Renewable Portfolio Standards: Status, Opportunities, and Threats. Galen Barbose, Lawrence Berkeley National Laboratory Rick Umoff, SEIA

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1 Renewable Portfolio Standards: Status, Opportunities, and Threats Galen Barbose, Lawrence Berkeley National Laboratory Rick Umoff, SEIA

2 Antitrust Reminder As a trade association of competitors, SEIA must comply with federal and D.C. antitrust laws. Competitively sensitive matters cannot be discussed on this webinar, including product prices; sales terms or conditions; production levels; sales territories; marketing plans; industry forecasts; or bid terms. If any such topic is raised, SEIA will stop the conversation and, if necessary, end the webinar. For more information, SEIA s antitrust policy is available on its website: November 25, Solar Energy Industries Association 2

3 State RPS Policies and Solar Energy Impacts, Experiences, Challenges, and Lessons Learned Galen Barbose Lawrence Berkeley National Laboratory SEIA Webinar November 21, 2013 This analysis was funded by the National Electricity Delivery Division of the Office of Electricity Delivery and Energy Reliability and by the Solar Energy Technologies Office of the Office of Energy Efficiency and Renewable Energy of the U.S. Department of Energy under Contract No. DE- AC02-05CH11231.

4 Summary of State RPS Experience-to-Date Subject to frequent revisions and refinements; have largely held up against recent political and legal challenges A significant driver for RE and solar growth Generally high levels of compliance Rate impacts have thus far remained relatively modest, though questions exist about future costs Significant additional RE capacity is required to meet future RPS targets, but is well in-line with pace of additions in recent years A diverse set of challenges exist to meeting future RPS obligations 4

5 RPS Policies Exist in 29 States and DC 7 More States Have Non-Binding Goals Existing State RPS Policies Apply to 55% of Total U.S. Retail Electricity Sales in 2012 WA: 15% by 2020 OR: 25% by 2025 (large utilities) 5-10% by 2025 (smaller utilities) CA: 33% by 2020 AK: 50% by 2025 NV: 25% by 2025 AZ: 15% by 2025 MT: 15% by 2015 UT: 20% by 2025 CO: 30% by 2020 (IOUs) 20% by 2020 (co-ops) 10% by 2020 (munis) ND: 10% by 2015 SD: 10% by 2015 KS: 20% of peak demand by 2020 NM: 20% by 2020 (IOUs) 10% by 2020 (co-ops) MN: 26.5% by 2025 Xcel: 31.5% by 2020 WI: 10% by 2015 IA: 105 MW by 1999 IL: 25% by 2025 MO: 15% by 2021 OK: 15% by 2015 MI: 10% by 2015 VT: 20% by 2017 NY: 30% by 2015 PA: 8.5% by 2020 NJ: 22.5% by 2020 OH: 12.5% by 2024 MD: 20% by 2022 ME: 40% by 2017 MA: 11.1% by %/yr RI: 16% by 2019 DE: 25% by 2025 DC: 20% by 2020 VA: 15% by 2025 NH: 24.8% by 2025 CT: 23% by 2020 NC: 12.5% by 2021 (IOUs) 10% by 2018 (co-ops and munis) HI: 40% by 2030 TX: 5,880 MW by 2015 Mandatory RPS Non-Binding Goal Source: Berkeley Lab Notes: Compliance years are designated by the calendar year in which they begin. Mandatory standards or non-binding goals also exist in US territories (American Samoa, Guam, Puerto Rico, US Virgin Islands) 5

6 Enactment of New RPS Policies has Waned, but States Continue to Hone Existing Policies CO (2007) HI (2005) IL (2008) MA (2003) CT (2000) MD (2006) DC (2007) NH (2008) MI (2012) ME (2000) PA (2001) NJ (2001) NY (2006) DE (2007) NC (2010) MO (2011) IA MN (2002) AZ (1999) NV (2001) WI (2000) TX (2002) NM (2002) CA (2003) RI (2007) MT (2008) WA (2012) OR (2011) OH (2009) KS (2011) IA MN AZ MN NM CT NJ CT AZ CA DC HI CO CA MA CO WI NV MN NM CO CA CO DE IL DE CT MD CT NV PA NV CT CT HI ME IL DC NJ MD TX HI DE MA MN MA DE NH MN Enactment (above timeline) Enactment (above timeline) Major Revisions (below timeline) ( ) Year of First Requirement NJ MD MD NV MD IL NM MT WI ME NJ OR NJ MA NY NV MN RI NY MD OH NJ NC NM WI PA TX 6

7 State RPS Policies Appear to Have Motivated Substantial Renewable Capacity Development Cumulative and Annual Non-Hydro Renewable Energy Capacity in RPS and Non-RPS States, Nationally Cumulative Capacity Annual Capacity Additions Nameplate Capacity (MW) 80,000 70,000 60,000 50,000 40,000 30,000 20,000 RPS Non-RPS Nameplate Capacity (MW) 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 10, RPS Non-RPS Though not an ideal metric for RPS-impact, 67% (46 GW) of all non-hydro renewable capacity additions from occurred in states with active/impending RPS compliance obligations 7

8 State RPS Have Largely Supported Wind, Though Solar Has Become More Prominent RPS-Motivated* Renewable Energy Capacity Additions from , by Technology Type 14,000 12,000 10,000 8,000 6,000 4,000 2,000 Cumulative RPS Capacity Additions ( ) 88% 8% 1% 3% Nameplate Capacity (MW) Annual RPS Capacity Additions Geothermal Biomass Solar Wind * Renewable additions are counted as RPS-motivated if and only if they are located in a state with an RPS policy and commercial operation began no more than one year before the first year of RPS compliance obligations in that state. On an energy (as opposed to capacity) basis, wind energy represents approximately 85%, biomass 8%, solar 4%, and geothermal 3% of cumulative RPS-motivated renewable energy additions from , if estimated based on assumed capacity factors. 8

9 Solar and DG Set-Asides Have Become Widespread 17 states + D.C. have solar or DG set-asides, sometimes combined with credit multipliers; 3 other states only have credit multipliers WA: 2x multiplier for DG OR: 20 MW solar PV by x multiplier for PV installed before 2016 NV: 1.5% solar by x multiplier for PV until 2015 MN: 1.5% solar by 2020 for IOUs CO: 3% DG by 2020 for IOUs (half from retail DG) 1% DG by 2020 for coops 3x multiplier for munis/coops for solar installed before July 2015 AZ: 4.5% customer-sited DG by 2025 (half from residential) NM: 4% solar electric by 2020, 0.6% customer-sited DG by 2020 MI: 3x multiplier for solar NY: 878 GWh retail DG by 2015 NJ: 4.1% solar electric by 2027 PA: 0.5% solar PV by 2020 OH: 0.5% solar electric by 2024 IL: 1.5% solar PV by 2025, 1% DG by 2015 (50% <25 kw) MO: 0.3% solar electric by 2021 NH: 0.3% solar electric by 2014 MA: 456 GWh customer-sited solar PV (no specified target year) DE: 3.5% solar by x multiplier for solar installed before Jan (applies only to solar used for general RPS target) MD: 2% solar by 2020 DC: 2.5% solar by 2023 NC: 0.2% solar by 2018 Set-aside Set-aside with multiplier Multiplier TX: 2x multiplier for all non-wind Source: Berkeley Lab Note: Compliance years are designated by the calendar year in which they begin Differential support for solar/dg provided via long-term contracting programs (CT, DE, NJ, and RI) and via up-front incentives/srec payments 11 states created solar/ DG setasides since 2007: DE, IL, MA, MD, MO, MN, NC, NH, NM, OH, OR 9

10 Impact of Solar/DG Set-Asides is Growing: Drove ~50% of U.S. PV Additions in Annual Grid-Connected PV Installations for Solar/DG Set-Asides (MWac) 1,200 1, Percent of U.S. annual grid-connected PV capacity additions, excluding California, driven by solar/dg set-asides [right axis] Percent of U.S. annual grid-connected PV capacity additions, driven by solar/dg setasides [right axis] % 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Percent of U.S. Annual Grid-Connected PV Installations (%) NH MO DC IL DE OH MD NY PA NM NV MA NC CO AZ NJ General RPS obligations also driving significant solar additions in California and Southwest 10

11 Solar Share is Notably Greater in Regions with Set-Asides or Strong Solar Resource Potential RPS-Motivated* Renewable Energy Capacity Additions from , by Region and Technology Type 100% 20,000 % of Capacity Additions (Nameplate MW) 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% New England, New York Mid-Atlantic California Non-CA West Texas Midwest 16,000 12,000 *Renewable additions are counted as RPS-motivated if and only if they are located in a state with an RPS policy and commercial operation began no more than one year before the first calendar year of RPS compliance obligations in the host state. 8,000 4,000 0 Capacity Additions (Nameplate MW) Solar Geothermal Biomass Wind Total MW (right axis) 11

12 Main Tier RPS Targets Largely Achieved; Isolated Struggles Apparent 100% 90% 80% 70% 60% 50% Percent of Main Tier RPS Target Met with Renewable Electricity or RECs (including available credit multipliers and banking, but excluding ACPs and borrowing) 40% 30% 20% 10% % AZ CA CO CT DC DE HI IA IL KS MA MD ME MI MN MO MT NC NH NJ NM NV NY OH OR PA RI TX WA WI Note: Percentages less than 100% do not necessarily indicate that full compliance was not technically achieved, because of ACP compliance options, funding limits, or force majeure events. 12

13 Achievement of Solar/DG Set-Aside Targets Has Steadily Increased in Most States Percent of Solar/DG Set-Aside Target Met with Solar/DG Electricity or SRECs (including available credit multipliers and banking, but excluding ACPs and borrowing) Percent of Solar/DG Target Met with Solar/DG Electricity or RECs 100% 80% 60% 40% 20% 0% AZ DC IL MD MO NH NM NY OR CO DE MA MN NC NJ NV OH PA Note: "Percent of Solar/DG Target Met with Solar/DG Electricity or RECs" excludes ACPs but includes applicable credit multipliers. In cases where this figure is below 100%, suppliers may not have been technically out of compliance due to solar ACP compliance options, funding limits, and force majeure provisions. 13

14 REC Pricing Reflects Current Supply-Demand Balance; Exhibits Continued Volatility Rising Class I REC prices in Northeastern states reflect tightening supply, while pricing in Mid-Atlantic states remain low Sinking SREC prices in recent years, across most markets, show persistent over-supply Avg Monthly REC Price (2012$/MWh) $80 $70 $60 $50 $40 $30 $20 $10 $0 Jan-05 Jul-05 Jan-06 Main Tier/Class I RECs CT Class I DC Tier I DE Class I IL Wind MA Class I MD Tier I ME New NH Class I NJ Class I OH In-State PA Tier I RI New TX Jul-06 Jan-07 Jul-07 Jan-08 Jul-08 Trading Month Sources: Evolution Markets (through 2007) and Spectron (2008 onward). Plotted values are the last trade (if available) or the mid-point of Bid and Offer prices, for the current or nearest future compliance year traded in each month. Jan-09 Jul-09 Jan-10 Jul-10 Jan-11 Jul-11 Jan-12 Jul-12 Jan-13 Jul-13 Avg. Monthly SREC Price ($2012/MWh) $800 $700 $600 $500 $400 $300 $200 $100 $0 Jan-05 Jul-05 Jan-06 DC MA NC NJ PA Jul-06 Jan-07 Jul-07 DE MD NH OH Jan-08 SRECs Jul-08 Jan-09 Jul-09 Jan-10 Trading Month Sources: Spectron, SRECTrade, Flett Exchange, PJM-GATS, and NJ Clean Energy Program. Depending on the source used, plotted values are either the mid-point of monthly average bid and offer prices, the average monthly closing price, or the weighted average price of all RECs transacted in the month, and generally refer to SREC prices for the current or nearest future compliance year traded in each month. Jul-10 Jan-11 Jul-11 Jan-12 Jul-12 Jan-13 Jul-13 14

15 Rate Impacts of State RPS Policies Have Thus Far Been Generally Modest (<2%) Translating REC prices or other available data on net incremental costs into retail rate impacts yields the results shown below 5% 4% 3% 2% 1% 0% -1% CT DC DE Estimated Rate Impact of State RPS Policies* (% increase in average retail electricity rate) MA MD ME NH NJ OH REC Purchases and ACPs PA RI Future compliance costs will be impacted by increasing RPS targets, changes to fed. tax incentives, and trajectories of RE costs and natural gas prices (among other factors) TX AZ CO IL MI MN NC NY Other Methods* OR * Other Methods for estimating rate impacts include RPS surcharge collections (AZ, CO, MI, NC), budget (NY), utility-reported incremental costs (OR, MN, WA), PUC analysis (IL, WI). States omitted if data on RPS incremental costs are unavailable (CA, IA, HI, KS, MO, MT, NM, NV). WA WI Simplified approach ignores some ratepayer costs (e.g., integration) and benefits (e.g., wholesale electricity price suppression) Limited/mixed data for states dominated by bundled contracts Rate impacts vary with target levels, REC prices, presence of setasides, procurement mechanisms 15

16 Rate Impacts of Solar/DG Set-Asides Vary and Were Tempered by SREC Price Declines in 2012 The rate impacts of solar/dg set-asides can be estimated using SREC prices or data on incentive program expenditures Rate impacts vary with target levels and SREC prices Incentive programs tend to front-load set-aside costs Rate impacts in 2012 fell in many states due to decline in SREC prices or incentive levels, in spite of increasing targets 4% 3% 2% 1% 0% DC DE Estimated Rate Impact of Solar/DG Set-Asides* (% of average retail electricity rate) MA MD NH NJ SREC Purchases and SACPs Set-Aside targets are still in the early phases of ramping up; will increase by a factor of 5 by 2020 OH PA AZ CO NY MO Solar/DG Incentive Program *States omitted from the figure if data on incremental costs of solar/dg set-aside are unavailable (IL, MN, NC, NM, NV, OR). Data for CO represent Xcel Energy's calculated incremental cost of all resources used to meet DG set-aside. 16

17 Most States Have Capped Rate Impacts Well Below 10% (13 States Below 5%) Many states cost containment mechanisms can be translated into an equivalent maximum increase in average retail rates Estimated Retail Rate Increase 15% 10% 5% 0% RPS Cost Caps (Maximum Allowed Percentage Increase in Average Retail Rates) Effective Cost Cap (Max Retail Rate Increase) Historical Compliance Costs (Most-Recent Year) NJ RI MA DC NH CT MD ME OR WA NM MI TX DE OH NY CO NC IL MO MT No explicit cap on incremental compliance costs in 9 states (AZ, CA, IA, KS, HI, MN, NV, PA, WI), though KS caps gross revenue requirements and CA is currently developing its cost containment mechanism 17

18 Future RPS Requirements are Sizable, But Well Within Recent RE Growth Rates 94 GW of New RE required by 2035, if full compliance is achieved Equates to roughly 3-5 GW/yr through 2020 and 2-3 GW through 2035 By comparison, RPSdriven RE additions have ranged from 6-13 GW/yr in all but one year since 2008 CA IL NJ TX MN OH MA CO WA PA MD AZ NY OR MO NC KS MI NM CT WI NV HI DE MT DC NH ME RI IA New Renewable Capacity by 2035 (Nameplate GW) HI MA MN CA IL NJ DE OR CT NM NH CO RI NV MD KS WA OH MT DC ME AZ MO NY WI PA MI TX NC IA New Renewable Generation by 2035 (Percent of Statewide Retail Sales) 0% 5% 10% 15% 20% 25% 30% 35% * New RE is defined based on state-specific distinctions between new vs. existing, or based on the year in which the RPS was enacted; it does not represent new renewables relative to current supply 18

19 Solar Market Growth is on Pace to Meet Future Solar/DG Set-Aside Requirements Cumulative capacity requirement grows to 9,200 MW by 2035 Required average annual solar capacity additions of 700 MW/yr through 2020, tapering off thereafter By comparison, set-aside PV additions reached 1,200 MW in 2012 Annual Solar Capacity Additions (MW ac ) 1,200 1, Required Annual Capacity Additions (left axis) Cumulative Capacity Required (right axis) ,000 8,000 6,000 4,000 2,000 Cumulative Solar Capacity (MW ac ) NJ AZ MD IL PA OH MN CO NM MA DE DC NC NY NV MO NH OR 19

20 The Future Role and Impact of State RPS Programs Will Depend On The outcome of ongoing and future legislative and legal challenges Whether cost caps become binding The ever-present possibility of federal energy legislation How policymakers re-tune RPS in response to changing market conditions Continued efforts to address challenges associated with volatile REC prices and limited availability of long-term contracts in restructured retail electricity markets How other related issues and barriers affecting RE deployment are addressed (transmission, integration, siting, EPA/environmental regulations, net metering, etc.) 20

21 Thank You! For further information: LBNL RPS publications and resources: rps.lbl.gov LBNL renewable energy publications: Subscribe to distribution list: Contact information: Galen Barbose, Ryan Wiser,

22 Renewable Portfolio Standards: Opportunities and Threats Thursday November 21, 2013 Rick Umoff Counsel and Regulatory Affairs Manager State Affairs

23 Agenda Discuss: 1. Introductory Remarks 2. Threats and opportunities related to renewable portfolio standards (RPS) 3. SEIA action on RPS 4. Education and engagement on RPS November 25, Solar Energy Industries Association 23

24 Background 1. RPS are proven bedrock policies that serve as a backstop for demand A few remarks: 2. Changes to RPS affect all members broadly Rollback sends message of weakened renewable markets 3. SEIA Partners Advanced Energy Economy; Vote Solar; National Labs; Environmental Law & Policy Center; Center for Resource Solutions; environmental groups; others 4. Dual Approach Threats Opportunities November 25, Solar Energy Industries Association 24

25 RPS Threats CC Litigation: Anti-RPS Legislation: Public Relations: In-State Renewables Requirements; Carve-Outs; Multipliers Ohio (Seitz); Kansas, Maine, Missouri, Others Increased costs; Job killer; Environmental/Liberal agenda; Unconstitutional RPS Erosion: Emphasis on voluntary RPS/Race to the bottom (ALEC) Non-renewable sources; REC integrity (REC as subsidy; taking RECs) Multiple stakeholders w/varied interests Mixing RPS w/other policies (RECs for right to net meter) Meeting RPS Goals: Preparing for the day when RPS goals are met (what then?) RPS Success: Addressing technical issues as solar penetration increases Addressing public perception as we meet and increase RPS goals November 25, Solar Energy Industries Association 25

26 Anti-RPS Legislation Overview 29 states & D.C. with RPS 16 states introduced legislation to weaken existing RPS in 2013 RPS Reduction Efforts: NC, KS RPS Repeal or Freeze Efforts: TX, OR, MN, WI, OH, MD, NC RPS Deceleration Efforts: KS, CT RPS Weaken Efforts: Hydro: WA, OR, CA, MN, MT, MO, MA, CT, NC Fossil Fuel: PA, MD Nuclear: WI 0 RPS Rolled Back in 2013 November 25, Solar Energy Industries Association 26

27 RPS Litigation to Watch ATI v. CO Coal/utility companies and CO resident challenge CO RPS under CC SEIA joined w/environment CO; Sierra Club; Conservation CO; Wilderness Society; Interwest Illinois CC v. FERC Court suggested MI in-state renewable energy requirements violate the CC, but did not rule on this issue May put in-state renewable requirements at risk HydroQuebec/NYSERDA HQ challenges NYSERDA in-state requirements on CC grounds Threatens program constitutionality; May put REC integrity at risk Rocky Mountain Farmers Union v. Corey 9 th Circuit reversed and remanded district court decision that CARB Fuel Standards violate CC Allows geographical requirements when used to measure carbon intensity of fuel pathways North Dakota v. Minnesota PUC Challenge to MN s Next Generation Energy Act, which requires utilities to offset new coalbased CO2 emissions imported into MN Not a direct RPS attack, but may affect future RPS litigation November 25, Solar Energy Industries Association 27

28 RPS Opportunities RPS Expansion CA: Est. 33% goal as a floor (AB 327); Bill to expand RPS to 51% by 2030 (AB 177) NV: Phase out energy efficiency; carry forward RECs (SB 252) CO: Expand Retail and Coop standards (SB 252) NY: RPS review; Green Bank (E-0188; E-13-M-0412) MI: Expanding and strengthening RPS (PSC report stating 30% goal feasible) EPA/GHG Emissions Regulations Clean Air Act Sec 111(b): New power plant requirements (individual plants) Clean Air Act Sec 111(d): EPA may allow states to qualify through RPS and other programs Look for Other Compliance Opportunities (Demand!) Resource Adequacy (Texas) Low to Middle Income Ratepayers Grid Resiliency Climate Mandates Water Resource Requirements Georgia Power Solar Goal (210MW by 2015) November 25, Solar Energy Industries Association 28

29 SEIA Tracks RPS Trends November 25, Solar Energy Industries Association 29

30 SEIA Acts on Threats and Opportunities Market Colorado Legislation Colorado Litigation California RPS Legislation Defense to Counter ALEC Anti RPS Initiative (note some states are loosening rules to reduce costs) New York RPS Extension Solar Market Value $100m (risk was that in-state RPS requirement violated commerce clause) Hundreds of millions countrywide as a legal challenge would set precedent Hundreds of millions Hundreds of millions at risk New Opportunity (expands RPS beyond 2015 to create funding for Governor s NY SUN program beyond 2015) SEIA Members Active-in-Market Est. over 100 The industry as a whole Hundreds Hundreds - AZ,OH,KS,ME,MI,NC 25 plus Status Legislation/statute was improved in Spring 2013 Litigation ongoing AB327 passed Supporting AEE, AWEA, Docket recently opened and it will run thru This will resolve what happens post Results to Date Positive outcome in Legislature Ongoing; next decision late 2013, early 2014 Included certainty that CA could go beyond 33% RPS 1 st half of 2013 Legislative attempts stalled or failed. New repeal attempts underway in OH RPS funds for NYSUN for 2014&2015 Effect on solar market size National Important in NC and AZ to market size, less so in OH, etc. but precedent matters The primary driver for development in NY outside of LIPA Effect on SEIA members Legal certainty on what qualifies for the RPS Provides certainty and framework for RPS expansion New opportunity, mostly customercited November 25, Solar Energy Industries Association 30

31 Educate and Engage Given the threats and opportunities, it remains important to educate lawmakers and engage in RPS issues. November 25, Solar Energy Industries Association 31

32 Educate Lawmakers Lawmakers must continue to be educated Value of RPS RPS have led to significant RE and solar investment (RPS work!) No significant increase in costs (<2% in many states) Local Benefits: Environment; jobs; investment; fuel diversity; etc. Challenges to RPS Head Off Commerce Clause Threat Carefully crafted language In-state/Carve-Outs/Multipliers; Stated Purpose; Sync Regulations and Legislation Emphasize deliverability requirements and legitimate local benefits, NOT geographical requirements Combat Anti-RPS Campaigns Fresh data; local resources; local arguments Understand legal precedent (head off misuse) Coalition against anti-rps legislation Combat RPS Erosion Renewable resource expansion ALEC s voluntary model/race to the bottom REC integrity (subsidy vs. property) Trading RECs for other policies (NEM) November 25, Solar Energy Industries Association 32

33 Specific Messages to Policymakers Create smooth demand by establishing clear long term goals Legally defensible RPS policies Push for pro-solar policies if solar/dg carve outs unavailable Keep RPS and NEM separate Maintain REC integrity Avoid weakening RPS w/dirty fuel types, hydro, etc. Ensure that the time frame for cost caps is as broad as possible Push for DG and solar specific carve-outs in nascent markets Emphasize opportunity for SHC and LMI Engage the end user through RECs, DG, etc. Avoid over design and ensure flexibility in RPS Effective but flexible enforcement mechanism November 25, Solar Energy Industries Association 33

34 Engage RPS Issues Combat Challengers Immediately Engagement at local level to combat challenges, lawsuits, etc. and emphasize local benefits OH: SEIA engaged w/grassroots groups opposing Seitz bill Expose the opposition for who they are (coal companies; Koch bros.; etc.) CO: Court required defendants to disclose coal company (Alpha) Coordinate & partner to leverage resources AZ: SEIA coordinated w/crs, REMA, EPA, members, others RPS stakeholders must stay engaged Understand the Process What part of RPS is statutory vs. regulatory? Ex: CO in-state requirement; ACC power (elected officials); etc. What is the best process for amending RPS? What are the risks? Start Thinking Now About RPS Expansion & Post-RPS Identify states where RPS have room to grow or don t exist yet MI, MN, CA, NY, WI, IL Develop arguments for RPS expansion before goals are met Climate; Grid Resiliency; Water Resources; Backstop; Steady Demand; Others? Anticipate technical issues as more solar comes online Ex: Interconnection concerns; duck curve What does a post-rps world look like? AZ Track and Record ; EPA Regulations; Texas Capacity Market November 25, Solar Energy Industries Association 34

35 Thank You Thank you for joining Special thank you to Galen Barbose and Lawrence Berkeley National Laboratory for contributing November 25, Solar Energy Industries Association 35

36 Contact: Questions Rick Umoff at Galen Barbose at November 25, Solar Energy Industries Association 36

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