OVERVIEW OF THE 2013 ANNUAL LOOKING FORWARD REPORT Presented to The SPP Board of Directors – Members Committee By BOSTON PACIFIC COMPANY, INC. Craig R

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  • OVERVIEW OF THE 2013 ANNUAL LOOKING FORWARD REPORT Presented to The SPP Board of Directors Members Committee By BOSTON PACIFIC COMPANY, INC. Craig R. Roach, Ph.D. Vincent Musco Andrew Gisselquist Sam Choi April 30, 2013
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  • PURPOSE A.Report contributes to longer-term strategic planning by the Board B.Received Oversight Committee input in March C.Nine issues in all, including four updates 2BOSTON PACIFIC COMPANY, INC.
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  • EXECUTIVE SUMMARY I.The Shale Gas Revolution (An Update) II.EPAs Continuing Campaign on Coal (An Update) III.Developments Driving the Future of Transmission Planning IV.The Future of U.S. Electricity Bills: Flat Demand, Rising Rates? V.Electric Vehicles (Update) VI.Distributed Generation as a Component of Demand Response VII.Other Issues of Note: Dodd-Frank, Future of Nuclear Power (An Update), Drivers Toward a Less-Centralized Grid 3 BOSTON PACIFIC COMPANY, INC.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) 4BOSTON PACIFIC COMPANY, INC.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) A.Alive and Well: IHS Global Study 1.Today: American production is 65 Bcf/day, about 50% from shale and tight gas 1 2.Year 2035: American production will be 100 Bcf/day, 80% from shale and tight gas 2 3.Over period from 2012 to 2035, shale gas production up by a cumulative 127% 3 5BOSTON PACIFIC COMPANY, INC. 1. IHS Global, Americas New Energy Future: The Unconventional Oil and Gas Revolution and the US Economy-Volume 1: National Economic Contributions, October 2012. 2. Ibid. 3. Ibid., 19, Production Table.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) 4.Price (Henry Hub in real terms): IHS Global a.Rise in near term (to $4.37/MMBtu in 2015) 4 b.Stable thereafter ($5.07/MMBtu by 2035 in real terms) 5 6BOSTON PACIFIC COMPANY, INC. 4. IHS Global, Americas New Energy Future, 19, Production Table. 5. Ibid.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) B.It is Really An Economic Revolution: IHS Global 1.$3 trillion investment (2012 to 2035), unconventional gas 6 2.2.1 million jobs (Direct, Indirect, Induced) 7 3.Federal taxes total $635 billion, state and local $700 billion over period from 2012 to 2035 8 7BOSTON PACIFIC COMPANY, INC. 6. IHS Global, Americas New Energy Future, 2. 7. Ibid., 7, 25. 8. Ibid., 35.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) C.Assessing Environmental Concerns 1.Net Greenhouse Gas Emissions a.NREL/JISEA Study: still less than half those of conventional coal- fired power 9 2.Water Quality Concerns a.EPA: not enough data, but wait until 2014 b.Water acquisition can be a local issue in drought states (TX, OK) c.Comprehensive water cycle assessment (please see chart) 10 8BOSTON PACIFIC COMPANY, INC. 9. JISEA, Natural Gas and the Transformation of the U.S. Energy Sector: Electricity, November 2012. 10. U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources, December 2012.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) Water Use in Hydraulic Fracturing Operations 9BOSTON PACIFIC COMPANY, INC. Water Acquisition Hydraulic fracturing fluids are usually water-based, with approximately 90% of the injected fluid composed of water. Estimates of water needs per well have been reported to range from 65,000 gallons for coalbed methane (CBM) production up to 13 million gallons for shale gas productionFive million gallons of water are equivalent to the water used by approximately 50,000 people for one day. (U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing, 14. Internal citation omitted.) Chemical Mixing Once onsite, water is mixed with chemicals to create the hydraulic fracturing fluid that is pumped down the wellThe fluid serves two purposes: to create pressure to propagate fractures and to carry the proppant into the fractureRoughly 1% of water-based hydraulic fracturing fluids are composed of various chemicals (U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing, 15.) Well Injection The hydraulic fracturing fluid is pumped down the well at pressures great enough to fracture the oil- or gas-containing rock formation (U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing, 16.)
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  • I. THE SHALE GAS REVOLUTION (UPDATE) Water Use in Hydraulic Fracturing Operations (Continued) 10BOSTON PACIFIC COMPANY, INC. Flowback and Produced Water Wastewater Treatment and Waste Disposal When the injection pressure is reduced, the direction of fluid flow reserves, leading to the recovery of flowback and produced water. For this study, flowback is the fluid returned to the surface after hydraulic fracturing has occurred, but before the well has been placed into production They are collectively referred to as hydraulic fracturing wastewater (U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing, 18.) Estimates of the fraction of hydraulic fracturing wastewater recovered vary by geologic formation and range from 10% to 70% of the injected hydraulic fracturing fluid. (U.S. Environmental Protection Agency, Study of the Potential Impacts of Hydraulic Fracturing, 19. Internal citation omitted.)
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  • I. THE SHALE GAS REVOLUTION (UPDATE) D.To Export or Not to Export: NERA Study 1.Resource availability has larger price effect than exports Selected Scenario Results For 2035 11 11BOSTON PACIFIC COMPANY, INC. 11. NERA Economic Consulting, Macroeconomic Impacts of LNG Exports from the United States, 2012, 11, fig. 6.
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  • I. THE SHALE GAS REVOLUTION (UPDATE) 2.Net economic impact of exports: NERA study 12 Change in Income and Total GDP (Billions of 2010$) 12BOSTON PACIFIC COMPANY, INC. 12. NERA Economic Consulting, Macroeconomic Impacts of LNG Exports from the United States, 2012,8, fig. 3.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL 13BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL A.Truly, a Campaign 1.Mercury and Air Toxics Standards and Regional Haze Rule 2.See multi-page list of regulations a.Air (new) Greenhouse Gas Emissions b.Air (new) Interstate NO X / SO 2 c.Air (revised) NAAQS d.Solid Waste and Water (new) 14BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL Environmental Regulations Impacting the Electric Power Sector NAMEDESCRIPTIONSTATUSIMPACT AIR GREENHOUSE GAS (GHG) EMISSIONS GHG New Source Performance Standards (NSPS) for New Units Restricts GHG emissions from new fossil-fuel-fired electric generating units to the emissions of natural gas combined- cycle technology (1,000 pounds of CO 2 per MWh). Coal plants will need carbon capture and storage technology or the equivalent. This requirement is considered in issuing units preconstruction permits and is incorporated into their operating permits. These permits are generally enforced by states. Proposed March 2012; final rule may be issued soon. This rule would prevent new traditional coal generation from being built. According to the EPA the rule will result in only negligible costs by 2020 because market conditions are leading away from coal. GHG New Source Performance Standards (NSPS) for Existing Units Under Clean Air Act section 111(d), once the EPA has issued GHG regulations for new plants, it must issue guidelines for states to use in drafting plans setting standards of performance for existing fossil-fuel-fired electric generating units. The level and structure of future guidelines are unknown, but, in 2008, EPA indicated it wanted power plants to improve their operating efficiency by two to five percent. Not yet proposed, but must be issued because of settlement agreement and Clean Air Act. The cost of efficiency improvements is unknown. However, the EPA did state that biomass co-firing could substitute for efficiency improvements, indicating that EPA may be flexible about potential compliance methods. 15BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL GHG Prevention of Significant Deterioration (PSD) Requirements Requires construction or operating permits for sources subject to PSD or Title V permitting anyway and that emit at least 75,000 tons per year CO 2 e. Also requires permits for any existing source that emits at least 100,000 tons per year CO 2 e and increases emissions by at least 75,000 tons per year CO 2 e; new sources that emit 100,000 tons per year CO 2 e also require permits. Implemented by states. Currently in effect and states are issuing permits. A workgroup has been formed to discuss streamlining the permitting process. EPA estimates that about 900 additional PSD permitting actions will be triggered each year by new and modified emission sources, including power plants. Permits may do no more than require the use of best practices. AIR MULTIPLE POLLUTANT REGULATIONS Mercury and Air Toxics Standards (MATS) Limits emissions of mercury, other heavy metals like arsenic, and acid gases such as hydrochloric acid from new and existing coal- and oil-fired electric utility steam generating units. Compliance by existing sources is required by April 16, 2015, but state permitting authorities can provide a one-year extension. Generally implemented by states. Environmental controls must comply with the Maximum Achievable Control Technology requirement in the Clean Air Act. This rule became effective April 16, 2012. The EPA then slightly modified the portion of the standard applying to new sources on March 28, 2013. According to the EPA, MATS may cause 4.7 GW to retire by 2015, increasing average U.S. retail electricity prices by 3.1 percent in 2015. Other estimates vary: RFF estimates 4 GW of retirements and 1 percent higher average electricity prices by 2020; NERA estimated 19 to 23 GW of coal retirements through 2015. Clean Air Interstate Rule (CAIR) / replacement rule for Cross-State Air Pollution Rule (CSAPR) CAIR requires (and the vacated CSAPR required) certain states to limit annual SO 2 and NOx emissions so downwind states can achieve the ozone and PM 2.5 NAAQS. CSAPR, originally intended to replace CAIR, was vacated in August 2012. CAIR is temporarily reinstated until a replacement rule is issued. The replacement rule and potential costs are unknown. However, EPA estimated that CSAPR could increase electricity rates by as much as 1.7 percent. CAIR was projected to increase electricity rates by as much as 2.7 percent. 16BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL Regional Haze rule Limits pollutants such as NOx, SO 2 and particulate matter that impair visibility in national parks and wilderness areas. The measures apply Best Available Retrofit Technology. Implemented by states. State Implementation Plans (SIPs) were originally due to the EPA by 2007. Many were filed late. EPA was under a consent decree to approve revised SIPs or issue Federal Implementation Plans (FIPs) before the end of 2012. However, at least some remain unresolved. EPA estimated that, assuming CAIR would be implemented, this rule would affect 491 coal units, or 218 GW, and increase national retail electricity prices by 0.1 percent on average in 2015. Some regions would experience higher costs than others. AIR NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) Revisions to Primary NAAQS for ozone Limits levels of ozone in the atmosphere to protect public health. Currently set at 75 parts per billion (ppb), based on an eight-hour standard. This value is currently under review. A 2011 rulemaking postponed by President Obama had set the ozone NAAQS at 70 ppb based on the advice of the EPAs Clean Air Scientific Advisory Committee to set the standard between 60 and 70 ppb. Current NAAQS for ozone was announced in March 2008. EPA is projected to issue a Notice of Proposed Rulemaking on an update by early 2014. The EPA is required to review and, if appropriate, revise this standard every five years. Based on the 2011 proposal postponed by President Obama, with a limit of 70 ppb, EPA estimated national annual costs for all affected sources in 2020 at $19 to $25 billion (2006$); if 60 ppb, $52 to $90 billion. Revisions to Primary NAAQS for SO 2 Limits the concentration of SO 2 in the atmosphere to protect public health. Currently set at 75 ppb, based a one- hour standard. In 2009, the EPAs Clean Air Scientific Advisory Committee endorsed a 1-hour standard with a range of 50 to 150 ppb. Also requires additional monitors to be installed nationwide. This standard was set in 2010. The EPA is required to review and, if appropriate, revise this standard every five years. EPA estimates that Electric Power Generation, Transmission, and Distribution sectors will incur annualized costs in 2020 of $699 million (2006$). New monitors could increase compliance obligation. 17BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL Revisions to Primary NAAQS for NO 2 Limits the concentration of NO 2 in the atmosphere to protect public health. Currently set at 100 ppb, based on a one-hour standard. This is consistent with the EPAs Clean Air Scientific Advisory Committees recommendations from 2009 of 80 to 100 ppb. Also requires additional monitors to be installed. This standard, set in 2010, is in effect but being reviewed. A NOPR is projected to be issued in January 2016. The EPA is required to review and, if appropriate, revise this standard every five years. EPA did not estimate any costs to the electric generating unit (EGU) sector. Updated monitoring may change this conclusion. New monitors could increase compliance obligation. Primary NAAQS for Particulate Matter (2.5) Limits levels in air of fine particulate matter to protect public health. Current standard is an annual average of 12 micrograms per cubic meter. In 2010, the EPAs Clean Air Scientific Advisory Committee supported a standard of between 11 and 13 micrograms per cubic meter. Final rule announced December 2012. The EPA is required to review and, if appropriate, revise this standard every five years. EPA did not estimate specific costs to EGUs of attaining this standard because EGUs were estimated to not have to reduce emissions beyond what was already required by MATS. SOLID WASTE Coal Combustion Residuals Will regulate the disposal of coal combustion residuals. The rule has two regulatory options. If CCRs are classified as hazardous waste, EPA will create requirements for their disposal in hazardous waste facilities. If deemed not hazardous, EPA will establish minimum national technical criteria, such as composite liner requirements, for states to include in their own regulations. Announced May 2010; final rule projected to be issued in 2014. EPA estimated that electricity rates could increase by 0.2 percent if CCRs were classified as non-hazardous and 0.8 percent if classified as hazardous. However, an industry estimate that examined broader upstream and other cost components was several times higher. 18BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL WATER Revisions to Steam Electric Power Effluent Limitation Guidelines and Standards Updates effluent guidelines and standards for steam electric power generating plants to limit the pollutants discharged into surface waters. Much of this pollution is from coal ash ponds and flue gas desulfurization wastes. Among the changes could be requiring waste disposal in landfills instead of surface impoundments and eliminating wastewater streams by converting waste handling systems from wet to dry handling. In line with a consent decree, the proposed rule was issued in April 2013. A final rule is expected in 2014. This rule was last updated in 1982; EPA is required to annually review it, and revise if appropriate. EPA says this could apply to 1,200 nuclear and fossil- fueled plants, though will cause no coal plant retirements and cost less than $1 billion annually. Affected sources will need to comply upon renewing their National Pollutant Discharge Elimination System (NPDES) permit, which lasts five years. Cooling Water Intake Structures, CWA 316(b) Requires existing electric generators that withdraw more than 2 million gallons of cooling water per day to limit how many fish are killed by being pinned against intake screens. New units added to existing facilities must produce results equal to at least 90 percent of closed-cycle cooling technology (i.e., cooling towers). Plants built after 2002 (new under this regulation) are already required to use such technology. Proposed rule issued in Spring 2011; final rule projected for June 2013. EPA estimated annualized costs for direct compliance by existing electric generators to be $386 million (2009$); a study commissioned by the Natl Association of Manufacturers estimated annualized costs of $8 billion. 559 EGUs are expected to be affected by this rule, over 45 percent of electric capacity. 19BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL B.U.S. Greenhouse Gas Emission Profile 1.A Powerful Patchwork Policy a.Federal Proposed EPA greenhouse gas New Source Performance Standards and joint rules for vehicle Corporate Average Fuel Economy and greenhouse gas emissions b.State Renewable portfolio standards and energy efficiency standards c.State Regional Greenhouse Gas Initiatives cap-and-trade program d.State Californias cap-and-trade program e.Local New York Citys plaNYC and Boulder, CO exploring municipal power to combat and/or adapt to climate change 20BOSTON PACIFIC COMPANY, INC.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL 2.On Track With Presidents Promise a.RFF: 16.3% cut in GHG by 2020 as compared to 2005 Sources of Emissions Reductions 13 EPA Regulations: 10.5% Fuel Price and Efficiency: 3.3% State Cap-and- Trade, RPS: 2.5% 21BOSTON PACIFIC COMPANY, INC. 13. Resources for the Future, U.S. Status on Climate Change Mitigation, October 2012, 10, fig. 4.
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  • II. EPAS CONTINUING CAMPAIGN ON COAL C.Case Study Public Service Company of Oklahoma 1.Regulation: Regional Haze Rule & Mercury and Air Toxics Standards 2.Settlement on two coal units at Northeastern Station a.Retire one coal unit by 2016 b.Replace first unit with natural gas-fired combined cycle 15-year PPA with Calpine Oneta c.Retrofit the second coal unit with DSI/ACI/FF in 2016 d.Retire second, retrofitted unit in 2026 3.Oklahoma Commission stayed case on cost recovery until EPA approves State Implementation Plan 22BOSTON PACIFIC COMPANY, INC.
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  • III. DEVELOPMENTS DRIVING THE FUTURE OF TRANSMISSION PLANNING 23BOSTON PACIFIC COMPANY, INC.
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  • III. DEVELOPMENTS DRIVING THE FUTURE OF TRANSMISSION PLANNING A. FERC Order No. 1000 (two parts selected for discussion) 1.End of right of first refusal a.Is this PURPA for transmission? b.States may determine impact through state-ROFR (ND, SD, MN, NE, NM) 2.Interregional Planning a.Midwest ISO, Entergy, and loop flow 24BOSTON PACIFIC COMPANY, INC.
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  • III. DEVELOPMENTS DRIVING THE FUTURE OF TRANSMISSION PLANNING B.Cost-Benefit Scrutiny 1.The IPL Case at FERC $170.5 million cost, no commensurate benefits 14 C.HVDC Breakthrough D.Cybersecurity E.Distributed Generation 25BOSTON PACIFIC COMPANY, INC. 14. Interstate Power and Light Company, Complaint to FERC against ITC Midwest, LLC, Docket No. EL12-104-000 (September 14, 2012), 9.
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  • IV. THE FUTURE OF MONTHLY ELECTRICITY BILLS: FLAT DEMAND, RISING RATES? 26BOSTON PACIFIC COMPANY, INC.
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  • IV. THE FUTURE OF MONTHLY ELECTRICITY BILLS: FLAT DEMAND, RISING RATES? A. Residential Bills Have Flatlined Average U.S. Residential Monthly Bill (2011$) 15 27BOSTON PACIFIC COMPANY, INC. 15. U.S. Energy Information Administration, Electric Sales, Revenue, and Average Price, U.S. EIA website, last modified September 27, 2012, http://www.eia.gov/electricity/sales_revenue_price/. http://www.eia.gov/electricity/sales_revenue_price/
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  • IV. THE FUTURE OF MONTHLY ELECTRICITY BILLS: FLAT DEMAND, RISING RATES? B.Stars Aligned Now, But Just Wait For Cost Increases 1.Natural gas prices reach equilibrium 2.Interest rates rise to reality 3.Public subsidies end due to budget crisis 4.Investments in just about everything are costly 5.Underfunded pension obligations 6.Demand: Mixed Future a.EE, smart grid, younger generation reducing demand b.More electronics, computer servers, U.S. manufacturing increasing demand 28BOSTON PACIFIC COMPANY, INC.
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  • V. ELECTRIC VEHICLES (UPDATE) 29BOSTON PACIFIC COMPANY, INC.
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  • V. ELECTRIC VEHICLES (UPDATE) A.Demand Shock Unlikely 1.Obama administration backing away from goal of one million electric vehicles by 2015 16 2.Only 80,000 sold since 2010 17 3.Range anxiety remains (New York Times controversy) 18 4.Electric vehicles must compete with hybrids and increasingly efficient traditional gas-powered vehicles 30BOSTON PACIFIC COMPANY, INC. 16. Ayesha Rascoe and Deepa Seetharaman, U.S. Backs Off Goal Of One Million Electric Cars by 2015, Reuters, January 31, 2013, http://www.reuters.com/.http://www.reuters.com/ 17. Electric Drive Transportation Association, Electric drive vehicle sales figures (U.S. Market)-EV Sales, EDTA website, accessed April 19, 2013, http://www.electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952. http://www.electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952 18. John M. Broder, Stalled on Teslas Electric Highway, The New York Times, February 8, 2013, http://www.nytimes.com/.http://www.nytimes.com/
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  • V. ELECTRIC VEHICLES (UPDATE) B. Supply Shock Unlikely Now, But China May Change That 1.Much more motivation: environmental, economic, geopolitical 2.U.S. acquisitions show its interest 3.Still, little progress: China produced just 6,000 electric vehicles in 2011 19 31BOSTON PACIFIC COMPANY, INC. 19. McKinsey & Company, Recharging Chinas Electric Vehicle Aspirations, China Auto Hub, April 2012.
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  • VI. DISTRIBUTED GENERATION 32BOSTON PACIFIC COMPANY, INC.
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  • VI. DISTRIBUTED GENERATION A.Distributed Generation in General 1.Considered part of demand response 2.For SPP, NERC expects 59% increase in demand response by 2022 2,408MW, 4% of demand 3.For SPP today, 98% of demand response is distributed generation 33BOSTON PACIFIC COMPANY, INC.
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  • VI. DISTRIBUTED GENERATION B.Not All Distributed Generation is Created Equal 1.Reliability vs. environmental performance C.For The Board 1.Granular depiction of distributed generation 2.Does it meet the need, mitigate strategic risks? 34BOSTON PACIFIC COMPANY, INC.
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  • VII. THREE OTHER ISSUES OF NOTE: DODD-FRANK, MODULAR NUKES (UPDATE), A LESS-CENTRALIZED GRID 35BOSTON PACIFIC COMPANY, INC.
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  • VII. THREE OTHER ISSUES OF NOTE: DODD-FRANK, MODULAR NUKES (UPDATE), A LESS-CENTRALIZED GRID A.Dodd-Frank 1.RTO products drawn into derivatives: day-ahead and real-time energy, FTRs, ancillary services B.Nuclear 1.Small Modular Reactor (SMR) funded for TVA, built by Babcock & Wilcox and Bechtel 20 2.Look elsewhere for growth of large-scale nuclear (China, South Korea, Russia) 21 3.And same for its decline (Germany, Japan) 22,23 36BOSTON PACIFIC COMPANY, INC. 20.Small Modular Nuclear Reactors, Energy.gov, accessed April 24, 2013, http://energy.gov/ne/nuclear-reactor-technologies/small-modular-nuclear-reactors. http://energy.gov/ne/nuclear-reactor-technologies/small-modular-nuclear-reactors 21. World Nuclear Association, Plans for New Reactors Worldwide, World Nuclear Association website, last modified March 2013, http://www.world-nuclear.org/info/Current-and-Future- Generation/Plans-For-New-Reactors-Worldwide/. http://www.electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952.http://www.world-nuclear.org/info/Current-and-Future- Generation/Plans-For-New-Reactors-Worldwide/ http://www.electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952 22. World Nuclear Association, Nuclear Power in Germany, World Nuclear Association website, last modified April 2013, http://www.world-nuclear.org/info/Country-Profiles/Countries-G- N/Germany/#.UT3ThNbkvlc.http://www.world-nuclear.org/info/Country-Profiles/Countries-G- N/Germany/#.UT3ThNbkvlc 23. World Nuclear Association, Nuclear Power in Japan, World Nuclear Association website, last modified April 2013, http://www.world-nuclear.org/info/Country-Profiles/Countries-G- N/Japan/#.UXf7PcpXrwo.http://www.world-nuclear.org/info/Country-Profiles/Countries-G- N/Japan/#.UXf7PcpXrwo
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  • VII. THREE OTHER ISSUES OF NOTE: DODD-FRANK, MODULAR NUKES (UPDATE), A LESS-CENTRALIZED GRID C.Drivers Toward a Less-Centralized Grid 1.Cybersecurity 2.Severe weather 3.Rising retail rates 37BOSTON PACIFIC COMPANY, INC.