PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements June 5, 2019 PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements This page is intentionally left blank. PJM © 2019 www.pjm.com i P a g e PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Contents Summary of Findings ..................................................................................................................................................... 3 Background Information ................................................................................................................................................. 4 Ohio ............................................................................................................................................................................... 4 Pennsylvania.................................................................................................................................................................. 4 Study Assumptions ........................................................................................................................................................ 4 Nuclear Retirements ................................................................................................................................................. 5 Transmission Upgrades ............................................................................................................................................ 5 Planned Generation .................................................................................................................................................. 5 Simulation Results ......................................................................................................................................................... 6 Base Case ..................................................................................................................................................................... 6 First Set of Simulations .................................................................................................................................................. 8 Beaver Valley 1 & 2 Retirement Withdrawn .............................................................................................................. 8 Davis-Besse and Perry Retirements Withdrawn ....................................................................................................... 8 Beaver Valley 1 & 2, Davis-Besse and Perry Retirements Withdrawn ..................................................................... 9 Second Set of Simulations ........................................................................................................................................... 10 Beaver Valley 1 & 2 Retirement Withdrawn and 50 Percent of New Gas Does Not Enter Market .........................10 Davis-Besse and Perry Retirements Withdrawn and 50 Percent of New Gas Does Not Enter Market ..................10 Beaver Valley 1&2, Davis-Besse and Perry Retirements Withdrawn and 50 Percent of New Gas Does Not Enter Market..................................................................................................................................................................... 11 PJM © 2019 www.pjm.com ii P a g e PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Summary of Findings • In response to separate requests from the Pennsylvania Public Utility Commission (PA PUC) and the Ohio Consumers’ Counsel (OCC), PJM Interconnection studied cost and emission impacts of potential nuclear power plant retirements in Pennsylvania and Ohio. • To evaluate these impacts, PJM simulated market results for the year 2023 under various resource mixes, including what exists today, projected conditions for the future and several combinations of potential nuclear unit retirements. • The PJM base case includes the announced retirements of nuclear units in Pennsylvania and Ohio: Three Mile Island (TMI), Beaver Valley 1 & 2, Davis-Besse and Perry, and also includes new generation with a planned in-service date of 2023 and an executed Interconnection Service Agreement. • Modeling the base case, considering retirements and new entry, shows that wholesale energy market net-load payments would decrease by $1.6 billion across the PJM region compared to today’s system due to the significant entry of new, efficient resources. • PJM executed three simulations of the requested nuclear unit retirement scenarios. These scenarios assume the requested combinations of nuclear unit retirements occur and also assume that those generators in the queue that have executed an Interconnection Service Agreement and are planned to come online between 2020 and 2023 would enter the market as scheduled. The results of these simulations for the PJM region, (without including the cost of a possible subsidy) are: o o o • PJM executed three additional simulations accounting for the same nuclear unit retirement scenarios and included an additional sensitivity assumption regarding the impact of subsidies on new entry. To represent what PJM believes to be the market’s likely, long-term reaction to out-of-market subsidies that retain substantial quantities of generation that would have otherwise retired, we discounted by 50 percent the planned natural-gas generation otherwise scheduled to come online between 2020 and 2023. We assumed these projects would be canceled or deferred and in any event, were assumed to not enter the market. The results of these simulations for the PJM region, (again without including the cost of a possible subsidy) are: o o o • Beaver Valley 1 & 2 remain online: $210 million decrease in load payments from the base case Davis-Besse and Perry remain online: $277 million decrease in load payments from the base case Beaver Valley 1 & 2, Davis-Besse, and Perry remain online: $474 million decrease in load payments from the base case Beaver Valley 1 & 2 remain online and new entry of natural gas is discounted by 50 percent: $240 million increase in load payments from the base case Davis-Besse and Perry remain online and new entry of natural gas is discounted by 50 percent: $164 million increase in load payments from the base case Beaver Valley 1 & 2, Davis-Besse and Perry remain online and new entry of natural gas is discounted by 50 percent: $91 million decrease in load payments from the base case Detailed tables in the report show the changes in emissions for each simulation case. 3 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Background Information Ohio On April 22, 2019, the OCC sent a letter to PJM requesting that PJM analyze the following: 1. If the Ohio nuclear power plants Perry and Davis-Besse were permanently shut down, what would be the expected impact on PJM’s wholesale capacity and energy market prices? 2. If the Perry and Davis-Besse nuclear power plants were permanently shut down, what would be the expected impact on retail electric prices for Ohio consumers? Given the limited time to produce the requested analysis, PJM focused on the Energy Market and emissions impacts of the requested study scenarios. PJM also focused on wholesale market impacts of the retirement scenarios rather than retail, given the many assumptions that would be required in order to estimate the impacts on retail electric prices. However, it is reasonable to assume that retail price impacts would follow in the same direction as wholesale market impacts. Pennsylvania On April 29, 2019, the PA PUC sent a letter to PJM requesting that PJM analyze the impacts of nuclear generation retirements in Pennsylvania. The letter asked PJM to quantify the impacts of retired nuclear generation on wholesale power prices as well as on emissions – carbon monoxide, lead, ground-level ozone, particulate matter, nitrogen oxide, sulfur dioxide and carbon dioxide. The PA PUC asked PJM to model the following scenarios using calendar year 2023 as the base year and assuming in the base case that: 1. TMI and Beaver Valley 1 & 2 remain online 2. TMI, Beaver Valley 1 & 2 and the Ohio plants Perry and Davis-Besse remain online The PA PUC initially requested that PJM provide its analysis by May 17, 2019, if possible. To provide the analysis relatively close to that timeframe, an exhaustive analysis of each market could not be performed. Rather, PJM focused on the Energy Market and emissions impacts associated with the scenarios studied. On May 8, 2019, Exelon Generation announced that TMI Generating Station Unit 1 would shut down by September 30, 2019. For this study, PJM therefore assumed that TMI would be retired in all scenarios (See Table 1). PJM’s analysis is confined to wholesale power prices and does not consider the added cost to consumers that would result from the imposition of any subsidy or non by-passable charge at the retail level. Study Assumptions PJM uses PROMOD software to simulate energy market impacts in future years. The PROMOD production cost simulation tool models an hourly security-constrained generation commitment and dispatch. 4 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements For this study, PJM used the input parameters and forecast assumptions from the best-available market-efficiency base case agreed upon by the PJM Transmission Expansion Advisory Committee (TEAC). Details regarding the PJM market efficiency input assumptions can be found in the white paper posted with the materials for the May 2019 TEAC, Market Efficiency Process Scope and Input Assumptions (2019 Mid-Cycle Update). Nuclear Retirements PJM considered the following retirement scenarios to evaluate the impacts of the combinations of nuclear unit retirements, as described in the Summary of Findings section: 1. Announced retirements of Beaver Valley 1 & 2 are withdrawn only 2. Announced retirements of Davis-Besse and Perry are withdrawn only 3. Announced retirements of Beaver Valley 1 & 2, Davis-Besse and Perry are withdrawn PJM executed two sets of these scenarios. The first set of scenarios assumed that all planned new generation capacity (having executed an Interconnection Service Agreement) announced to come online between 2020 and 2023 enters the market as scheduled. In the second set of scenarios, to account for the market’s potential reaction to out-of-market subsidies implemented in order to retain nuclear generation that would otherwise retire, PJM assumed that roughly 50 percent of natural gas capacity planned to come online between 2020 and 2023 did not enter the market. Table 1. Nuclear Units Included in the Study Name Area State Max. Cap. (MW) Davis-Besse:1 Perry (OH):1 Beaver Valley:2 Beaver Valley:1 FirstEnergy ATSI FirstEnergy ATSI Duquesne Light Company Duquesne Light Company OH OH PA PA 896 1,247 903 910 Transmission Upgrades For each scenario, PJM modeled any new electric transmission system investments necessary to preserve a reliable electric transmission system, given the announced nuclear retirements in Pennsylvania and Ohio. Any such reinforcements were included in all of the scenarios, including those in which the nuclear units were assumed to have retired, as well as those in which the nuclear units were assumed to remain in operation. Planned Generation Planned generation in the scenarios was composed of all proposed generating units in the PJM queue with a planned in-service date by 2023 and an executed Interconnection Service Agreement. Pennsylvania nuclear power station TMI was retired in all scenarios. As indicated above, two sets of scenarios were executed for each nuclear unit retirement combination. The second set of scenarios, in which only half of the planned natural gas units is retained, is informative and based on a credible assumption because it can reasonably be expected that imposing additional out-of-market subsidies to 5 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements retain generation that would otherwise retire would have a chilling effect on new investment in the longer term. While PJM believes this is a reasonable expectation, we acknowledge that accurately forecasting how new investment will react to out-of-market intervention is difficult, at best. Therefore, in this report, PJM presents the second set of scenarios as a sensitivity showing the impact of a decrease in new entry by half of what is expected, so that readers of this report may interpolate the effects of various levels of new entry on the overall cost to consumers as well as emissions (see Table 2 and Table 3). Table 2. Assumed Retirements 2023 Market Efficiency Base Case Retirements Retired Coal Retired Gas Retired Nuclear Nuclear not Retired Table 3. 2023 Base Case All Announced PJM Nuclear Retirements Occur (MW) 11,882 1,768 5,387 - Beaver Valley 1 & 2 Not Retired (MW) 11,882 1,768 3,575 1,812 Davis-Besse + Perry Not Retired (MW) 11,882 1,768 3,244 2,143 Beaver Valley 1 & 2 + Davis-Besse + Perry Not Retired (MW) 11,882 1,768 1,432 3,955 Assumed New Generation Additions* 2023 Market Efficiency Base Case Additions New Coal New Gas (in-service 2018 and 2019) New Gas (in-service 2020 and beyond) Total New Gas New Wind New Solar 2023 Base Case All ISA Units Included (MW) Generation Conditions as of End of 2019 (MW) No Market Reaction (All New Gas Goes In-Service as Scheduled) (MW) Some Market Reaction (50% Planned Gas Does Not Enter the Market)** (MW) - - - - 11,415 11,415 11,415 11,415 10,514 - 10,514 4,618 21,929 3,235 3,933 11,415 3,235 3,933 21,929 3,235 3,933 16,033 3,235 3,933 *PJM assumed status quo for energy efficiency and renewables forecasts. **Assumption: 50 percent of new entrants do not materialize if nuclear units are kept in service (i.e., 5,896 MW – 50 percent of megawatts – capacity of 10,514 MW ISA units with in-service date of 2020 and beyond). Simulation Results Base Case The PJM base case includes the stated retirements of nuclear units in Pennsylvania and Ohio – TMI, Beaver Valley 1 & 2, Davis-Besse, and Perry and also includes new generation with a planned in-service date of 2023 and an executed Interconnection Service Agreement. This base case shows that under these conditions, when compared to today’s system, wholesale energy market net-load payments would decrease by $1.6 billion across the PJM region due to the significant quantity of new, more efficient generation that is expected to enter the market. Emissions of carbon dioxide would decrease by 6 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements 4,300,000 tons, nitrogen oxides would decrease by 37,900 tons, and sulfur dioxide would decrease by 18,200 tons compared to the base case (see Table 4). The nuclear retirement scenario results are all compared to this base case. If a given nuclear retirement scenario indicates that net-load payments increase compared to the base case, that result could also be articulated as netload payments would not be expected to decrease as much from today. Table 4. Simulation Results Base Case Category Nuclear Unit Status Item Base Case TMI (PA) Retired End of 2019 Case Retired Beaver Valley 1 & 2 (PA) Retired In-Service Perry (OH) Retired In-Service Davis-Besse (OH) Retired In-Service Nuclear Capacity Retired (MW) 3,955 1,432 10,514 - Ohio CO2 (millions) 80.17 74.75 (5.4) Ohio SO2 (thousands) 87.09 87.85 0.8 48.13 48.18 0.1 102.24 98.63 (3.6) Planned New Gas Capacity (MW) Ohio NOx (thousands) Pennsylvania CO2 (millions) Delta in Effluent Tons Delta in Load Payments ($ millions) Pennsylvania SO2 (thousands) 62.71 71.54 8.8 Pennsylvania NOx (thousands) 86.20 108.94 22.7 PJM CO2 (millions) 383.06 387.36 4.3 PJM SO2 (thousands) 284.64 302.89 18.2 PJM NOx (thousands) 247.01 284.95 37.9 AEP $4,409 $4,653 $244 APS $1,718 $1,834 $116 FE-ATSI $2,316 $2,435 $119 DAY $591 $627 $36 DEOK $901 $959 $58 DUQ $471 $503 $31 $526 $565 $40 $1,396 $1,494 $98 METED PECO PENELEC Delta in Load-Weighted LMP ($/MWh) Change $579 $615 $36 PLGRP $1,364 $1,474 $110 Ohio $5,485 $5,790 $305 Pennsylvania $5,271 $5,647 $375 PJM $26,797 $28,394 $1,597 AEP 32.39 34.20 $1.81 APS 32.84 35.00 $2.17 FE-ATSI 33.48 35.20 $1.72 DAY 33.10 35.09 $1.99 DEOK 32.07 34.13 $2.07 DUQ 32.37 34.52 $2.14 METED 32.43 34.86 $2.43 PECO 32.85 35.15 $2.31 PENELEC 32.09 34.15 $2.06 7 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Category Item PLGRP 32.17 End of 2019 Case 34.76 0.00 0.00 $0.00 0.00 0.00 $0.00 32.88 34.83 $1.96 Base Case Ohio Pennsylvania PJM Change $2.60 First Set of Simulations The first set of simulations was executed with the assumption that all new gas generators enter the market as scheduled (see Table 5). Beaver Valley 1 & 2 Retirement Withdrawn If the stated retirement of Beaver Valley 1 & 2 is withdrawn and the units remain online: Energy Market Impacts: Results show an annual decrease in net-load payments of $210 million from the base case for the entire PJM region. Of that decrease, $45 million would occur in Pennsylvania and $62 million would occur in Ohio. Said another way, load payments would decrease by an additional $210 million for the PJM region, $45 million for Pennsylvania and $62 million for Ohio from the base case if the Beaver Valley 1 & 2 units are retained and if all anticipated new generation entry into the market occurs as is expected today. This reduction in customer payments, however, is not netted against the cost of a potential subsidy to consumers in a particular state. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 2,100,000 tons, nitrogen oxides would decrease by 2,100 tons, and emissions of sulfur dioxide would decrease by 1,300 tons compared to the base case (or more than they otherwise would if Beaver Valley 1 & 2 retire). In Ohio, emissions of carbon dioxide would decrease by 1,500,000 tons, nitrogen oxides would decrease by 500 tons, and sulfur dioxide would decrease by 700 tons (see Table 5). Davis-Besse and Perry Retirements Withdrawn If the stated retirements of Davis-Besse and Perry are withdrawn and the units remain online: Energy Market Impacts: Annual load payments would decrease by $277 million over the base case for the entire PJM region. Of that decrease, $50 million would occur in Pennsylvania and $95 million would occur in Ohio. Said another way, load payments would decrease by an additional $277 million from the base case for the PJM region, $50 million in Pennsylvania and $95 million in Ohio if the Davis-Besse and Perry units are retained and if all the anticipated new generation entry into the market occurs as is expected today. This reduction in customer payments, however, is not netted against the cost of a potential subsidy to consumers in a particular state. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 2,300,000 tons, nitrogen oxides would decrease by 2,000 tons and emissions of sulfur dioxide would decrease by 2,000 tons. In Ohio, emissions of carbon dioxide would decrease by 2,300,000 tons, nitrogen oxides would decrease by 1,700 tons and sulfur dioxide would decrease by 2,600 tons (see Table 5). 8 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Beaver Valley 1 & 2, Davis-Besse and Perry Retirements Withdrawn If the stated retirements of Beaver Valley 1 & 2, Davis-Besse and Perry are all withdrawn and the units remain online: Energy Market Impacts: Annual load payments would decrease by $474 million over the base case for the entire PJM region. Of that annual decrease, $95 million would occur in Pennsylvania and $155 million would occur in Ohio. Said another way, load payments would decrease by an additional $474 million for the PJM region, $95 million in Pennsylvania and $155 million in Ohio from the base case if Beaver Valley 1 & 2, Davis-Besse, and Perry are all retained and if all the anticipated new generation entry into the market occurs as is expected today. This reduction in customer payments, however, is not netted against the cost of a potential subsidy to consumers in a particular state. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 4,700,000 tons, nitrogen oxides would decrease by 5,000 tons and emissions of sulfur dioxide would decrease by 3,300 tons. In Ohio, emissions of carbon dioxide would decrease by 3,700,000 tons, nitrogen oxides would decrease by 2,400 tons and sulfur dioxide would decrease by 3,500 tons (see Table 5). Table 5. Simulation Results Base Case (No Market Reaction Regarding New Entrants) Category Item Nuclear Units Status TMI (PA) Beaver Valley 1 & 2 (PA) Perry (OH) Davis-Besse (OH) Nuclear Capacity Not Retired (MW) Planned Gas Capacity Removed (MW) Delta in Effluent Tons Delta in Load Payments ($ millions) Delta in Load-Weighted LMP ($/MWh) Ohio CO2 (millions) Ohio SO2 (thousands) Ohio NOx (thousands) Pennsylvania CO2 (millions) Pennsylvania SO2 (thousands) Pennsylvania NOx (thousands) PJM CO2 (millions) PJM SO2 (thousands) PJM NOx (thousands) AEP APS FE-ATSI DAY DEOK DUQ METED PECO PENELEC PLGRP Ohio Pennsylvania PJM AEP APS Retired Retired Retired In-Service Retired Retired In-Service In-Service In-Service Retired In-Service In-Service 1,812 (1.5) (0.7) (0.5) (2.1) (1.3) (2.1) (6.6) (2.9) (3.7) $(37.85) $(20.91) $(39.11) $(4.20) $(5.69) $(11.77) $(2) $(7) $(6) $(6) $(62) $(45) $(210) $(0.28) $(0.41) 2,143 (2.3) (2.6) (1.7) (2.3) (2.0) (2.0) (8.1) (5.3) (4.8) $(52.48) $(21.71) $(61.93) $(6.58) $(8.75) $(8.33) $(3) $(8) $(9) $(7) $(95) $(50) $(277) $(0.39) $(0.42) 3,955 (3.7) (3.5) (2.4) (4.7) (3.3) (5.0) (15.1) (8.5) (9.7) $(88.49) $(42.19) $(99.63) $(10.55) $(14.16) $(19.53) $(5) $(15) $(15) $(14) $(155) $(95) $(474) $(0.66) $(0.79) 9 Page PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Category Item FE-ATSI DAY DEOK DUQ METED PECO PENELEC PLGRP Ohio Pennsylvania PJM $(0.57) $(0.24) $(0.21) $(0.82) $(0.16) $(0.16) $(0.33) $(0.15) $(0.37) $(0.28) $(0.26) $(0.90) $(0.37) $(0.33) $(0.59) $(0.18) $(0.18) $(0.51) $(0.16) $(0.57) $(0.31) $(0.34) $(1.45) $(0.60) $(0.54) $(1.37) $(0.32) $(0.35) $(0.84) $(0.32) $(0.93) $(0.58) $(0.58) Second Set of Simulations The second set of simulations was executed assuming that 50 percent of new gas does not enter the market (see Table 6). Beaver Valley 1 & 2 Retirement Withdrawn and 50 Percent of New Gas Does Not Enter Market If the stated retirement of Beaver Valley 1 & 2 is withdrawn and the units remain online: Energy Market Impacts: Results show an annual increase in load payments of $240 million over the base case for the entire PJM region. Of that increase, $43 million would occur in Pennsylvania, and $52 million would occur in Ohio. Said another way, load payments would increase by $240 million from the base case if the Beaver Valley 1 & 2 units are retained, given the anticipated reduction in new entry that would otherwise occur. The load payment increases would result from by higher-cost marginal units setting the zonal locational marginal prices in the absence of expected new entrants we assumed will not enter due to the existence of the subsidies. This increase in customer payments does not include the cost of a potential subsidy to consumers in a particular state — the subsidy would be an additional cost on top of the increase in wholesale energy prices. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 2,800,000 tons, nitrogen oxides would increase by 3,000 tons, and emissions of sulfur dioxide would increase by 1,400 tons. Increases in nitrogen oxides and sulfur dioxide reflect coal generation, which is uneconomic in the base case, being dispatched when less new entry from natural gas occurs. In Ohio, emissions of carbon dioxide would decrease by 2,200,000 tons, nitrogen oxides would decrease by 300 tons, and sulfur dioxide would decrease by 400 tons (see Table 6). Davis-Besse and Perry Retirements Withdrawn and 50 Percent of New Gas Does Not Enter Market If the stated retirements of Davis-Besse and Perry are withdrawn and the units remain online: Energy Market Impacts: Results show an annual increase in load payments of $164 million over the base case for the entire PJM marketplace. Of that increase, $39 million would occur in Pennsylvania, and $16 million would occur in Ohio. The analysis shows that load payments would increase by $164 million from the base case if the DavisBesse and Perry units were retained, given the anticipated reduction in new entry that would otherwise occur. The 10 P a g e PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements load payment increases would result from higher-cost marginal units setting the zonal LMPs in the absence of expected new entrants that we assume will not enter due to the existence of the subsidies. This increase in customer payments does not include the cost of a potential subsidy to consumers in a particular state – the subsidy would be an additional cost on top of the increase in wholesale energy prices. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 3,000,000 tons, nitrogen oxides would increase by 2,700 tons, and emissions of sulfur dioxide would increase by 1,400 tons. In Ohio, emissions of carbon dioxide would decrease by 2,800,000 tons, nitrogen oxides would decrease by 800 tons and sulfur dioxide would decrease by 1,000 tons (see Table 6). Beaver Valley 1&2, Davis-Besse and Perry Retirements Withdrawn and 50 Percent of New Gas Does Not Enter Market If the stated retirements of Beaver Valley 1 & 2, Davis-Besse and Perry are all withdrawn and the units remain online: Energy Market Impacts: Results show an annual decrease in load payments of $91 million from the base case for the entire PJM marketplace. Of that annual decrease, $15 million would occur in Pennsylvania, and $56 million would occur in Ohio. Said another way, load payments would decrease by an additional $90 million for the PJM region, $15 million in Pennsylvania and $56 million in Ohio from the base case if the Beaver Valley 1 & 2, Davis-Besse and Perry units were retained, even if a reduction in new entry were to occur. This is because the retention of all the nuclear plants and their associated energy production is sufficient to offset the impact of the reduced new entry. This reduction in customer payments, however, is not netted against the cost of a potential subsidy to consumers in a particular state. Emissions Impact: In Pennsylvania, emissions of carbon dioxide would decrease by 5,500,000 tons, nitrogen oxides would show very little change and emissions of sulfur dioxide would decrease by 300 tons. In Ohio, emissions of carbon dioxide would decrease by 4,000,000 tons, nitrogen oxides would decrease by 1,400 tons and sulfur dioxide would decrease by 1,800 tons (see Table 6). Table 6. Simulation Results Base Case (50 Percent of New Entrants Don’t Enter Market) Category Nuclear Units Status Item TMI (PA) Retired Retired Retired In-Service Retired In-Service Perry (OH) Retired In-Service In-Service Davis-Besse (OH) Retired In-Service In-Service Nuclear Capacity Not Retired (MW) 1,812 2,143 3,955 Planned Gas Capacity Removed (MW) Delta in Effluent Tons 5,896 5,896 5,896 Ohio CO2 (millions) (2.2) (2.8) (4.0) Ohio SO2 (thousands) (0.4) (1.0) (1.8) Ohio NOx (thousands) (0.3) (0.8) (1.4) Pennsylvania CO2 (millions) (2.8) (3.0) (5.5) 1.4 1.4 (0.3) Beaver Valley 1 & 2 (PA) Pennsylvania SO2 (thousands) 11 P a g e PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Category Item Pennsylvania NOx (thousands) PJM CO2 (millions) Delta in Load Payments ($ millions) 0.0 (4.1) (5.2) (12.5) 1.7 0.9 (3.0) PJM NOx (thousands) 3.8 2.9 (1.9) AEP $45.29 $27.98 $(17.17) APS $15.67 $14.84 $(7.94) FE-ATSI $13.67 $(10.85) $(54.05) $8.20 $5.49 $0.15 DEOK $13.14 $9.88 $2.22 DUQ $0.08 $3.67 $(9.02) METED $5 $5 $1 PECO $13 $12 $3 $5 $2 $(5) PLGRP $12 $11 $2 Ohio $52 $16 $(56) Pennsylvania $43 $39 $(15) PJM $240 $164 $(91) AEP $0.34 $0.21 $(0.13) APS $0.27 $0.28 $(0.18) FE-ATSI $0.20 $(0.16) $(0.78) DAY $0.46 $0.31 $0.00 DEOK $0.47 $0.34 $0.06 DUQ $0.00 $0.25 $(0.63) METED $0.30 $0.28 $0.07 PECO $0.31 $0.30 $0.07 PENELEC $0.27 $0.09 $(0.28) PLGRP $0.27 $0.27 $0.06 Ohio $0.31 $0.10 $(0.33) Pennsylvania $0.27 $0.24 $(0.09) PJM $0.29 $0.20 $(0.11) PENELEC Table 7. 2.7 PJM SO2 (thousands) DAY Delta in Load-Weighted LMP ($/MWh) 3.0 Summary of all Simulation Results Category Nuclear Units Status Nuclear Capacity not Retired (MW) Planned Gas Capacity Removed (MW) Item TMI (PA) Scenarios Retired Retired Retired Retired Retired Retired Retired Beaver Valley 1&2 (PA) In-Service In-Service Retired In-Service In-Service Retired In-Service Perry (OH) In-Service Retired In-Service In-Service Retired In-Service In-Service Davis-Besse (OH) In-Service Retired In-Service In-Service Retired In-Service In-Service 3,955 1,812 2,143 3,955 1,812 2,143 3,955 10,514 - - - 5,896 5,896 5,896 12 P a g e PJM Interconnection Response to the Pennsylvania Public Utility Commission & Ohio Consumers’ Counsel Requests to Analyze Certain Impacts of Nuclear Power Plant Retirements Category Delta in Effluent Tons Delta in Load Payments ($millions) Delta in LoadWeighted LMP ($/MWh) Item Ohio CO2 (millions) Scenarios (5.4) (1.5) (2.3) (3.7) (2.2) (2.8) (4.0) Ohio SO2 (thousands) 0.8 (0.7) (2.6) (3.5) (0.4) (1.0) (1.8) Ohio NOx (thousands) 0.1 (0.5) (1.7) (2.4) (0.3) (0.8) (1.4) Pennsylvania CO2 (millions) Pennsylvania SO2 (thousands) Pennsylvania NOx (thousands) PJM CO2 (millions) (3.6) (2.1) (2.3) (4.7) (2.8) (3.0) (5.5) 8.8 (1.3) (2.0) (3.3) 1.4 1.4 (0.3) 22.7 (2.1) (2.0) (5.0) 3.0 2.7 0.0 4.3 (6.6) (8.1) (15.1) (4.1) (5.2) (12.5) PJM SO2 (thousands) 18.2 (2.9) (5.3) (8.5) 1.7 0.9 (3.0) PJM NOx (thousands) 37.9 (3.7) (4.8) (9.7) 3.8 2.9 (1.9) AEP $244.18 $(37.85) $(52.48) $(88.49) $45.29 $27.98 $(17.17) APS $115.51 $(20.91) $(21.71) $(42.19) $15.67 $14.84 $(7.94) FE-ATSI $118.82 $(39.11) $(61.93) $(99.63) $13.67 $(10.85) $(54.05) DAY $35.51 $(4.20) $(6.58) $(10.55) $8.20 $5.49 $0.15 DEOK $58.44 $(5.69) $(8.75) $(14.16) $13.14 $9.88 $2.22 DUQ $31.20 $(11.77) $(8.33) $(19.53) $0.08 $3.67 $(9.02) METED $40 $(2) $(3) $(5) $5 $5 $1 PECO $98 $(7) $(8) $(15) $13 $12 $3 PENELEC $36 $(6) $(9) $(15) $5 $2 $(5) PLGRP $110 $(6) $(7) $(14) $12 $11 $2 Ohio $305 $(62) $(95) $(155) $52 $16 $(56) Pennsylvania $375 $(45) $(50) $(95) $43 $39 $(15) PJM $1,597 $(210) $(277) $(474) $240 $164 $(91) AEP $1.81 $(0.28) $(0.39) $(0.66) $0.34 $0.21 $(0.13) APS $2.17 $(0.41) $(0.42) $(0.79) $0.27 $0.28 $(0.18) FE-ATSI $1.72 $(0.57) $(0.90) $(1.45) $0.20 $(0.16) $(0.78) DAY $1.99 $(0.24) $(0.37) $(0.60) $0.46 $0.31 $0.00 DEOK $2.07 $(0.21) $(0.33) $(0.54) $0.47 $0.34 $0.06 DUQ $2.14 $(0.82) $(0.59) $(1.37) $0.00 $0.25 $(0.63) METED $2.43 $(0.16) $(0.18) $(0.32) $0.30 $0.28 $0.07 PECO $2.31 $(0.16) $(0.18) $(0.35) $0.31 $0.30 $0.07 PENELEC $2.06 $(0.33) $(0.51) $(0.84) $0.27 $0.09 $(0.28) PLGRP $2.60 $(0.15) $(0.16) $(0.32) $0.27 $0.27 $0.06 Ohio $1.83 $(0.37) $(0.57) $(0.93) $0.31 $0.10 $(0.33) Pennsylvania $2.32 $(0.28) $(0.31) $(0.58) $0.27 $0.24 $(0.09) PJM $1.96 $(0.26) $(0.34) $(0.58) $0.29 $0.20 $(0.11) 13 P a g e