAQS Revision 316(b) Compliance 3-4 yrs after final rule Effluent Guidelines Compliance 3-5 yrs after final rule '08 '09 '10 '11 '12 '13 '14 '15 '16 '17 PM-2.5 SIPs due ( 97) CAMR & Delisting Rule vacated Begin CAIR Phase I Annual NOx Cap Begin CAIR Phase I Annual SO2 Cap Proposed Rule for CCBs Management PM2.5 Next PM- Final 2.5 Rule for NAAQS CCBs Revision Mgmt HAPs MACT proposed rule 316(b) proposed rule expected HAPS MACT final rule expected Final EPA Nonattainment Designations Ash PM-2.5 SIPs due ( 06) New PM-2.5 NAAQS Designations Begin Compliance Requirements under Final CCB Rule (ground water monitoring, double monitors, closure, dry ash conversion) Hg/HAPS Beginning CAIR Phase II Annual SO2 & NOx Caps HAPS MACT Compliance with Compliance 3 yrs CAIR after final rule Replacement Rule CO2 Beginning CAIR Phase II Seasonal NOx Cap will force nearly all coal plants to retrofit or retire

8 Potential Effects of EPA Regulations Multiple reports conclude EPA regulations will result in: The loss of significant amount of generation capacity Extensive capital costs associated to comply Upward pressure on energy prices Negative effects on system reliability - 8 -

9 Estimated Coal Retirements/Sample Reports NERC (October 2010) 34 GW of retirements through MJ Bradley (August 2010) GW of retirements by 2015 Sanford Bernstein (October 2010) 65 GW of retirements by Credit Suisse (September 2010) GW of retirements through ICF for EEI (May 2010) GW of retirements through 2015 UMWA (May 2010) 56 GW of retirements by 2015 Source: ACCCE November

10 Regulations Will Be Costly Utilities/Generators may need billions to retrofit or replace coal generation and these costs will be borne by utility customers. Source: Air costs per EEI Coal Fleet Initiative study. Water & solids cost per AYE internal estimates. Carbon costs per EIA AEO

11 All West Virginia Coal Generation will be Impacted While billions have been spent in WV to reduce air emissions Non-scrubber all plants will now face additional mandated investments. Source: EPA Needs v.4.10 database

12 Regulations Will Require Significant Retrofits 40% of US coal capacity is scrubbed (SO2 and mercury). 33% of US coal capacity has an SCR (NOX control). Therefore, to survive the train wreck, about 2/3 of US coal capacity would have to invest in a scrubber and/or an SCR, plus other controls. 76% of WV coal capacity has both SCR and scrubbers. 10% of WV coal capacity has only scrubbers. 14% of WV coal capacity has neither a SCR nor scrubbers. AE has already invested ~$3 Billion in clean air controls

13 Continuous Environmental Improvements Scrubbers which reduce SO2 also reduce a significant amount of mercury

14 Effect of plant closures on jobs Job loss is an issue of concern with pre-mature coal plant closures More than 2,700 operation and maintenance employees work in WV coal fired power stations There are approximately 46,000 mining employees in WV Other suppliers Every 4 MW of generation lost represents the loss of one power plant job Every 10,000 tons of coal that will not be used due to retirements represents the loss of one mining job

15 What can we do? We must work with Congress and the EPA to mitigate the Train Wreck by coming up with regulations that: Provide a better time line for implementation of regulations. Balance reducing emissions with keeping the lights on Limit cost impact on customers. Support the long-term development of clean coal technologies. If we do not find solutions, then we face: A rash of coal generation retirements. Loss of jobs in the utility/generation sectors. Increased costs for utilities and their customers. We cannot give on a few regulations One regulation by itself is enough to cause plant closures

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