Potential Impacts to Texas of EPA s Clean Power Plan. Brian Tulloh Austin Electricity Conference April 9, 2015

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1 Potential Impacts to Texas of EPA s Clean Power Plan Brian Tulloh Austin Electricity Conference April 9, 2015

2 Luminant Is Texas Largest Competitive Power Generator 15.4 GW of generation capacity: 8.0 GW coal (49 GWh/yr) 2.3 GW nuclear (19 GWh/yr) 5.1 GW natural gas (<1 GWh/yr) High-performing nuclear and coal plant operator Top 10 U.S. coal-mining operations One of the largest purchasers of windgenerated electricity Recipient of more than 90 environmental awards Source: EnergyFutureHoldings.com,

3 Texas Includes Multiple Grids / Reliability Entities Source: Association of Electric Companies of Texas (AECT), Electricity 101 2

4 Texas Improved Its Emissions Profile Before EPA s CPP Renewable/other 3% Nuclear 11% Gas 45% Wholesale competition in ERCOT 38 GW of new natural gas-fired generation Renewable/other Nuclear 9% 9% Gas 50% 41% 12 GW of new wind generation 32% Coal 17+GW of older, less efficient generation retired or mothballed Coal 329 TWh electricity 217 million tons CO 2 1,322 lbs CO 2 /MWh 430 TWh electricity 250 million tons CO 2 1,165 lbs CO 2 /MWh Source: EIA, PUCT 3

5 EPA Assumes Dramatic Redispatch of Texas Fleet in 111(d) Texas Emission Rate (EPA formula lb CO 2 /MWh) 2012 Texas Baseline 1,292 Block 1 Heat rate improvements 49-4% (6% efficiency improvement at coal units) Block 2 Re-dispatch of fleet % (70% CCGT utilization) 1 Block 3 More renewables, nuclear % (20% RPS + some nuclear) Block 4 Demand-side reductions 70-5% (end-user energy efficiency 1.5% /yr improvement) 2030 Texas Target % total reduction EPA s proposal calls for a 39% reduction in the Texas emission rate (per the 111(d) formula). Texas reduction would be even more severe on a mass basis. Source: IHS CERA: Digesting EPA s Proposed Clean Power Plan ; June 10, 2014 Webcast 1. From 45% in Texas, 2012; shifts 72 million MWh from coal to gas (52% of Texas 2012 coal generation) 4

6 EPA Assumptions Yield Differentiated State Impacts 2000 Carbon Emission Rate Target by State in 2030 Pounds of CO 2 per MWh Simple average = Washington Idaho Oregon Maine New Hampshire New Jersey California Connecticut New York Massachusetts Nevada Mississippi Arizona Florida South Dakota South Carolina Rhode Island Texas Virginia Georgia Delaware Minnesota Louisiana Oklahoma Arkansas North Carolina Alaska New Mexico Pennsylvania Alabama Colorado Michigan Tennessee Maryland Wisconsin Illinois Iowa Hawaii Utah Ohio Nebraska Kansas Indiana Missouri West Virginia Wyoming Kentucky Montana North Dakota EPA s 2030 state targets vary widely; Texas is 20% more stringent than average Source: From EPA worksheet: tsd state goal data computation 5

7 EPA Assumptions Yield Differentiated State Impacts Carbon Emission Reductions, 2020 vs Millions of tons of CO 2 per year (reductions by 2020 relative to 2012 baseline) Texas Florida Arizona Illinois Arkansas Louisiana Oklahoma Georgia Michigan Pennsylvania Alabama Minnesota Missouri Colorado Indiana Wisconsin Ohio North Carolina Iowa South Carolina New York Utah Kentucky Mississippi Tennessee West Virginia New Mexico Washington Nevada Wyoming Nebraska North Dakota Kansas New Jersey Oregon Maryland Massachusetts South Dakota Montana New Hampshire Delaware Virginia Connecticut Alaska Hawaii Maine Idaho Rhode Island California Texas called upon to provide 18% of total U.S. CO 2 reductions, despite being only 11% of 2012 CO 2 emissions. Majority of annual CO 2 reductions frontloaded to 2020 despite 2030 target. Source: From EPA worksheet: tsd state goal data computation reflecting Block 1 and 2 changes to fossil fleet 6

8 Block 2: State Impacts of EPA s Assumed Re-Dispatch EPA s Assumed Reduction in Coal Generation for Top 15 Coal States Million MWh less than 2012 baseline Texas Indiana Pennsylvania Ohio Kentucky Illinois Missouri West Virginia Michigan North Carolina Alabama Florida Wyoming Georgia Colorado % of 2012 Texas provides largest share of reductions in coal generation; 19% of U.S. total Source: Derived from EPA worksheet: tsd state goal data computation changes in coal dispatch (Block 2) 7 52% 5% 10% 7% 1% 16% 11% 0% 23% 33% 22% 91% 1% 34% 34%

9 Block 3: State Impacts of EPA s Assumed Increases in Renewable Energy (RE) EPA s Assumed Changes in RE for Top 10 RE States Million MWh/yr by 2030 Texas 86 California 41 Iowa Minnesota Oklahoma 2012 RE Increase in RE Decrease in RE Illinois Washington Oregon Colorado North Dakota Texas is assumed to increase from 34 million MWh in 2012 to 86 million MWh in 2030 (+153%); California increase = 37%; Iowa and Minnesota decrease Source: Balanced Energy for Texas, July Depicts top 10 states based upon 2012 renewable generation, excluding existing hydro resources. 8

10 Texas Coal Unit Retirements EPA s CPP Projections ERCOT 8.8 GW SPP 4 GW Plant (# Units) Capacity (MW) Projected Retirement Year Big Brown (2) Coleto Creek (1) Fayette (3) Gibbons Creek (1) J T Deely (2) Base Case Monticello (2) San Miguel (1) W A Parish (4) (2); (2) Harrington (3) (1); (2) Oklaunion (1) Pirkey (1) Welsh (3) Base (1); 2016 (2) Total =12.8 GW Source: EPA s IPM modeling, Base case unit retirements; BET analysis 9

11 ERCOT Projected Reserve Margins are Tight and At Risk ERCOT Summer Reserve Margin (RM) ; Percent % target reserve margin CPP retirement of ~8 GW could reduce 2020 RM by ~11 points. In combination with other EPA rules, ERCOT estimated an impact that could reduce ~12 RM points %? ERCOT is tight even before considering environmental retirements CPP and other environmental retirements could tighten the market further below target, which could threaten reliability and increase costs for consumers 1 Source: ERCOT Capacity, Demand and Reserves (CDR) Report, December 2014 and May 2014; current reserve margin formula = (resources firm peak demand) / firm peak demand. 2 ERCOT: Impacts of Environmental Regulations in the ERCOT Region, December 16, 2014, citing potential for 8.7 GW of coal retirements. 10

12 Projected Price Increases due to CPP in Texas Texas Delivered Electricity Prices Annual Average 2020 through 2030; 2013 cents/kwh 1 Baseline (No CPP) CPP Building Blocks 2 +25% +31% +26% +27% Residential Commercial Industrial Total NERA s analysis on impact of CPP in Texas: 25% to 31% retail price electricity increases across segments Represents nearly $9 billion/year in added costs to consumers 1 NERA: Impacts of the EPA Clean Power Plan Building Blocks on Texas Energy Markets November 2014 (Appendix A to Luminant comments) 2 Building Blocks scenario attempts to reflect EPA building block assumptions; excludes customer portion of energy efficiency costs, A/S, etc. 11

13 Appendix Back-up 12

14 Fuels used for electricity in ERCOT compared with U.S. average ERCOT U.S. Average Capacity (MW) Energy (MWh) Wind 10% Nuclear 12% 37% Coal Wind Nuclear 13% 6% Coal 23% 1% 1% Other 41% Other 56% Natural Gas Natural Gas Hydro Non-Hydro Renewables (Mostly Wind) 6% Nuclear 19% 7% 1% Hydro Non-Hydro Renewables 7% 5% (Mostly Wind) 7% Nuclear Coal 9% 29% Other (Mostly Petroleum) 39% 27% 42% Natural Gas Coal Other (Mostly Petroleum) Natural Gas Note: Oil-fired generation is negligible in ERCOT, accounting for less than 0.1% of ERCOT capacity and load; numbers may not add up to 100% due to rounding. Sources: ERCOT (2013 data for energy; 2014 data for capacity); EIA (2013 data for energy, 2012 data for capacity) 13

15 REPs and offers in large competitive regions of Texas AEP Texas North Service Territory 76 One-Year Fixed Price Offers 263 Total Offers Oncor Service Territory 85 One-Year Fixed Price Offers 296 Total Offers 72 One-Year Fixed Price Offers 243 Total Offers AEP Texas Central Service Territory 72 One-Year Fixed Price Offers 242 Total Offers CenterPoint Energy Service Territory 88 One-Year Fixed Price Offers 300 Total Offers Source: Power to Choose, as of November 19,

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