ScottMadden Energy Industry Update February 2011


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In this the February 2011 issue: The ScottMadden Energy Industry Update looks at at how utilities plan to grow in the “New Normal” economy. In the wake of a slowly improving economy, a change of political control of the U.S. House of Representatives, and tightening environmental requirements, the energy industry is looking at ways to expand business opportunities while keeping a rein on escalating costs. In this issue, we reflect upon the aspirations of energy and utility companies for growth in a “New Normal” economic environment.

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ScottMadden Energy Industry Update February 2011

  1. 1. The ScottMadden Energy Industry Update gy y p Highlights of Recent Significant Events and Emerging Trends February 2011 Vol. 12, Issue 1Copyright © 2011 by ScottMadden, Inc. All rights reserved.
  2. 2. Table of Contents Executive Summary/View from the Executive Suite E ti S /Vi f th E ti S it 2 Executive Summary Economic Outlook: Turning the Corner Energy Industry Stock Prices—Electrics, Diversifieds Continue to Languish Trends in Dividends, Earnings, and Valuations Among Selected Energy Sectors Mergers and Acquisitions—Speeding Up? Behind-the-Meter Products and Services: New Opportunity or Dot-Com Redux? Residential Utility Customer Satisfaction: A Mixed Bag Energy Supply, Demand, and Markets gy pp y, , 10 Natural Gas: A New Normal or About to Make the Turn? Two Views of the Impact of EPA Regulations on Power System Reliability in the U.S. Infrastructure 13 Smart Grid 2.0: Integrating Smart Grid Into Utility System-Wide Business Planning NERC Reliability Standards and Compliance Violations: A Roundup Rates and Regulatory Issues 16 Electricity Cost Trends, Fuel Mix, and Regulatory and Market Models Energy Costs and “Share of Wallet”: A Pushback Coming? Climate Change, Environment, and Sustainability 19 Renewable Portfolio Standards: Comparing Resources with Goals Energy and Environmental Policy: A Grand Bargain or Guerilla War on the Piece Parts? Solar Development Remains on a Roll, But It Still Requires Subsidies1 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
  3. 3. Executive Summary/View from the Executive Suite2 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
  4. 4. Executive Summary Enhancing Value  The economy is brightening, as the world continues to dig out of the “Great Recession.” Energy consumption has begun to recover, but only modestly  Electric utility valuations have lagged the broader indexes; for some companies, this presents potential opportunities f reasonably priced acquisitions t ti l t iti for bl i d i iti  In this slow-growth environment, utility companies are looking for growth opportunities. Some options include both corporate mergers and acquisitions or asset acquisitions. Also, utilities are pondering behind-the-meter products and services opportunities as growth vehicles, enhanced by smart grid capabilities (if and when those capabilities come to fruition) Diverging Trends in  Natural gas continues to be cheap and plentiful, with continued modest demand combined with Costs plentiful resources, including shale gas  These plentiful supplies, and the slow economic rebound, helped keep end-user gas and p power costs tame in 2010. However, the broader trend is that energy is taking a larger , gy g g proportion of the consumer “wallet”  In the renewables sector, solar photovoltaic module costs continue to fall, little by little. However, the overall installed cost of solar remains high. Solar development, which had a strong 2010, continues to require significant subsidies to achieve grid parity The Beat Goes  Regulatory activity continues in both the environmental and energy arenas Regulation  The U.S. EPA continues to push tightening emissions requirements for power generators, with unknown impacts on reliability and price of energy. The Administration’s rapprochement with business and concern about economic growth might lead EPA to delay implementation. However, However various interest groups may use the courts to keep the regulatory “train” going  FERC is engaged as well, focusing on more aggressive enforcement of reliability standards and also trying to resolve years-old issues regarding transmission cost allocation3 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
  5. 5. Economic Outlook: Turning the Corner Economic Growth Is Picking Up E i G th I Pi ki g U U.S. Economic G US E i Growth A l t I t 2011 th Accelerates Into  Economic growth is expected to continue into 2011, aided U.S. Real GDP Growth – Actual and Selected Forecasts (%) by compromise over extension of tax credits and extended 4% unemployment insurance benefits Year  While some forecasts are quite bullish (4% to 5%), the 2% Growth Rate median among economists is 3% for 2011 Year-Over-Y R 0% CFOs Are Optimistic but Cautious 2007 2008 2009 2010 2011 2012  CFOs expect increased growth in both revenues and profits, -2% Actual OECD but have a slightly negative view of business conditions Conference Board Wells Fargo -4% BofAML WSJ Median  Biggest concerns: healthcare costs, revenue growth, cash costs growth flow, consumer confidence, and corporate taxes Interest Rates May Increase Sooner Than Expected  There are fewer downside risks in the near term, as most believe a “double dip” has been avoided Ten-Year Treasury Yield (2000–Early 2011) (%) 2011 Forecast  A key near-term risk to the world economy: a significant Blackstone ~5% 8 economic deceleration in China BofAML o 4% % 6 Northern Trust 3.7% Yield (%) Capital Spending Expected to Increase 4 Wells Fargo 2.98%  Continued growth in capital investment is expected as credit loosened, especially for large firms, as well as tax 2 incentives. This may bring forward some capex from 2012 - into 2011 2000 2002 2004 2006 2008 2010  M&A activity is expected to continue as well Interest Rates Are a Worry, Inflation Less So Commodity Prices Are on the Rise  Increasingly, analysts are expecting interest rates to Iron and Steel Scrap and Copper Prices (Jan. 2009–Aug. 2010) increase, increase especially as 60% of U.S. federal debt matures in US $4 $400 the next three years and must be rolled over $3 $300 $/Pound  Rising rates are expected longer term: By 2020, OECD $/Ton expects a large gap between savings and investment $2 $200 needs, especially as investment in developing countries $1 Copper (COMEX) ($/lb.) $100 accelerates Steel Scrap (Am. Metal Mkt.) ($/ton) $0 $0  Core inflation has faded as a concern, but some key raw materials and food prices are rising, as developing countries post strong economic growth Sources: OECD; IMF; Kiplinger’s; Wall Street Journal; Wells Fargo; The Blackstone Group; Bloomberg;4 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Northern Trust; Bank of America Merrill Lynch; The Conference Board; U.S. Geological Survey
  6. 6. Energy Industry Stock Prices—Electrics, Diversifieds Continue to Languish Diversified and Electric Utilities Tracking The Dow Since 2005 Small Diversified, Gas Companies Ahead of the Dow Since Crash Diversified 5-Year Sector Performance 3-Year Sector Performance Normalized Daily Index Values (Dec. 2005–Dec. 2010) Normalized Daily Index Values (Dec. 2007–Dec. 2010) 200% 200% DJ Industrial Avg. SNL Energy Large Diversified SNL Energy Small Diversified S&P Gas Utilities 175% Peaked at 206%  Peaked at 206% 175% SNL Merchant Generator S&P Electric Utilities In May 2007 DJ Utility Index Citigroup MLP 150% 150% 125% 125% 100% 100% 75% DJ Industrial Avg. 75% SNL Energy Large Diversified SNL Energy Small Diversified 50% 50% S&P Gas Utilities SNL Merchant Generator 25% 25% S&P Electric Utilities DJ Utility Index 0% 0% Dec-05 Jun-06 Dec-06 Jun-07 Dec-07 Jun-08 Dec-08 Jun-09 Dec-09 Jun-10 Dec-07 Apr-08 Aug-08 Dec-08 Apr-09 Aug-09 Dec-09 Apr-10 Aug-10 Dec-10 Gas Upstream and LDCs Continue to Outpace DJIA, Electrics Trail Ending Index Value (Start of Period = 100%) Since  Since  Since  18-Month Sector Performance Mid‐2009 End‐2007 End‐2005 Normalized Daily Index Values (Jun. 2009–Dec. 2010) SNL Energy Large Diversified gy g 116% 75% 95% 200% SNL Energy Small Diversified 132% 103% 115% 175% S&P Gas Utilities 142% 95% 134% 150% S&P Electric Utilities 105% 68% 95% SNL Merchant Generator 88% 40% 70% 125% Citigroup MLP 161% 117% * 100% DJ Industrial Avg. 134% 86% 105% DJ Industrial Avg. DJ Utility Index 114% 74% 96% 75% SNL Energy Large Diversified 50% SNL Energy Small Diversified S&P Gas Utilities Despite low natural gas prices, gas LDC and gas MLP S&P Electric Utilities SNL Merchant Generator SNL M h G stocks have done well. Moreover, electric and 25% Citigroup MLP DJ Utility Index diversified utility stock prices continue to lag the 0% Dow, despite improving economic numbers. Jun-09 Aug-09 Oct-09 Dec-09 Feb-10 Apr-10 Jun-10 Aug-10 Oct-10 Note: All index values are 100% at beginning of relevant period. * means not available.5 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Sources: SNL Financial; ScottMadden analysis
  7. 7. Trends in Dividends, Earnings, and ValuationsAmong Selected Energy Sectors Price-to-Book Valuations E ilib ti g Post-Recession P i t B k V l ti Equilibrating P t R i Small Diversifieds B ki g Earnings Growth Decline S ll Di ifi d Bucking E i g G th D li Year-End* Price-to-Book Value Year-over-Year Net Income Growth Rate (Capitalization-Weighted) (%) (Capitalization-Weighted) (%) 600% 250% Large Diversified Large Diversified 500% Small Diversified S ll Di ifi d 200% Small Diversified Electric Electric 400% Merchant Merchant 150% Gas Utility Gas Utility 300% 100% 200% 50% 100% 0% 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 0% -50% 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 3Q 2010 -100% Dividend Growth Down but Still Positive  Utility valuations, as measured by multiples of book value, are down from the mid-2000s Year-over-Year* Dividend Growth — A key question is whether these valuations are a return to (Capitalization-Weighted) (%) normal or some inflection point that signals a bottom or 20% buying b i opportunity t it Large Diversified 15% Small Diversified  Dividend growth declined in response to the “Great Recession” Electric — Another driver is the desire to retain funds for the next wave 10% Gas Utility of capital investment 5%  As one might expect, net income g g p , growth has trended downward 0% — While slightly negative for most sectors in 2009, it was not as negative as many had feared -5% — Early returns for 2010 show improved sales, especially -10% among industrial classes -15% % — Small diversified utilities, however, seem to have been able 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 3Q to sustain positive earnings growth d i the d i ii i h during h downturn 2010 Notes: *3Q 2010 is for quarter end. Sectors are derived by SNL Financial: SNL Large Diversified (electric & gas utilities > $4 billion capitalization); SNL Small Diversified (< $4 billion); SNL Electric (electric only); SNL Merchant; and gas utility components of the SNL Energy index.6 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Sources: SNL Financial; KeyBanc Capital Markets; ScottMadden analysis
  8. 8. Mergers and Acquisitions—Speeding Up?  The first half of 2010 saw continued merger activity with large transactions like Asset Deals C i g B k Slowly: F A t D l Coming Back Sl l Fewer but Larger b tL g PPL/E.ON, FirstEnergy/Allegheny, and Exxon/XTO. The second half continued this trend, with both asset and corporate acquisition activity continuing Power Generation Asset Deals (Announced and Pending 2008–2010)  Some large transactions were announced at valuations that, for the most part, represented very modest premiums. This could reduce the need for huge 147 143 ons) synergies and perhaps lessen the risk of regulatory “claw back” $25 160 on Value ($ Billio  Deal drivers were often related to scale: 117 140 $20 $21.8 — Increase balance sheet size to support infrastructure investment (NU/NSTAR, 120 No. of Deals for example, expect $6 billion in combined spending over the next several $15 100 years) 80 — Acquire assets or reserves in pursuit of growth (renewables, $10 60 shale gas) or while valuations are depressed (merchant generation) $9.5 $9 5 Transactio s — Expand base across which to spread fixed and corporate costs $8.5 40 $5 20  The weak economy requires savings without layoffs and could pressure public service commissions $0 0 — Despite synergy potential, many acquirers are relying on attrition, not politically 2008 2009 2010 unpalatable layoffs — With ratepayers strapped for cash, regulators may require compelling savings cash Total Transaction Value No. of Transactions passed along in rates, even absent large synergiesMajor Corporate Merger & Acquisition Announcements—Energy Companies M&A Announced Transactions (Corporate) Share DealCompanies Deal Value Price Announced Sector Size Value/ 2001 11 Premium Book Value 2002 26Exelon Corp./ 2003 23 Renewable 1.5 GW in various John Deere  $0.9B NA Aug. 2010 NA generation development stages 2004 37Renewables 2005 34Northeast Utilities/ $4.2B Electric 3.5 million  ~1.9% Oct. 2010 NM 2006 37NSTAR (plus $3.4B in debt) utilities customers combinedChevron Corp./ $3.2B  Upstream 9 TCF (incl.  2007 69 37% Nov. 2010 2.2xAtlas Energy (plus $1.1B in debt) gas shale gas reserves) 2008 36AGL Resources/ $2.4B Gas  4.5 million 2009 33 13% Dec. 2010 2.22XNicor, Inc.Nicor Inc (plus $0.7B in debt) (plus $0 7B in debt) utilities customers combined customers combined 2010 47Duke Energy/ $13.6B Electric  7 million 3.9% Jan. 2011 1.36x 0 50 100Progress Energy (plus $12.1B in debt) utilities customers combined7 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Sources: SNL Financial; The Wall Street Journal;; company websites; ScottMadden analysis
  9. 9. Behind-the-Meter Products and Services:New Opportunity or Dot-Com Redux? Relative Technology Maturity of Behind the Meter Products Behind-the-Meter Companies, Companies in our sector and outside it are trying to determine whether the smart it, grid will create a new era of business opportunity for behind-the-meter (BTM) ESCO products and services. Some questions they have: services  When will smart grid be capable of creating BTM opportunities? Growth in Adoption Demand Distributed response resources  What is different now from prior retail “waves” in energy? aggregation Energy (traditional) Distributed monitoring/  How much integration is needed across value chain stages? d meter data Smart resources management  How will the revenue and profits of this BTM “renaissance” be divided among (emerging) appliances segments and players? What operating and business models will emerge?  How will customers respond? Which segments can, or will, participate? Maturity  What are the scale and scope requirements to profitably offer BTM products? Segment Description Example Players Some Drivers/IssuesDemand response Intermediators between customers and  EnerNOC  Energy market expansion, utilities/regional ISOs to pool demand response  cPower restructuring; ISO rolesaggregation capabilities and provide peak load management  Comverge  Transparent price signals; supportive rate structures and curtailment services, capacity bidding, and  Public policy p y other services to reduce firm energy costsDistributed Distributed generation and storage for primary and  Capstone  GE Energy  Installed cost (improving) stand-by power, heating and cooling applications, Turbine  FuelCell  Resistance to net meteringresources and grid ancillary services/renewables support  Caterpillar Energy buybacks and FIT structures(incl. renewables)  Siemens  SunEdison  Grid-parity costs (esp. renewables)Energy monitoring gy g Software, hardware, analytics, and customer y  OPower  eMeter  Improved technologyand management/ interfaces that provide signals, information on real-  GridPoint  Comverge  Clear interoperability standards time consumption  Smart Synch  Tendril  Privacy concernsmeter data  Google  Itron  “Performance contractor” stigma;management  EnerNOC customer investment required (also applies to ESCOs below)ESCO services Energy audits and consulting; energy equipment gy g gy q p  Utility affiliates  National  Subsidies and financing and installation, including energy efficiency  Global ESCOs ESCO  Agency issues retrofits, controls, HVAC, and building automation equipment  Local HVAC,  Pricing of efficiency providers electric cos.  Payback time, returnSmart appliances/ Facility appliances and devices with modernized  Whirlpool  Johnson  Clear interoperability standards electricity usage systems that monitor, protect, and  Honeywell Controls  Technology maturity/lifecycleshardware automatically adjust operations to the needs of its y j p  Carrier/  General  Customer and equipment service(incl.(incl facility/ Ice E I Energy Electric owner, including in response to price, utility  “New normal” frugalitypremise area  Microsoft  Transparent price signals; signals, and emergency power situationsnetworking) supportive rate structures Sources: Company websites; investment analyst reports; industry news; Cleantech Group, 2010 U.S. Smart Grid8 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Vendor Ecosystem (Sept. 2010); DOE Berkeley National Laboratory; ScottMadden analysis
  10. 10. Residential Utility Customer Satisfaction:A Mixed Bag West d South Lead Residential El t i Utilit S ti f ti W t and S th L d R id ti l Electric Utility Satisfaction Customer Communication Helps Electrics Residential Electric Utility Average  According to J.D. Power, satisfaction levels have increased J.D. Power Rating* by Region and Utility Size (2010) year-over-year as customer bills have decreased and reliability has improved 750  J.D. Power also found that managing customer king Median Score High Low expectations around outages and restoration mitigates Customer Sat. Index Rank 700 declines in or even improves satisfaction 650  To improve satisfaction, a mix of proactive and event 600 communiqués is required. For example: ─ More scheduled outage notifications with the rising 550 number and frequency of grid upgrade projects r 500 ─ Announcements of reliability and operational response investments and their results (benefits) West: West: South: South: Midwest: Midwest: East: East: Midsize Large Midsize Large Midsize Large Midsize Large ─ More frequent status updates, even with limited information, during storm outages (e.g., radio or mobile devices—texting, Facebook, Twitter, etc.)  Helping customers with their overdue bills, as one might expect, substantially improves customer satisfaction; utility Gas Utility Satisfaction Has a Narrower Range Than for Electrics education and energy efficiency/management programs are additional, helpful high bill resolution options Residential Gas Utility Average J.D. Power Rating* by Region and Utility Size (2010)  Customer awareness of their local utility’s implementation of smart grid and smart meter technology remains low 750 ndex Ranking Median Score High Low 700 Satisfaction Improves for Gas Utilities 650  Lower bills, more frequent communication, and improved perceptions of corporate citizenship have led to higher satisfaction levels Customer Sat. In 600 550  Gas customers are also more familiar with energy savings programs and want more communication on how to reduce 500 bills and conserve energy West: West: South: South: Midwest: East: Midwest: East:  J.D. Power opines that emphasizing the value of service g Large Midsize Large Midsize Midsize Midsize Large g g Large g provided by gas utilities lifts overall satisfaction Notes: *Scores are out of a possible 1,000 points Source: J.D. Power and Associates, 2010 Gas Utility Residential Customer Satisfaction Survey (Sept. 22, 2010) and9 Copyright © 2011 by ScottMadden, Inc. All rights reserved. 2010 Electric Utility Residential Customer Satisfaction Survey (July 14, 2010); ScottMadden analysis
  11. 11. Energy Supply, Demand, and Markets10 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
  12. 12. Natural Gas:A New Normal or About to Make the Turn? “Drill, B b D ill” P d i C i “D ill Baby, Drill”: Production Continues to Grow G Gas Prices P j t d t R G Pi Projected to Remain i th Mid-$4s to Mid $5 Through 2013 i in the Mid $4 t Mid-$5s Th gh  Onshore gas production continues to grow despite Actual Wellhead Gas Prices vs. Henry Hub Price Projections low gas prices and regulatory setbacks in by Selected Analysts (in $/MMBTU) Marcellus $10  Rig count is expected by some to level off and Natural Gas Week Scoreboard (Median) ultimately decline to a tipping point of abo t 800 ltimatel about $8 NGW Scoreboard (High Forecast) $/MMBTU rigs (U.S.) to stabilize gas prices $5.35 $5.35 $6 $4.72  However, horizontal gas drilling operations are more efficient and productive, yielding more gas $4 $4.36 $4.45 $4.45 per rig, so supply should be plentiful through 2012 Wellhead actual prices $2 (average) EIA Forecast: 2011:  $4.02 2011: $4.02 For Producers, First the Bad News, Then…? $0 2012:  $4.50 2005 2006 2007 2008 2009 Jan.-Oct. 2010 2011 2012  Enhanced revenues from rising natural gas liquids 2010 prices have lowered the breakeven dry gas (Avg.) production cost in some plays  Some producers looking to migrate from dry gas- gas only plays like Haynesville and Barnett to places Horizontal Rigs in January 2011 at 967, Up from Under 400 in Spring 2009 like Eagle Ford and Marcellus  Some analysts project that gas prices will firm after North American Rig Count by Type vs. 2012, buoyed by: U.S. Gas Rigs as % of Total Rigs — Coal power plant retirements 1,200 100% as % of Total Rig — Carbon constraints 1,000 North American 80% U.S. Gas Rigs — Step-down in drilling activity as wells mature Rig Count 800 60% — Hedges (i.e., forward sales) roll off 600 — Possible export (LNG) demand 40% 400 20% s 200 N gs Demand and New Large Players 0 0%  Demand remains suppressed, but is expected to 2006 2007 2008 2009 2010 2011 begin to firm with continued economic growth  Oil and gas majors are entering the market, % Gas Rigs Directional Horizontal Vertical acquiring shale players who need a larger balance % of Total Rigs % of Total Rigs Rig Count sheet and gaining experience to apply in shale fields inside and outside North America Sources: Energy Intelligence Natural Gas Week; Energy Information Administration; SNL Financial; Baker Hughes;11 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Deutsche Bank; American Gas Association; industry publications; ScottMadden analysis
  13. 13. Two Views of the Impact of EPA Regulationson Power System Reliability in the U.S. Much attention has been paid to the potential retirement of power generation in the U.S. as a result of various pending US EPA regulations covering air, water, and ash. Two recent studies looked at possible consequences for reliability. A Comparison of Two Analyses of EPA Regulation NERC (Oct. 2010) ( ) Charles River Associates (Dec. 2010) ( )  A significant portion of coal-fired generation is currently slated for retirement, even without tighter environmental regulations Key Points  Certain reliability sub-regions will be affected much more than others of Alignment  The impact of greenhouse gas regulation is not included  Assessments did not project expected power cost, only retrofit vs. retire economics  Looks at all EPA regulations – MACT, coal combustion  Looks only at MACT and CATR Key Differences in residuals, cooling water (thermal) constraints,  Limited its analysis to the Eastern Interconnection Assumptions and Approach and Clean Air Transport Rule (CATR)  Analysis was national in scope  Regulations impact 33 GW to 70 GW (retire or retrofit)  Under an aggressive MACT policy, CRA projects 35 GW of coal  MACT alone could trigger retirement of 2 GW to 15 GW capacity in the Eastern Interconnection to be retired by 2015  Cooling water intake has the greatest impact on reserve — Retirements are small compared with historical net margins, as it impacts nuclear and could force derates capacity additions  By 2015, combined EPA regulations could cause 32+ GWs in — Average age of those units is 55 years retirements and derates (over 77 GWs under a strict case with  With retirements, 2015 reserve margins fall below required no compliance extensions) margins in some sub-regions, but are adequate on a regional Conclusions  Under a moderate case and assuming only deliverable (i.e., level existing plus planned) capacity: — Permitted projects development can reduce the shortfall — ERCOT, ReliabilityFirst, and SERC-Delta, are most — New gas-fired capacity, above that currently permitted, affected by retirements (in total GWs) can “easily address” the shortfall (about 11.5 GWs) — ERCOT, the Midwest, New England, and many of the  Other methods can be used to manage shortfall, including: Southeastern subregions fall below target reserve margins — Load management — Coal-to-gas conversion Leadership in the Republican-controlled 112th Congress has Key issues and uncertainties: announced strategies (or intent) to slow or moderate EPA  How long cheap gas will last regulation via:  Impact of better than expected electric demand  Appropriations: Limiting EPA funding on selected initiatives  Availability and cost of gas pipeline extensions,  Oversight: Conducting hearings on EPA activities before expansions to support new or repowered generation Energy & Environment, other Congressional committees Environment  R Required cost and ti i of t i d t d timing f transmission enhancements i i h t  Legislation: Mandating delay on some EPA actions (esp.  Realistic timing of new capacity resources “in the wings” greenhouse gas regulation)  Cost of power with shift in resource mix Sources: NERC, 2010 Special Reliability Scenario Assessment: Resource Adequacy Impacts of Potential U.S. Environmental Regulations (Oct. 2010);12 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Charles River Associates, A Reliability Assessment of EPA’s Proposed Transport Rule and Forthcoming Utility MACT (Dec. 16, 2010)
  14. 14. Infrastructure13 Copyright © 2011 by ScottMadden, Inc. All rights reserved.