Impacts of a Modest Carbon Tax: A Review of the Success of the Regional Greenhouse Gas Initiative

Transcription

1 Impacts of a Modest Carbon Tax: A Review of the Success of the Regional Greenhouse Gas Initiative By David T. Stevenson June 8, 2017 CATO WORKING PAPER No Massachusetts Avenue NW Washington DC Cato Working Papers are intended to circulate research in progress for comment and discussion. Available at

2 Impacts of a Modest Carbon Tax: A Review of the Success of the Regional Greenhouse Gas Initiative David T. Stevenson The nearly decade old Regional Greenhouse Gas Initiative is being recommended as a model for a national carbon tax program, and RGGI states are negotiating an extension of the program beyond To date, significant program reviews have been from RGGI, Inc., the program administrator, its paid consultants, or environmental advocacy groups. This report investigates if power plant carbon dioxide emissions reductions were actually achieved by the program, along with associated gains in health benefits, and other claims. Any such study is complicated by confounding issues. There are inherent regional differences in the electric power grid. Also, at roughly the same time RGGI started, many states began requiring increased use of premium cost, intermittent power from wind and solar energy in their Renewable Portfolio Standard (RPS) laws, and set energy efficiency requirements, which vary widely from state to state. A further complication is a number of states deregulated the supply portion of electric bills allowing market competition just prior to the start of the RGGI program. This report takes extra steps to compare RGGI states to states with comparable policies. The key results are: There were no added emissions reduction from the carbon tax, or associated health benefits. Emission reductions are consistent with national trend changes caused by new EPA power plant regulations and lower natural gas prices, and after accounting for increases in the amount of power imported by the RGGI states, reduced economic growth in RGGI states, and loss of energy intensive industries in the RGGI states from high electric rates. Energy intensity improved, and wind and solar energy generation actually increased faster in comparison states. Low income utility bill assistance from RGGI revenue added only about 1.6%, or $5 per year, to an existing federal program, and grants for wind and solar power only accounted for about 1% of all the wind and solar power added by the RGGI states. RGGI allowance costs added to already high regional electric bills, and the combined pricing impact resulted in a 13% drop in goods production and 35% drop in the production of energy intense goods, while comparison states grew goods production 15%, and only lost 4% of energy intense manufacturing. Forthcoming in Cato Journal, Vol. 38, No. 1 (Winter 2018). David Stevenson is Director, Center for Energy Competitiveness for the Caesar Rodney Institute, and was a member of the President Trump s EPA Transition Team. He has written numerous articles on both federal and state energy and environmental policies, and has been involved in legislative, and public utility commission actions. He is a plaintiff in a lawsuit against the Delaware Department of Natural Resources & Environmental Control regarding the failure to obtain legislative approval of its 2013 Administrative Rule Change authorizing a reduced number of emission allowances for the RGGI program.

3 Background Ten northeast states joined together to form the Regional Greenhouse Gas Initiative to require carbon dioxide emission allowances be bought by power plants over 25 megawatts in capacity for each ton of emissions. The states included Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont. The allowances were sold in quarterly auctions beginning in The plan was to gradually reduce the number of allowances available to achieve a 10% emission reduction by New Jersey dropped out of the plan in In 2013 the RGGI states approved increasing the emissions reduction target to 45% for 2014 with an additional 2.5% reduction per year until Allowance prices averaged about $3/ton from 2008 to 2013 ranging from about $2 to about $4. Prices rose to a high of $7.50/ton, but averaged about $5/ton from 2014 to In this report we review information (2007 to 2014 unless otherwise noted) to claims from RGGI Inc., the RGGI managing organization, in its report, The Investment of RGGI Proceeds Through 2014, and the Acadia Center report titled Regional Greenhouse Gas Initiative Status Report. Since RGGI auctions began in 2008, and 2008 was also the first year of the Great Recession, we use 2007 as the base year. Electricity Demand The change in electricity demand, by necessity, must consider the interplay of real economic growth, the details of that growth, changes in population, the impact of pricing, and of changes in energy efficiency. The regional tax on carbon dioxide emissions has an impact on these parameters. We start with the price of electricity. It is difficult to compare electric prices from state to state because of significant regional differences in power cost. Also, at roughly the same time RGGI started, many states began requiring increased use of energy sources like wind and solar in their Renewable Portfolio Standard (RPS) laws, and set energy efficiency requirements. A further complication is a number of states deregulated the supply portion of electric bills allowing market competition just prior to the start of the RGGI program. All the RGGI states deregulated. Fortunately, five non-rggi states, Illinois, Ohio, Oregon, Pennsylvania, and Texas that deregulated electric supply, in a manner similar to the RGGI states, also had significant RPS requirements. Both RGGI and non-rggi states have wide variation in their RPS programs which adds uncertainty. Increasing wind and solar power raises electric rates as they are premium priced power sources. For example, Delaware electric prices are up 9% directly related to the RPS which shows on Delmarva Power electric bills. Maryland electric bills are up 14% according to a report from the Maryland Energy Administration titled Presentation to the House Economic Matters Committee. We considered how much wind and solar the RGGI and non-rggi states added. It turns out the non-rggi comparison states added almost twice as much new wind and solar power as the RGGI states. While the difference may be related to physical factors such as better wind or solar potential, or by the better use of subsidies, the key point is premium priced wind and solar

4 power should have had a greater impact on electric prices in the non-rggi states. As we will see below, despite this disadvantage the non-rggi states still had lower overall price increases. Several states that offered limited deregulation were not included in the comparison, and New Jersey is not included as a RGGI state as it dropped out of RGGI in 2011, and California is not included as it began a carbon tax just a few years ago.. The results are shown in Figure 1 covering a period of 2002 to 2015 to capture the impact of deregulation. FIGURE 1 Electricity Price Trends 2002 to 2015 Price - Cents /kilowatt hour % +36% +52% RGGI Non-RGGI Deregulated Remaining States X NJ, CA Source; U.S. Energy Information Agency Annual Sarte Data The price trends in Figure 1 are based on an average of average state nominal prices by year for simplicity. A more accurate way to look at price changes for multi-state groups is to use a weighted average of total electric revenue for the group divided by total electric demand. We do this in Table 1 to compare average prices in 2007 to 2015 to more accurately isolate the impact of RGGI. Our calculations suggest about half the 1.8% difference between RGGI and non-rggi states is due directly to the pass through cost of RGGI allowances ($436 million 2015 RGGI revenue/$51.4 billion 2015 RGGI state electric revenue = 0.85%). The rest of the difference may be due to indirect RGGI costs. For example, when power is imported to Delaware and Maryland from the PJM Regional Transmission Organization there are premium charges for transmission distances, transmission congestion, and capacity charges. Our earlier study, Cost Impacts of 2013 RGGI Rule Changes in Delaware, demonstrates RGGI allowances directly added $11 million a year to Delaware electric bills, while the indirect costs added another $28.5 million.

5 TABLE 1 Weighted average nominal price change 2007 vs Electric Revenue Electric Revenue Demand Million Demand Million $/MWH 2007 $/MWh 2015 $Billion 2007 $ Billion 2015 MWh 2007 MWh 2015 % Change RGGI $50.8 $ $ $ % Non- RGGI $77.1 $ $90.51 $ % U.S. $343.7 $ $98.71 $ % Source: U.S. EIA Annual State Data 1990 to 2015 Since prices in RGGI states rose 64% faster than the comparison states, we see more energy intense manufacturing segments of the economy leaving the RGGI states, and slower overall real economic growth based on information from the U.S. Bureau of Economic Analysis Regional Real Chained GDP (Table 2). Please note, linking real economic growth to RGGI alone is fraught with problems. Consider real economic growth rates in RGGI states between 2007 and 2014 varied widely from a negative 7% for Connecticut, to a plus 8.2% for New York. Can we realistically claim RGGI helped New York, but hurt Connecticut at the same time? TABLE 2 Real GDP growth 2007 to 2014, $MM (latest data available in $2009) Energy Intense Total Goods Total GDP Goods State Change Connecticut % Delaware 4.1 2, % Maine % Maryland % Massachusetts % New Hampshire %

6 New York , , % Rhode Island % Vermont % RGGI Total , , % Illinois % Ohio % Oregon % Pennsylvania % Texas , , % Non-RGGI Total , , % US Total , , , , % The comparison states economies grew 2.5 times faster than the RGGI states. While the RGGI states lost 35% of energy intensive businesses (primary metals, food processing, paper products, petroleum refining, and chemicals), the comparison states only lost 4%. The RGGI states lost 13% of overall goods production, while the comparison states grew by over 15%. We see this impact show up in industrial electric demand with the RGGI states falling 17%, while non-rggi comparison states only fell 3% (Table 3). Table 3 Industrial Electric Demand (Millions of megawatt-hours) Difference % Change RGGI States % Non-RGGI States % U.S % Source: U.S. Energy Information Agency Annual State Data We also need to consider energy efficiency improvements as shown by the improvement in energy intensity which is electric demand divided by real GDP (Table 4). RGGI states

7 improved by 9.6%, while non-rggi comparison states improved faster at 11.5%. Note energy intensity improves when it goes down. Table 4 Energy Intensity 2007 to 2015 MM Megawatt-hours of Demand/Real GDP $2009 billion Electric Demand Real GDP Energy Intensity Millions MWh $ Billions MWh/$ Million % Change RGGI % Non- RGGI % U.S , , , % According to RGGI Inc., RGGI states are investing the RGGI revenue in energy efficiency projects, suggesting RGGI states should be improving energy efficiency faster than other states. Based on gains in overall energy intensity this claim appears to be false. An explanation for this disparity may be the funds are not going to energy efficiency, or the energy efficiency projects may not be working well. Both effects are seen in Delaware. We tracked RGGI revenue and expenditures from Delaware budget reports. Delaware has received $100 million in RGGI revenue, and $55 million remains unspent. Another $22 million has gone to administrative overhead and fuel assistance, with just $23 million, or 23%, going for energy efficiency projects. We did a similar analysis for Maryland and found only about 20% of RGGI revenue is reaching clients for energy efficiency projects. Furthermore, the energy efficiency projects have had minimal Evaluation, Measurement& Verification. The Delaware Department of Natural Resources & Environmental Control reported in its Annual Report on the Weatherization Assistance Program the federal program, which receives 10% of RGGI revenue, was shut down for two years while all existing projects were re-done because of various quality control issues. We can predict 2015 electric demand in the RGGI states based on the 2007 demand adjusted for economic growth, and efficiency improvements. Demand was million megawatt-hours in Table 5 highlights theoretical changes in demand in The actual demand fell 11 million megawatt-hours, close to the projected 14 million suggesting a fairly accurate analysis. Table 5 Theoretical Changes in RGGI State Demand 2007 to 2015 Millions of MWh

8 Cause % Change in Demand Economic Growth +7.1% +25 Population Growth +1% +4 Loss of Goods Producing Industry -13% -9 Overall Energy Intensity Improvement -9.6% -34 Net Theoretical Change -14 Actual Change -11 Source: author calculations Impact on Carbon Dioxide Emissions Emissions were reduced about 40% from 2007 to 2015 from electric generating units in the RGGI states (Table 6). That compares to only about a 20% reduction in emissions for the country as a whole, suggesting RGGI has been a success yielding an extra 36 million metric tons of CO 2 reduction. However, there are a number of confounding issues to be addressed. Table 6 CO 2 Emissions from Power Plants 2007 to 2015 Metric Tons Reduction % Reduction RGGI States 144,273,724 87,100,464 57,173, Non-RGGI States 635,998, ,342, ,655, US Total 2,547,032,486 2,031,452, ,558, Source: U.S. EIA Annual State Electricity Data 1990 to 2015 Delaware, followed closely by the author, provides an early example of a confounding issue. On December 17, 2008, Delaware participated in its first regional cap and trade auction. Three weeks later the Valero owned Delaware City Refinery announced the shut-down of its electric generation at the plant. CO 2 emissions from the plants electric generation facility accounted for 17% of Delaware s initial emission allocation. Valero had been gasifying petroleum coke, a waste product from the refinery, to fuel the power plant. Petroleum coke has emission rates similar to coal, but by gasifying it Valero reduced emissions of other air pollutants. So, three weeks into the RGGI program Delaware met its total 10% RGGI reduction goal. That isn t the end of the story. Valero sold the facility to PBF Energy. PBF restarted

9 portions of the power plant fueled with conventional natural gas. The petroleum coke was loaded onto ships and sent to China to be burned directly for electric generation without pollution controls! The RGGI states export CO 2 when they increase the import of electricity from other states. Between 2007 and 2015 the RGGI states doubled their importation rate from about 8% to 17%. Much of the imported power comes from the PJM transmission region. Adjusting for this drops the RGGI state emissions reductions about 11 million pounds (Table 7). Table 7 Adjustment of RGGI State CO 2 Emissions from Importing More Power MM MWh Change in Added Generation Demand Imports Generation Demand Imports Imports MM tons CO Source: U.S. EIA Annual State Electricity Data 1990 to 2015, Note conversion of MWh to metric tons of CO 2 is PJM average emission rate of generation of 1014 pounds/mwh in 2015 divided by pounds/metric tons or CO 2 emissions are way down across the country. A number of major EPA regulations have been implemented since Electric power plants have seen the most impact from regulation including the Mercury & Air Transport Standard (MATS), the Cross State Air Pollution Rule (CSAPR), the Carbon Pollution Standard for New Power Plants which established New Source Performance Standards (NSPS), and the Clean Power Plan (CPP), all targeted at reducing the use of coal, and forcing the closure of older, smaller power plants that were not worth upgrading with expensive new filtration equipment, given the low cost of natural gas. The key question is how much of the improvement in power plant emission reduction was caused by EPA regulations. As shown in Figure 2 below, nominal natural gas prices dropped significantly starting about 2009 driven by an increase in supply from the deployment of hydraulic fracturing and horizontal well drilling technology in shale formations. EPA regulations began taking effect in Lower prices played a major role in a switch from coal to natural gas for electric generation starting in 2009, and regulations impacted generation capacity starting in 2012.

10 $/MMBTU Figure 2 Nominal Fuel Prices for Electric Generation 2002 to Coal Natural Gas Source: US EIA Electric Power Monthly Total electric generation was relatively constant since 2003, but increased almost 3% from 2009 to 2016 as the economy recovered from the recession (Figure 3 below). That increase in demand was met with wind and solar power growth driven by state Renewable Portfolio Standards along with federal and state subsidies. Coal-fired generation was relatively constant until 2008, and began to fall in The fall paralleled declining natural gas prices. Natural gas generation has been increasing for decades at a relatively constant rate. Megawatt-hours 4,500,000 4,000,000 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,000, ,000 0 FIGURE 3 Electric Generation by Fuel 2003 to Coal NG Renewable Total Source; US EIA Electric Power Monthly EPA regulations did impact coal-fired generation capacity as shown in Figure 4. Many older, smaller power plants were shut down rather than invest in expensive filtration equipment that would be needed to meet new standards. The downturn in coal capacity coincides with new regulation implementation beginning in Note lower natural gas prices indirectly influenced the decisions to close down the coal-fired generation.

11 600,000 FIGURE 4 Electric Generation by Year 2003 to 2016 Megawatts of Capacity 500, , , , , Coal Generation Source: US EIA Electric Power Monthly Natural Gas Generation However, more important to coal-fired generation was the change in how often power plants ran in comparison to natural gas-fired power plants over time (Capacity Factor) which is shown in Figure 5. The decline tracks the falling natural gas price curve. 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% FIGURE 5 Generation Capacity Factors 2003 to Coal Natural Gas Source; US EIA Electric Power Monthly We can state with some certainty, nationally, coal plant capacity reductions were caused by EPA regulations, and output reductions were caused by falling nominal natural gas prices. We can parse the relative impact as shown in Table 8. The result, both nationally and for the RGGI states, is an identical 28% from lost generation capacity, and 72% from lower natural gas prices. If the RGGI allowance cost program had a significant impact it would have offset some of the impact of lower natural gas prices, and would have shifted the ratio. This result is not unexpected as RGGI allowance revenue only averaged 0.6% of electric revenue between 2007 and 2015 ($0.3 billion/$51 billion). The conclusion is RGGI had no impact on carbon dioxide reductions from coal-fired power plants.

12 Table 8 Calculations to Parse Relative Contribution of Regulation vs. Lower Natural Gas Price Formula US Total RGGI State Total 2007 Coal Generation/Coal Capacity = 2007 Rate MWH/MW 2,016,000,000 MWh / 336,040 MW = 5999 MWh/MW 76,800,000 MWh / 15,177 MW = 5080 MWh/MW 2015 Generation-2007 Generation = Net Generation Loss MWh 2,016,000,000 MWh - 1,352,000,000 MWh = 664,000,000 MWh 76,800,000 MWh - 20,800,000 MWh = 56,000,000 MWh 2015 Capacity X 2007 Rate MWh/MW = 2015 Potential 2007 Rate 304,700 MW X 5999 MWh/MW = 1,828,000,000 MWH 11,992,000 MW X 5080 MWh/MW = 60,900,000 MWh 2007 Generation 2015 Potential Generation = Generation Lost to Capacity Reduction MWh 2,016,000,000 MWh - 1,828,000,000 MWh = 188,000,000 MWh 76,800,000 MWh - 60,900,000 MWh = 15,900,000 MWh Net Generation Lost Generation Lost to Capacity Reduction = Generation Lost to Lower Natural Gas Price 664,000,000 MWh 188,000,000 MWh = 476,000,000 MWh 56,000,000 MWh 15,900,000 MWh = 40,100,000 MWh Generation Lost to Capacity Reduction / Net Generation Loss = % Loss to Capacity Reduction 188,000,000 MWh / 664,000,000 MWh = 28% 15,900,000 MWh / 56,000,000 MWh = 28%

13 Generation Lost to Lower Natural Gas Price / Net Generation Loss = % Loss to Lower Natural Gas Price 476,000,000 MWh / 664,000,000 MWh = 72% 40,100,000 MWh / 56,000,000 MWh = 72% Source of generation & capacity data id US Energy Information Agency Annual State Data Coal plant emission reductions need to be amended by added natural gas generation, and decreased generation from petroleum fueled power plants. Natural gas-fired generation increased 18.2 megawatt-hours. Generation from petroleum-fired power plants dropped 5.2 million megawatt-hours for the same reasons coal-fired generation fell. Table 9 shows the total net estimated emission reduction of 58.8 million metric tons compared an actual reduction of 57.2 million metric ton reduction, suggesting the actual reduction is accounted for without any additional contribution from the RGGI program. Fuel Table 9 CO 2 Calculated Emission Change Compared to Actual 2007 to 2015 Est. Lost Generation CO 2 Emission CO 2 Emission Millions megawatt-hours Rate/MWh Reduction MM Metric Tons Coal Natural Gas Petroleum Imported Power Calculated Reduction 58.8 Actual Reduction 57.2 Note: Emission Rates from US Energy Information Agency

14 We come to the same conclusion when we look at the generation mix in Table 10. Coalfired generation drops 16 percentage points in both RGGI and non-rggi comparison states and has the roughly the same 10 percentage point gain in natural gas-fired generation. Natural gas emits about half the amount of CO 2 for each megawatt-hour of power produced. Table 10 Generation Mix % Change 2007 to 2015 Fuel RGGI 2007 RGGI 2015 Non-RGGI 2007 Non-RGGI 2015 Coal Petroleum Natural Gas Nuclear Hydro Other Wind & Solar Biomass & Wood Source: U.S. Energy Information Agency Electric Power Monthly Notice how the non-rggi comparison states actually added more wind and solar generation adding 5% to generation compared to the RGGI states adding 3%. Some RGGI auction revenue was invested in solar energy projects, but reports from RGGI Inc. identify less than 100 MW of solar capacity which would account for only about 1% of the wind and solar capacity added in the RGGI states. Clearly the RGGI program had almost no impact on the amount of wind and solar power added. Low Income Program According to RGGI Inc. 15% of RGGI revenue, or $178.2 million, went to direct low income electric bill assistance to 2.6 million households from the beginning of the RGGI auctions through That is roughly $68/household, spread over 6 years. RGGI provided about $30 million a year toward the Low Income Home Energy Assistance Program, or LIHEAP. According to the U.S. Department of Health and Human Services in its LIHEAP Report to Congress for Fiscal Year 2014, it provided $795 million to the RGGI states. So, RGGI added less than 4% to LIHEAP. But, we have to account for higher electric rates caused by the RGGI allowances.

15 According to the Analysis Group in their report The Economic Impacts of the Regional Greenhouse Gas Initiative on the Ten Northeast and Mid-Atlantic States, page 15, within the electric system, the impacts of these initial (RGGI) auctions show up during the period, as power plant owners priced the value of CO 2 allowances into prices they bid in regional wholesale prices. A flow diagram on page 22 shows how the auction costs flow from the electric generators to the electric distributors, and on to consumers. We agree RGGI allowance costs flow to consumers on their electric bills. RGGI allowance revenue totaled $1.8 billion through 2014, or $294.3 million a year spread over 348 million megawatt-hours of demand a year or $0.85/megawatt-hour. RGGI state residential electric demand has been fairly flat, and averaged million megawatt-hours/year. According to the U.S Census there were 17.3 million households in the RGGI states. So, residential electric demand averaged 7.6 megawatt-hours per year (130.9/17.3), or 45.6 megawatt-hours over 6 years. The total cost of RGGI equaled $39/household over six years ($0.85 X 45.6). This reduces the net contribution to low income households to $29 over 6 years ($68-$39), about $5/year. Therefore, the RGGI contribution to the federal LIHEAP was only 1.6% of the RGGI state program. Conclusions Changes in electricity demand can be accurately accounted for by changes in GDP, population, and non-rggi related energy efficiency improvements. Net weighted average nominal electricity prices rose 4.6% in RGGI states compared to 2.8% in comparison states (half the difference due to direct RGGI cost pass through), and 5.5% nationally. Electricity pricing is complicated by other policies such as deregulation of supply prices, requirements for premium priced wind and solar power, and by dramatic decreases in the cost of natural gas. We used a 2002 to 2015 time frame to consider the total impact on nominal electricity prices of state energy policies and find electricity prices rose 57% in RGGI states, 36% in comparison states, and 52% for all states. Linking real economic growth to RGGI alone is fraught with problems. Consider real economic growth rates in RGGI states between 2007 and 2014 varied widely from a negative 7% for Connecticut, to a plus 8.2% for New York. Can we realistically claim RGGI helped New York, but hurt Connecticut at the same time? Also average RGGI revenue only amounted to 0.01% of the combined average real GDP of the RGGI states, so we wouldn t expect much impact. We did attempt a comparison by carefully selecting comparison states and found real economic growth was 2.5 times faster in comparison states than in the RGGI states. High electric rates led to a 35% reduction in energy intensive industries, and a 13% drop in the goods production sector while comparison states saw only a 4% drop in energy intensive industries, and a 15% gain in goods production. The RGGI states saw a lower improvement in energy intensity at 9.6% compared to 11.5% for comparison states, so there appears to be no RGGI related gain in overall energy efficiency. We discuss potential disconnects between the RGGI Inc. energy efficiency estimates, and the real facts on the ground.

16 There were no added emissions reduction from the carbon tax. Emission reductions are consistent with national trend changes caused by new EPA power plant regulations and lower natural gas prices, and after accounting for increases in the amount of power imported by the RGGI states, reduced economic growth in RGGI states, and loss of energy intensive industries in the RGGI states from high electric rates. Wind and solar energy installation was slower in RGGI states only increasing by 3 percentage points, while comparison states grew by 5 percentage points, almost twice as fast. We estimate the investment of RGGI revenue in wind and solar energy projects had no significant impact on building new wind and solar energy generation capacity. Since RGGI did not lead to decreased emissions in RGGI states there are no added health or environmental benefits from the program. The net fuel assistance help for low income households, 15% of all households, only added 1.6% to the federal Low Income Home Energy Assistance Program, or less than $5/year. RGGI had no meaningful impact on lower income families. Meanwhile, the other 85% of households saw an increase in electricity cost of $6.50/year directly caused by the RGGI allowance cost. All households, including low income households, would have been better off with better energy policies, instead of the fuel assistance programs. References Acadia Center (July 2015) Regional Greenhouse Gas Initiative Status Report. Hibbard, P.J., Tierney, S.F., Okie, A.M., and Darling, P.G. (November 2011) The Economic Impacts of the Regional Greenhouse Gas Initiative on Ten Northeast and Mid-Atlantic States Analysis Group 15 and 22 RGGI Inc. (September 2016) The Investment of RGGI Proceeds through Small, David (March 20, 2012) Annual Report on the Weatherization Assistance Program, Delaware Department of Natural Resources & Environmental Control Stevenson, D.T., Stapleford, J.E. (August 2016) Cost Impacts of 2013 RGGI Rule Changes in Delaware, Caesar Rodney Institute 2 Tung, Mary Beth (2016) Presentation to the House Economic Matters Committee RPS Requirement and Aggregated Cost of RPS, Maryland Energy Administration 17 U.S. Department of Health and Human Services (2014) LIHEAP Report to Congress for Fiscal Year 2014 Division of Energy Services 10-11