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target percentage by 2020–2030. Some targets are fairly minor but others, like Californoia’s 33% renewables by 2020, represent substantial deployment of renewable energy generation. Stakeholders operating within state or utility RPS requirements with predominantly natural gas capacity may find themselves subject to compliance costs if renewable targets cannot be met, particularly if jurisdictions increase or advance their RPS targets down the road, a not unlikely possibility. Overinvestment in natural gas and underinvestment in renewables now could potentially impact future compliance. Complementarity: Renewable energy projects eligible to meet RPS requirements are not subject to future cost uncertainty, as with little or no fuel costs and typically long-term power purchase agreements. Renewable generation may acquire additional revenue streams through the sale of renewable energy certificates (RECs) or similar monetization of environmental benefits. The modularity of some renewable energy technologies (kilowatts to hundreds of megawatts) also provides valuable flexibility to deployment timelines of new capacity and can incrementally hedge risks from future policy uncertainty.73 Natural gas investments, on the other hand, tend to be in larger increments (e.g., 500 MW and more) of new capacity. 3.2.1.4 Federal Environmental Regulations Issue: Within the past three years, a number of EPA emission regulations affecting power plants, including carbon dioxide emission-limiting New Source Performance Standards (NSPS), the p Cross-State Air Pollution Rule (CSAPR), and the Mercury and Air Toxics Standqards (MATS), have been proposed or finalized. While litigation and judicial review have delayed implementation and prompted reconsideration of several rules in recent months, the broad industry expectation of these environmental regulations have accelerated the scheduled retirement of aging coal plants74 and reinforced the belief that no new coal plants will be built in the future unless their emissions can be reduced by carbon capture and sequestration, an as yet unproven and costly technology. Today’s highly efficient natural gas plant technology easily meets the environmental standards proposed by these regulations and thus have been the predominant generation replacement choice. This has provided substantial short-term opportunities to reduce the country’s carbon dioxide and other criteria pollutant emissions without additional cost or policies.75 However, the emissions reduction benefit of natural gas will eventually plateau as long-term emission thresholds become increasingly stringent. Tightening emission regulations and the possibility of future low-carbon policies during the 30+-year lifespan of natural gas plants are an area of considerable uncertainty and, subsequently, additional latter-period profitability risk. Complementarity: In the near-term, the environmental benefit of both natural gas and renewable energy compared to the current generation mix provides a common platform from which to o For more details on state RPS programs, see the Database of State Incentives for Renewables & Efficiency (www.dsireusa.org). p The NSPS rules would only apply to new power plants, whereas CSAPR and MATS would apply to both new and existing power plants. q CSAPR was rejected by the U.S. Court of Appeals for the District of Columbia in August 2012. The prior Clean Air Interstate Rule (CAIR) will remain in place while EPA reviews the court’s decision. 20PDF Image | Opportunities Synergy Natural Gas and Renewable Energy
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