Mais conteúdo relacionado Semelhante a ScottMadden Energy Industry Update February 2011 Semelhante a ScottMadden Energy Industry Update February 2011 (20) ScottMadden Energy Industry Update February 20111. The ScottMadden Energy Industry Update
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Highlights of Recent Significant Events and Emerging Trends
February 2011
Vol. 12, Issue 1
Copyright © 2011 by ScottMadden, Inc. All rights reserved.
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 Subsidies
1 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
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 On...in 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 allocation
3 Copyright © 2011 by ScottMadden, Inc. All rights reserved.
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. 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. Trends in Dividends, Earnings, and Valuations
Among 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. 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 synergies
Major Corporate Merger & Acquisition Announcements—Energy Companies M&A Announced
Transactions (Corporate)
Share Deal
Companies Deal Value Price Announced Sector Size Value/ 2001 11
Premium Book Value
2002 26
Exelon Corp./ 2003 23
Renewable 1.5 GW in various
John Deere $0.9B NA Aug. 2010 NA
generation development stages 2004 37
Renewables
2005 34
Northeast Utilities/ $4.2B Electric 3.5 million
~1.9% Oct. 2010 NM 2006 37
NSTAR (plus $3.4B in debt) utilities customers combined
Chevron Corp./ $3.2B Upstream 9 TCF (incl.
2007 69
37% Nov. 2010 2.2x
Atlas Energy (plus $1.1B in debt) gas shale gas reserves) 2008 36
AGL Resources/ $2.4B Gas 4.5 million 2009 33
13% Dec. 2010 2.22X
Nicor, Inc.
Nicor Inc (plus $0.7B in debt)
(plus $0 7B in debt) utilities customers combined
customers combined 2010 47
Duke Energy/ $13.6B Electric 7 million
3.9% Jan. 2011 1.36x 0 50 100
Progress Energy (plus $12.1B in debt) utilities customers combined
7 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Sources: SNL Financial; The Wall Street Journal; Bloomberg.com; company websites; ScottMadden analysis
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/Issues
Demand response Intermediators between customers and EnerNOC Energy market expansion,
utilities/regional ISOs to pool demand response cPower restructuring; ISO roles
aggregation
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 costs
Distributed 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 metering
resources
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 technology
and management/ interfaces that provide signals, information on real- GridPoint Comverge Clear interoperability standards
time consumption Smart Synch Tendril Privacy concerns
meter 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, return
Smart appliances/ Facility appliances and devices with modernized Whirlpool Johnson Clear interoperability standards
electricity usage systems that monitor, protect, and Honeywell Controls Technology maturity/lifecycles
hardware
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” frugality
premise area Microsoft Transparent price signals;
signals, and emergency power situations
networking) supportive rate structures
Sources: Company websites; investment analyst reports; industry news; Cleantech Group, 2010 U.S. Smart Grid
8 Copyright © 2011 by ScottMadden, Inc. All rights reserved. Vendor Ecosystem (Sept. 2010); DOE Berkeley National Laboratory; ScottMadden analysis
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) and
9 Copyright © 2011 by ScottMadden, Inc. All rights reserved. 2010 Electric Utility Residential Customer Satisfaction Survey (July 14, 2010); ScottMadden analysis
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. Two Views of the Impact of EPA Regulations
on 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)