Existing vs. New Resources

The prime objective of any RPS is to promote the development of new renewable resources, not simply to benefit existing generation. Only 2-3% of Pennsylvania’s electricity currently comes from "renewables" (if defined very broadly). However, new resources would not necessarily fill the remainder of a 10% RPS requirement, because existing out-of-state renewables can be imported to meet the RPS obligation.

If SB 1030 were passed as currently worded, it’s theoretically possible that the bill’s requirements could be met without a single new wind or solar facility being built. The demand created by a 10% RPS requirement in 15 years is considerable, yet the existing generation from wind, wood waste, waste coal, landfill gas and hydroelectric power in our PJM grid is enough to fill 75% of that requirement… and this is if you assume that only 10% of the hydroelectric power would qualify as “low-impact” – a term which is undefined in all proposed legislation. If the PUC defines “low-impact” hydro more loosely, then the entire RPS goal could be met using existing resources within PJM.

Even if the limits on waste coal intended in SB 1030 are put into effect, there's still the possibility that 40-60% of the market created by the RPS could be met by existing generation. This underscores the need for real limits on the role of existing renewables.

Proportion of RPS goals that can be met by existing generation capacity in the PJM grid
(based on language in HB 2250 or SB 1030, as written)

Proportion of RPS goals that can be met by existing generation capacity in the PJM grid

(if the "energy from waste" loopholes in HB 2250 and SB 1030 are closed and waste coal is confined to a 30% cap through a 2 tier approach, as per the Rendell / McGinty administration's draft)

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Proportion of RPS goals that can be met by existing generation capacity in the PJM grid

(if the "energy from waste" loopholes in HB 2250 and SB 1030 are closed, waste coal is confined to a 30% cap through a 2 tier approach, as per the Rendell / McGinty administration's draft, and the SB 1030 definition is used, allowing only waste coal power plants which became operational after December 31, 1999 -- therefore counting only the 521 MW Seward plant as existing waste coal capacity))

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Notes

PJM, the electric grid serving Pennsylvania, New Jersey and Maryland, has long included Delaware, Washington, D.C., and a small slice of Virginia. Through the PJM West and PJM South expansions in recent years, the PJM Grid now includes all of West Virginia, nearly all of Virginia, much of Ohio and parts of Indiana, Illinois, Kentucky, North Carolina and small slices of Tennessee and Michigan. For the purpose of evaluating existing renewables in PJM, the above analysis includes data from the states which are entirely, or almost entirely covered by PJM (PA, NJ, MD, DE, OH, VA and WV), thus making this a conservative estimate of the amount of existing generating capacity that could meet the RPS definitions.

Of course, some of this capacity wouldn't be available to meet the RPS, since it is already being used to meet New Jersey's RPS. New Jersey's RPS protects against double-counting with other state RPS laws. Without strong statutory protections against other forms of double-counting, there is no guarantee that attributes won't be double-counted in other ways, despite PJM's Generation Attribute Tracking System (GATS), which only provides limited protection against some forms of double-counting. For more information on consumer protections against double-counting, see the comparison page.

The data above assumes that there will continue to be a 1.9% annual increase in electricity demand in Pennsylvania, despite the deindustrialization of the state and one of the nation's slowest population growth rates. This is assuming that the high rate of sprawl development keeps the annual increase high and that no gains are made in conservation and efficiency. These assumptions are also conservative, since a lower increase in electric demand would make it easier for the existing generation to meet a larger portion of the RPS goal, which is set as a percentage of the total electric demand in the state.