1. The Regulatory Assistance Project 50 State Street, Suite 3 Montpelier, VT 05602 Phone: 802-223-8199 web: www.raponline.org Tracking Renewable Energy for US EPA’s Clean Power Plan October 22, 2014 North Dakota Alliance for Renewable Energy, Bismarck State College National Energy Center of Excellence, Bismarck, ND David Farnsworth, Senior Associate

2. Overview of Presentation The Clean Power Plan –Cooperative Federalism—111(d) Numerous Compliance Options, including a role for Renewable Energy –Policies –Technologies and Practices –Observations 2

3. Options to reduce emissions through the use of low- or non-emitting generation (emphasis added) Increase use of existing NGCC Build new NGCC Use and/or increase use of existing utility scale renewables Build new utility scale renewables including: –Wind –Solar –Geothermal –New Hydro Build new distributed renewables Incremental hydro at existing facilities (capacity uprates) Uprates at existing nuclear power plants Use of energy storage to increase utilization of existing or new low- or zero-emitting technologies 3

4. 111(d) Compliance: the Case for Renewables Build on existing policies, technologies and practices: –E.g., RPS, net-metering, and group net- metering –Tracking Systems 4

5. Renewable Portfolio Standards 5

6. 6 Net Metering

7. 7 Voluntary Systems

8. 8 Tracking Systems Are Already Interstate

9. The Case for Renewables cont. What is essential about tracking systems? –Ownership –Retirement –Regional –Similar platforms nationwide 9

10. Platform: Generation attribute severable from the underlying energy 10

11. Attribute Certificate—GATS Example 11

12. Attribute Certificate—GATS Example 12

13. Systems are a Series of Accounts 13

14. How the Systems Work 14

15. How the Systems Work—cont. 15

16. Demonstrating Compliance Serving expanded RE policies –In a rate-based program—lb. CO2/Mwh –In a mass-based program—tons/year How well does REC reflect CO2 attribute? –Produced in one region & sold into another –Need to establish and apply reasonable emissions factors 16

17. Compliance in Capped Regions Capped regions will need to adjust caps to reflect incremental RE production? –One model: RGGI Voluntary RE Set-Asides Adjust cap to reflect RE carbon attributes sold/claimed beyond region? Will this be de minimus or a cost to RE developers? Will originating states continue to support RE development through a production-based true up? 17

19. Thank you—questions?

20. The Regulatory Assistance Project (RAP) is a global, non-profit team of energy experts, mostly veteran regulators, advising current regulators on the long-term economic and environmental sustainability of the power and natural gas sectors. (www.raponline.org)www.raponline.org David Farnsworth has been with RAP since 2008. He served as a hearing officer and staff attorney with the Vermont Public Service Board from 1995 to 2008. From 2003 to 2008, he was a member of the Regional Greenhouse Gas Initiative (RGGI) Staff Working Group. 20