Rps Negative

RPS Neg

Georgia novice packet

Index Index............................................................................................................................................................................................................1 Solvency frontline........................................................................................................................................................................................2 Solvency frontline.......................................................................................................................................................................................3 Solvency – ext 1 – jurisdiction.....................................................................................................................................................................4 Solvency – ext 2 – enforcement...................................................................................................................................................................5 Solvency – ext 2 – DOE can’t enforce.........................................................................................................................................................6 Solvency – ext 3 – can’t be met...................................................................................................................................................................7 Solvency – ext 4 – vague.............................................................................................................................................................................8 Environment frontline..................................................................................................................................................................................9 Environment frontline................................................................................................................................................................................10 Environment – ext 1 – won’t decrease coal use.........................................................................................................................................11 Environment – ext 2 – won’t help environment........................................................................................................................................12 Environment – Ext 4 – air pollution answers.............................................................................................................................................13 Competitiveness frontline..........................................................................................................................................................................14 Competitiveness frontline..........................................................................................................................................................................15 Competitiveness – ext 2 – go overseas......................................................................................................................................................16 Competitiveness – ext 3 – renewable not key............................................................................................................................................17 Competitiveness – ext 4 – no innovation...................................................................................................................................................18 A2 – Competitiveness key to hegemony...................................................................................................................................................19

1

RPS Neg

Georgia novice packet

Solvency frontline 1. The plan will create jurisdictional conflicts with States – intensifying regulatory uncertainty Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP Finally, most advocates of a national RPS have said little about federal and state regulatory jurisdiction. State commissions determine both retail rates and [*110] requirements for new generation and transmission to meet anticipated load growth. They will continue to have those powers under a national RPS, but federal compliance requirements may impose new constraints on them. The situation may mirror the concerns that state regulators have expressed about the Energy Policy Act of 2005's grant of federal "backstop" authority over the siting of certain transmission lines that states have not approved. Lengthy regulatory proceedings and court tests on transmission will surely occur in the near future. The same will happen for generation under a national RPS, perhaps even more confrontational because generation is a larger percentage of delivered power costs. The FERC cannot compel investment in generation, but the penalty provisions of a national RPS would coerce utilities into constructing generation (or arranging RECs) that state regulators might not approve. Many questions remain. May a utility be excused if it made a good-faith effort to gain state regulatory approval for a national RPS compliance investment but was refused? What if a proposed facility is not reachable because state regulators have blocked transmission to it? What if state-level intervenors introduce interminable litigation and regulatory proceedings to stop a compliance project? A national RPS threatens a larger displacement of state regulatory authority than any policy change since open access, and state regulators now know how to fight wars of attrition.

2. RPS won’t be enforced – agencies will side with industry Ottinger & Jayne, 2000 – *Dean Emeritus of Pace University School of Law, founder of the Pace Energy Project, former Member of Congress and Chair of the House Energy, Conservation and Power Subcommittee, and **Pace Law School student and Research Assistant (Richard L Ottinger and Mindy Jayne, “Global Climate Change – Kyoto Protocol Implementation: Legal Frameworks for Implementing Clean Energy Solutions,” www.solutions-site.org/special_reports/sr_global_climate_change_4.htm) // JMP Effective enforcement is critical to the success of any standards program. Theoretically, the governments adopting the standards should enforce them, and any standards program, to be effective, should incorporate substantial resources for training, inspection and enforcement. In practice, however, governments and their regulatory agencies often come to identify with the industries or companies that they regulate. Also, political pressures often prevent effective government enforcement. Citizen enforcement, adopted in the U.S. in the Clean Air Act and other environmental statutes has been found to be a most effective enforcement mechanism. NGOs in the U.S. are able to hold regulators’ feet to the fire very effectively by filing suit to enforce standards, with the award of attorney’s fees for such litigation; the very presence of citizen suit provisions enables the NGOs to influence government enforcement policies.

2

RPS Neg

Georgia novice packet

Solvency frontline 3. Even a 10% RPS by 2020 is unrealistic NAM 7 - National association of Manufactureres ("PROTECT ELECTRICITY CONSUMERS FROM RATE INCREASES: OPPOSE THE BINGAMAN RENEWABLE PORTFOLIO STANDARD AMENDMENT", unknown date in 07, http://www.nam.org/s_nam/doc1.asp?CID=202504&DID=226878) The RPS Amendment is Unrealistic * A 10 percent RPS mandate by 2020 is unrealistic. In 2001, nonhydropower renewable energy accounted for only 2.1 percent of generation and is projected to increase to only 3.3 percent of generation by 2025, according to the federal government’s Energy Information Administration (EIA). The amendment would require a quadrupling of the projected renewable generation in a shorter time period, without any credit for existing capacity. * Under the Bingaman amendment, in 2020 utilities would have to generate electricity from renewable energy resources equal to roughly 350 billion kilowatt-hours. In comparison, total electric industry generation from non-hydroelectric renewable energy resources was about 70 billion kilowatt-hours in 2001. To comply with the 10 percent RPS mandate in 2020 would require a whopping five-fold increase in renewable energy generation! * In order to meet the 10 percent mandate by 2020, more than 32,000 megawatts of renewable capacity would have to be added, assuming that this capacity operates at 100 percent 24 hours a day, 365 days a year. However, this is an unrealistic assumption because most renewable energy resources are intermittent in nature. * The percentage targets in the Bingaman amendment are based on amounts of energy produced, not capacity. Therefore, in many cases utilities would have to “overbuild” their renewable capacity in order to meet the targets. The most promising renewable energy technology, wind energy, operates at only about 30-40 percent of capacity. Therefore, almost three times this amount of capacity would be required to generate the mandated levels of electricity from renewables!

4. A vague RPS will encourage legal battles and/or just reinforce the status quo Dr. Sovacool, & Coooper, 7 – *Senior Research Fellow for the Network for New Energy Choices in New York and Adjunct Assistant Professor at the Virginia Polytechnic Institute & State University in Blacksburg, VA and ** Executive Director of the Network for New Energy Choices (Benjamin K. Sovacool, also a Research Fellow at the Centre for Asia and Globalization at the Lee Kuan Yew School of Public Policy and Christopher Cooper, Electricity Journal, “Big Is Beautiful: The Case for Federal Leadership on a National Renewable Portfolio Standard,” May 2007, vol. 48, no. 4, Lexis-Nexis Academic) // JMP In his evaluation of lessons learned from state RPS policies, Ryan Wiser found that the design of the mandate was critical to its effectiveness. An RPS mandate can be poorly designed and ineffective or elegant and cost-effective.48 We have noted how vague definitions of regulated utilities have provoked prolonged legal battles in some states. In others, overly broad definitions of eligible resources have resulted in programs that "have largely supported or will support existing (not new) renewable generation."49

3

RPS Neg

Georgia novice packet

Solvency – ext 1 – jurisdiction A federal RPS will create jurisdictional conflicts with States Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP Advocates of a national RPS have also said little about the jurisdictional conflicts it will create between state and federal regulators. State regulators set cost-based retail rates and have authority over utilities' planning of generation and transmission additions, while the FERC has authority over wholesale transactions, even if the parties are in the same state. It is not easy to see how disagreements over investments made by utilities for compliance will be resolved. A requirement that state regulators include all of a utility's compliance investments (including RECs) in its rate base (on which it earns the allowed return) takes away an important part of their authority with no corresponding benefit. Allowing state regulators to disallow investments intended for compliance leaves the federal authorities with question of how to treat them. (Even if the legal answer is clear the political answer is not.) Federal regulators will be at least a shadow presence in state procurement proceedings, and probably an unappreciated one. n132 Most proposals for a federal RPS differ from existing state programs in having no price cap on renewables that will excuse a utility if renewable power is unavailable for less. n133 The political problems of reconciling state price caps with an uncapped federal program also remain unexplored. n134 A federal RPS will add another layer of reporting requirements for electricity suppliers – creating uncertainty and increasing energy costs Fershee, 8 – Assistant Professor of Law at the University of North Dakota School of Law (Joshua P., Energy Law Journal, “Changing Resources, Changing Market: The Impact of a National Renewable Portfolio Standard on the U.S. Energy Industry,” 29 Energy L. J. 49, Lexis-Nexis Academic) // JMP B. Compliance Requirements A national RPS would mean new federal reporting requirements for retail electricity suppliers. For those operating in RPS states, a federal RPS would mean a second, potentially duplicative, reporting requirement. Electricity industry representatives (such as the Edison Electric Institute) have argued that a federal RPS, which mandates "different targets, technologies, and timetables through a federal RPS on top of the state programs would create uncertainty and drive up the cost of meeting renewable mandates even further for electricity suppliers and consumers in those states." n116 A federal RPS will intensify jurisdictional conflicts Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP VI. State RPS Experiences A. Why Examine the States? Any RPS must be an ambitious exercise in institutional design. States with RPS have had to formulate definitions of eligible renewables, put institutions in place to monitor compliance and crediting, and set penalties for noncompliance. A federal

RPS will be further complicated by constraints that are imposed by the industry's dual regulatory system. The Federal Energy Regulatory Commission (FERC) has jurisdiction over "wholesale" exchanges of power and transmission, defined as those that are intended for ultimate resale to end-users. State commissions regulate "retail" rates charged to end-users and monitor the planning and prudence of utilities' generation and transmission investments. The

FERC has no powers to compel or prohibit generation investments, and states are unlikely to shed their existing authority without a fight. States also have primary jurisdiction over the siting of new plants and lines. Interactions between state and federal regulators under a national RPS will be complex, time-consuming, and costly to administer. Before committing to a federal RPS it may be useful to examine the actual organization and performance of state programs. Positive state results would be encouraging news for supporters of a federal regime. If the states have performed poorly or indifferently, advocates of a national RPS should explain why it will not produce similar results. State regulators require compliance reports from utilities and have varying amounts of discretion to impose penalties. n92 Some states have seen [*102] little enforcement activity because RPS is not yet a binding constraint, and others are still formulating rules. Some legal definitions of compliance and crediting may not be clear, as is being demonstrated in California (see below). There are also escape provisions for noncompliant utilities. All but one RPS state has some type of price cap on renewables, and a utility is deemed in compliance (or exempt) if it cannot find any at or below that price. n93 Resource availability can also be a matter of definition. Minnesota exempts utilities that are under "economic and competitive pressure," and Pennsylvania does so if resources are not "reasonably available." n94

4

RPS Neg

Georgia novice packet

Solvency – ext 2 – enforcement Individual State RPSs prove non-compliance is the norm Michaels, 8 – Adjunct Scholar at CATO and Research Fellow at the Independent Institute (Robert J., Electricity Journal, “A National Renewable Portfolio Standard: Politically Correct, Economically Suspect,” April 2008, vol. 21, no. 3, Lexis-Nexis Academic) // JMP An RPS at any level requires reporting, monitoring, and penalties for noncompliance. Nearly all RPS states have penalties, but regulators have differing powers to set and impose them.60 Cost caps on renewables further complicate the process. Since

national RPS proponents have said little about penalties and compliance, a look at the states may be worthwhile.61 Hard data on state programs is conspicuously absent from most proposals. Instead of numbers the reader gets such undocumented and misleading assertions as Sovacool and Cooper's claim that California, New York, and Nevada have "made impressive progress."62 Likewise, a report by Barry Rabe for the Pew Center on Global Climate Change says that "In a number of instances, RPSs have clearly played a central role in fostering rapid and significant expansion of the amount of renewable energy provided in a state."63 Rabe singles out five states for attention based on their representativeness and diversity: * Texas' 1999 retail choice legislation set a 2009 deadline for 2,000 new MW of renewables in the territories of the ERCOT member utilities.64 All utilities and competitive retailers must obtain a percentage of their supplies from renewables or credits. The goal was reached in 2007, almost entirely by wind turbines. Its new RPS sets a quota of 5,000MW by 2015 and 10,000 by 2025, at least 500MW of the latter non-wind. Both utilities and competitive retailers must own renewable capacity or credits. Rabe does not mention that Texas

is the sole state that has put enough new capacity on-line to stay ahead of a meaningful requirement. His report also omits any data on wind's actual contribution to ERCOT's resources and reliability. As noted above, 2,800MW of wind translates into 300 dependable MW, producible by a cheaper gas-fired plant with a smaller footprint that requires less transmission to reach its loads. * Massachusetts' 1997 restructuring law required that renewables be 1 percent of deliveries through 2002 and then rise by 0.5 percent annually to 4 percent in 2009.65 Utilities achieved compliance in 2003 using credits banked in 2002. They then fell 32.6 percent short in 2004 and 37.4 percent in 2005, paying the state $55.13 for each deficit MWh.66 The

wind resources originally expected to satisfy the RPS are not being built due to resistance from rural residents, environmentalists, and the state's two senators.67 Rabe remarks that there is "considerable uncertainty regarding Massachusetts' ability to achieve its ascending RPS targets," but he does not identify any alternative resources, evaluate other enforcement methods, or consider modifying or scrapping the RPS.68 * Nevada may be "the next Texas," according to Rabe.69 Its 2005 RPS requires annual progress to 20 percent by 2015, with 5 percent solar in that year. The state's empty, windy deserts and proven baseload geothermal capacity make it an ideal test case. Its 2006 output of wind power was zero. The state's two utilities taken together have signed contracts that leave them in compliance with their 9 percent 2007 RPS requirement, but their actual supplies were 3 percent (Nevada Power) and 6 percent (Sierra Pacific Power). Nevada

Power met its 2006 requirement by purchasing 1.02 million kWh of credits from Sierra Pacific, which was unable to deliver them because of weak interconnections. Both are also failing to meet their solar requirements, which may not be surprising because there are no penalties for noncompliance.70 Rabe concludes by asserting that new proposals (apparently not actual projects) have made state officials "increasingly sanguine" about future compliance.71 * Pennsylvania's "Alternative Energy Portfolio Standard" consists of two tiers. The first is non-hydro sources with a 0.5 percent solar set-aside. Tier 2 has dismayed environmentalists by including incinerated trash and waste coal. They are to produce 8 and 10 percent of the state's power by 2021. A utility's compliance requirements only begin after recovery of its state restructuring transition costs. The RPS became effective for three of them on Feb. 28, 2007, and the rest on or before Jan. 1, 2011.72 Data on compliance are currently unavailable. * In 2004 Colorado voters enacted a 10 percent 2015 requirement with a 4 percent solar set-aside. 2007 legislation raised it to 20 percent by 2020 with the same set-aside. Municipals and cooperatives are subject to it, but at lower levels than investor-owned systems. Compliance data are not currently available. Rabe apparently mentions Colorado only to illustrate the possibility of referenda as alternatives to legislation.73

Of these states chosen by an RPS advocate, only Texas is in genuine compliance with its own program. Massachusetts and Nevada were out of compliance almost as soon as their requirements became binding. None of Pennsylvania's utilities was subject to its RPS at the time of publication, and Colorado is still putting its rules in place. In his search for a template, Rabe might better have looked at California.

Officials don’t care about enforcement – just kicks the problem down the road Michaels, 8 – Adjunct Scholar at CATO and Research Fellow at the Independent Institute (Robert J., Electricity Journal, “A National Renewable Portfolio Standard: Politically Correct, Economically Suspect,” April 2008, vol. 21, no. 3, Lexis-Nexis Academic) // JMP State experiences with RPS suggest that it is less a breakthrough than another episode of regulation-as-usual. Its

political point is to show concern by instituting a seemingly stringent requirement and leaving compliance for someone else to enforce. Elected officials will have little subsequent interest, both because of its obscure complexity and because serious enforcement probably means higher bills. California's utilities and regulators appear to understand the interests of legislators. Despite the reality of almost no new operating renewables, the CPUC's January 2007 report to the legislature says utilities are "closing in on the 20 percent target with four years of procurement ahead."85 On page 2 it notes that the legal definition of compliance is operation, but all subsequent graphics and data refer to signed contracts. Despite the unencouraging data discussed above, the CPUC report's projections assume that no new contracts will fail and all expiring ones will be renewed or reformulated.

Political and economic interests will determine the provisions of a federal RPS, and utilities will make their choices about compliance. California's appear to be treating their RPS as a tactical tool to reestablish primacy that has been diminished by competition and divestitures required by restructuring. Its RPS has brought back IRP and utility-environmentalist collaboration, with the approval of legislators and regulators. Its restrictive current policies and uncertain future ones have drastically reduced in-state fossil generation investments, and its coming carbon regulation will further raise power costs. Renewables will be delayed if they are built at all, and demand management programs are also underperforming.86 The coming crunch presents an ideal opportunity for utilities to vertically reintegrate themselves. In 2006 Southern California Edison received an Order from the CPUC to install 250MW of turbines and 300MW of demand response in anticipation of a capacity shortfall in summer 2007.87 The purchase was exempted from complex and lengthy competitive procurement procedures as a one-time action to deal with an impending emergency, but there are good reasons to expect that episodes like this one will recur. How

utilities and others will game a federal RPS will depend on its details, but there is little reason to assume anyone will passively comply.

5

RPS Neg

Georgia novice packet

Solvency – ext 2 – DOE can’t enforce The DOE can’t effectively enforce an RPS Fershee, 8 – Assistant Professor of Law at the University of North Dakota School of Law (Joshua P., Energy Law Journal, “Changing Resources, Changing Market: The Impact of a National Renewable Portfolio Standard on the U.S. Energy Industry,” 29 Energy L. J. 49, Lexis-Nexis Academic) // JMP Enforcement of a national RPS would create an additional case load, but not one that should prove problematic. Unfortunately, the Proposed RPS called for EPA enforcement when a better alternative for compliance monitoring was readily available. The DOE has little, if any, experience in administering a program on the scale of a national RPS, and has shown no indication that enforcement of a major program is within the agency's capabilities. Further, the Proposed RPS includes a program providing RECs for certain energy efficiency measures, an area in which the DOE has already failed to show effective leadership. The DOE was charged with the task of promulgating energy efficiency standards for household appliances in 1987, n174 but failed to update the efficiency standards, leading to a lawsuit brought by fifteen states. n175 Even when [*72] DOE has acted to increase efficiency standards, the agency has not indicated a willingness to push for significant progress. n176 DOE can’t effectively enforce Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP n132. A national RPS impacts both environmental and energy policy, but the House-passed measure fails to mention either the EPA or the FERC. Instead it lodges compliance and enforcement authority with the Department of Energy. The DOE lacks both the EPA's accumulated experience in environmental monitoring and the FERC's familiarity with power markets and their regulation.

6

RPS Neg

Georgia novice packet

Solvency – ext 3 – can’t be met RPS standards have never been met Electric Utility Weekly, 8 (Paul Carlsen, “S&P renewables reality check finds them too little, costly and 'painful' for ratings,” 3-17-2008, pg.1, Lexis-Nexis Academic) // SM

No existing RPS has met original goals. Twenty-nine states and the District of Columbia now have some type of RPS, up from about a dozen four years ago (see map, page 11). A third were adopted in the past two years. "And, since 2006, nine of the 29 states that had some sort of RPS actually increased their renewable targets, notably before any of them met their original goals," Selting noted. But with "going green" (however defined) having rapidly become a corporate virtue, utilities that do not meet RPS objectives can be blamed, even if the goals were unreasonable. "These feasibility risks are particularly acute in states that adopt increasingly aggressive targets before demonstrating the viability of earlier goals," S&P pointed out. According to the Energy Information Agency's February 2008 Electric Power Monthly, excluding conventional hydroelectric ? which, Selting said, not all states consider "green" ? only about 2.5% of US generation in the first 11 months of 2007 was from renewable resources. Of that, 54% was from wood and related waste, 31% from wind, 14% from geothermal ? and 1% from solar.

On a rolling 12-month basis, wind generation 31,756 was GWh last year ? up 21.4% from 2006 and almost 1,000% from the 3,000 GWh in 1993. But it still represented only 0.8% of last year's US total, and virtually no change from 2006's 0.6%. EIA figures show wood/wood waste, at 55,336 GWh, was down 1.1% from 1993, and geothermal, at 14,851 GWh, was down 11.5%. Over those 15 years solar went from 462 GWh to 606 GWh, S&P noted. The 2007 rolling 12-month total was about 102,550 GWh for those four renewables categories. Emerging Energy Research estimates that to meet RPS requirements in the 24 states (and Washington, DC) with mandatory standards, another 160,000 GWh would have to be generated in 2015.> "That translates into a rough requirement that some 6,000 MW of new renewable capacity come online each year ... We question whether this is attainable," she continued, especially since Congress has yet to extend the 1.9 cent/kWh production tax credit for wind beyond the end of this year (EUW, 10 March, 7). In California, for example, independent energy producers recently accused utilities of deliberately delaying the addition of renewable resources, and have asked the California Public Utilities Commission to audit utility RPS power supply bids. These

feasibility risks are particularly acute in states that adopt increasingly aggressive targets before demonstrating the viability of earlier goals.

Renewables are growing rapidly, but they can’t make 20% by 2020—the Energy Department concedes it AP, 8 (“Why are electric rates rising?” 6-24-08, http://abclocal.go.com/kgo/story?section=news&id=6225366) –CMM Q: My power company is raising rates, and blaming soaring coal and natural gas prices. But given all the new wind farms and solar projects I read about, shouldn't electricity rates be falling? A: Wind and solar power is growing at a rapid pace in the U.S. Wind-generated electricity grew 45 percent between 2005 and 2006, and 21 percent between 2006 and 2007, the Energy Department says. Solar power generation grew by 19 percent between 2006 and 2007. The photovoltaic, or PV, solar panel industry has grown by an average of 25 percent a year over the last 10 years, according to the Solar Energy Industries Association. "However, this rapid growth is from a very small base," the SEIA notes on its Web site. "PV still accounts for a small percentage of electricity generation worldwide." Indeed, there lies the problem with wind and solar power: Even at breakneck growth rates, renewable energy sources will account for only 12.6 percent of U.S. electricity generation by 2030, up from 9.5 percent in 2006, the Energy Department says. Worldwide, renewable energy's share of electricity generation will actually fall to 16 percent in 2030 from 19 percent in 2004, the department says. Solar and wind power aren't even the leading sources of renewable energy. Hydroelectricity plants -- power-producing dams -- account for 75 percent of all renewable power generation, vastly overshadowing wind at 7 percent and solar, at 0.1 percent. All renewable power sources are growing, but so are fossil fuel power sources.

A national RPS will AT BEST marginally increase renewable as a percentage of the market Electric Utility Weekly, ‘7 (Dipka Bhambhani, and Paul Carlsen, “Bingaman, still aiming for national RPS, finds few supporters at NARUC meeting,” 7-23-08, pg. 13, Lexis-Nexis Academic) // SM


7

RPS Neg

Georgia novice packet

Solvency – ext 4 – vague The plan is too vague – the RPS passed by the House includes the percentage, the qualifying renewables, specifies a phasein and stipulates the provision of renewable credits Fershee, 8 – Assistant Professor of Law at the University of North Dakota School of Law (Joshua P., Energy Law Journal, “Changing Resources, Changing Market: The Impact of a National Renewable Portfolio Standard on the U.S. Energy Industry,” 29 Energy L. J. 49, Lexis-Nexis Academic) // JMP For purposes of this Article, the impact of a national RPS will be considered under the plan passed by the House in House Bill 3221 (the Proposed RPS). n25 Like the prior three RPS proposals that passed the Senate, n26 the Proposed RPS would have been enacted as an amendment to Title VI of the [*54] Public Utility Regulatory Policies Act of 1978 (PURPA). n27 As such, it is likely that a national RPS, if passed, would be included as part of PURPA.

The Proposed RPS required all "retail electric suppliers" to provide 15% of their energy sold from renewable sources by the year 2020. n28 That is, 15% of each covered retail electricity supplier's energy would have needed to be either generated from renewable energy resources or the retail electric supplier would need to otherwise purchase or exchange credits derived from renewable generation. n29 The plan provided one additional option for a portion of the requirement: utilities were permitted to achieve up to 4% of this requirement through efficiency programs. n30 The Proposed RPS provided that renewable energy meant electric energy that is generated by a "renewable energy resource," which "means solar (including solar water heating), wind, ocean, tidal, geothermal energy, biomass, landfill gas, or incremental hydropower." n31 The plan would have been phased in, starting with a requirement of 2.75% renewable energy beginning in 2010, increasing gradually (but significantly) through 2020 up to 15%. n32 RPS Requirements As Proposed in H.R. 3221 Calendar Years Required annual percentage 2010 2.75 2011 2.75 2012 3.75 2013 4.5 2014 5.5 2015 6.5 2016 7.5 2017 8.25 2018 10.25 2019 12.25 2020 and thereafter through 2039 15 Source: H.R. 3221, 110th Cong. § 9611(a).

The Proposed RPS would have exempted retail electricity sellers who sold less than one million megawatt-hours of electricity for purposes other than resale use in the preceding year, as well as all municipal and rural cooperative suppliers. n33 [*55] Under the Proposed RPS, the Secretary of Energy would have been charged with establishing a program to verify and issue Federal renewable energy credits (RECs). n34 The RECs were to be issued to generators of renewable energy, and the program planned to track the sale, exchange, and retirement of RECs. n35 The proposal also provided that, "to the extent possible, in establishing such program, the Secretary shall rely upon existing and emerging State or regional tracking systems that issue and track non-Federal renewable energy credits." n36 As a general rule, one REC would have been issued for each kilowatt hour of renewable electric energy generated under the statute. n37 In addition, the plan provided a premium (i.e., additional RECs) in certain situations. Two RECs were to be issued per kilowatt hour of renewable energy generated on Indian land, n38 and three RECs would have been issued for renewable energy generated at an on-site facility where that renewable energy was used to offset all or part of the customer's electricity requirements. n39

Finally, the Proposed RPS expressly preserved the validity of state programs, including those that exceeded the national RPS. n40 In recommending reliance upon state and regional systems that track "non-Federal renewable energy credits" in the development of a federal REC tracking system, House Bill 3221 contemplated the coexistence of such state programs. n41 Further, the proposal stated, all retail electricity supplier payments made, "directly or indirectly, to a State for compliance with a State renewable portfolio standard program, or for an alternative compliance mechanism, shall be valued ... based on the amount of electric energy generation from renewable resources and electricity savings that results from those payments." n42 The Proposed RPS thus would have kept intact state RPS programs and allowed for the issuance of both federal RECs and state RECs where the renewable energy source satisfied both the federal and state requirements. This does not mean that there would not have been lawsuits claiming some sort of preemption, but the Proposed RPS made the intent quite clear. n43

8

RPS Neg

Georgia novice packet

Environment frontline 1. A national RPS won’t significantly reduce emissions – trades off with cleaner conventional energiess Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP

2. RPS, Emissions, and Wind One does not need NEMS to see that a national RPS will cut carbon emissions by less than its percentage requirement - a rough consensus is that a 10% increase in renewable output reduces them by only about 6%. n76 This occurs because intermittently available renewables such as wind turbines (which will make up most of the renewable fleet) must be backed by gas-fired generators whose outputs can quickly adjust to fluctuations in wind velocity. Coal-fired generators produce more GHG per kwh hour generated, but they will be base-loaded because their output cannot be altered on short notice. Some renewables such as biomass and geothermal can be base-loaded and will displace coal, but the wind turbines that will dominate renewable investment primarily displace cleaner conventional energy. n77

2. National RPS won’t help environment – several reasons Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP We begin with data on renewables which suggests that a federal RPS will bring little diversity in generation resources and few environmental benefits. The next sections examine advocates' claims for it, finding them inadequate at best. As environmental policy, an RPS is inefficient by every economic standard. It is a costly measure whose effects on emissions are uncertain, difficult to integrate with existing environmental regulation, and needlessly disruptive of generation investments intended to comply with anticipated emissions rules. Other purported consequences are also questionable. As macroeconomic or industrial policy, a national RPS cannot possibly "create" net increases in employment and rural areas that it will "revitalize" seldom need the help. Claims that it is necessary to stimulate reductions in production cost lose their force in a global economy, as do expectations that it will position the U.S. to dominate the world renewables market. Rather than facilitating risk management, standard renewables contracts only transfer it from utilities to captive customers. National security is better advanced through direct policies instead of compulsory investment in renewables.

9

RPS Neg

Georgia novice packet

Environment frontline 3. Species extinction studies are based upon extinction rates on islands – these aren’t true for larger land areas Lewis, 07 – senior fellow at the Competitive Enterprise Institute (Marlo, “X. Birds, Beetles, Extinctions,” 1/22, http://cei.org/pdf/ait/chX.pdf) Extinction alarmists assume that the observed relationship between habitat loss and species loss on small islands holds for much larger land areas. Hence they suppose that any reduction in “species area,” whether due to deforestation or climate change, will result in a corresponding number of extinctions. The data tell a different story, as Bjorn Lomborg explains: If islands get smaller, there is nowhere to escape. If, on the other hand, one tract of rainforest is cut down, many animals and plants can go on living in the surrounding areas. One obvious thing to do would be to look at our own experiment, the one carried out in Europe and North America. In both places, primary forest was reduced by approximately 98-99 percent. In the U.S., the eastern forests were reduced over two centuries to fragments totaling just 1-2 percent of their original area, but nonetheless this resulted in the extinction of one only forest bird.15 Similarly, notes Lomborg, not one land animal species perished because Brazil deforested its Atlantic coast: Brazil’s Atlantic rainforest had been almost entirely cleared in the nineteenth century, with only 12 percent extremely fragmented forest left. According to [biologist E.O.] Wilson’s rule of thumb, one ought to expect half of all species to have become extinct. However, when members of the Brazilian Society of Zoology analyzed all 171 known Atlantic forest animals, the group “could not find a single known animal species which could properly be declared as extinct, in spite of the massive reduction in area and fragmentation of the habitat.”16

4. Air pollution isn’t that bad – power plans don’t have an impact Schwartz, 03 - ADJUNCT SCHOLAR, COMPETITIVE ENTERPRISE INSTITUTE (Joel, “PARTICULATE AIR POLLUTION: WEIGHING THE RISKS,” April, http://cei.org/pdf/3452.pdf) Note: PM = particulate matter Sulfate PM—the type of PM caused by coal power plant emissions—is a particularly implausible culprit as a cause of increased mortality. Ammonium sulfate, the main form of sulfate PM, is used as an inactive control substance in human studies assessing thehealth effects of inhaling acidic aerosols. Inhaled magnesium sulfate is used therapeutically to reduce airway constriction in asthmatics. Sulfate is also naturally present in bodily fluids at levels many times the amount that could be inhaled from air pollution. The evidence suggests that exposure to PM at current levels likely has little or no effect on mortality in most of the United States. Regardless, processes already set in motion guarantee substantial PM reductions in coming years. Additional near-term reductions in PM are probably best achieved by dealing with the stock of high-polluting older vehicles that account for a substantial portion of ambient PM levels in metropolitan areas. This flexible, more cost-effective approach is far more likely to result in net public health benefits than other proposals that are the focus of current legislative and regulatory activity and debate.

10

RPS Neg

Georgia novice packet

Environment – ext 1 – won’t decrease coal use RPS will only trade off with gas fired generation – won’t reduce coal use Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP

An RPS inefficiently limits the types of generation to be used rather than constraining allowable emissions of pollutants and GHGs. Percentage [*87] reductions in emissions over a region will not vary one-for-one with the percentage of power produced by renewables. Both the amounts emitted and their composition depend on the types of renewables built and the types of conventional generators they displace. As noted below, wind turbines will dominate renewable investments over at least the medium-term, but their intermittent availability means that they will largely displace gas-fired generation that can adjust output on short notice. Gas-fired plants emit fewer criteria pollutants and GHGs than coal-burning ones, so using intermittent renewables to satisfy an RPS will cut emissions by less than the RPS percentage. Unlike gas-fired generators, coal units will remain base-loaded and operating at almost all times. Among other renewables, geothermal and biomass plants can be base-loaded, but their growth prospects appear small.

RPS won’t reduce coal consumption – trades off with natural gas Hall & Kirkham, 7 – natural resource attorneys with Stoel Rives LLP (Richard R. Hall and John S. Kirkham, The Enterprise Newspaper, “Coal: Like It or Not, It's Here to Stay,” 6-1-2007, www.stoel.com/showarticle.aspx?Show=2484) // JMP

Some point to the introduction of renewable portfolio standards as a means to reduce coal reliance and the environmental impacts associated with coal-fired generation. Renewable portfolio standards typically require a certain level or percentage of electricity purchased or consumed by a utility or governmental entity to be produced from renewable sources. While renewable portfolio standards have had measured success in promoting the development of renewable energy sources, they do not appear to have a significant effect on coal consumption. Due to price differentials, renewable portfolio standards tend to decrease the consumption of natural gas, rather than coal. In the long run, the development of renewable energy sources may certainly prove key to reducing global reliance on coal. However, in the short term, encouraging the development of renewable energy sources alone does not appear to have a substantial effect on coal use or carbon dioxide emissions from the electricity sector in the absence of other policy measures.

Reliability concerns will force utilities to operate fossil fuel back up generators Ralls, 6 – Senior Regulatory Counsel at the National Rural Electric Cooperative Association (Mary Ann, Energy Law Journal, “Congress Got it Right: There’s No Need to Mandate Renewable Portfolio Standards,” Vol. 27, no. 2, p.451, Proquest) // JMP B. Flexibility in Assessing Reliability

Like renewables programs, there is no "one-size-fits-all" approach to assessing reliability of renewable resources. Certainly some, such as biomass and landfill gas, are dispatchable.91 Since there is no guarantee that wind and solar will generate power when needed, purchasing utilities may be forced to continue to operate traditional fossil-fuel, back-up generators when necessary. Because of the need to run these back-up systems, the environmental and economic benefits of certain renewable resources may be overstated.92 In a recent study, the North American Electric Reliability Council (NERC) noted that because renewable resources are intermittent in nature, generating capacity that is available during peak periods is less predictable than capacity from traditional fuels, and energy actually produced during these times is even smaller. According to NERC, reliability has two components-supply adequacy and operating reliability. Two

elements of renewables-intermittence and low energy production-necessitate that back-up resources and transmission capacity be available to ensure supply adequacy. Additionally, renewable resources must be assessed on their ability to provide levels of reactive power capability, voltage regulation, and low-voltage ride-through capability sufficient to maintain connection to the bulk transmission system under low-voltage conditions.93 To the extent that implementers of renewable programs perceive that the lack of reliability creates a barrier to successful incorporation of renewables into utility portfolios, the RPSs or other programs can be and are being revisited. For instance, Texas recently amended its statute to require utilities to upgrade their transmission systems to meet RPS goals and to be able to recover those costs in their rate bases.94 In California, the IOUs have expressed concern that they may not be able to meet the 20% by 2010 standard because of transmission constraints.95

11

RPS Neg

Georgia novice packet

Environment – ext 2 – won’t help environment Environmental compliance can be met with conventional plants – RPS not necessary Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP C. Efficiency Through Time The principles of efficiency extend to durable investments in generation and transmission. Intertemporal efficiency entails the choice of investments that produce a utility's planned output at the lowest cost, discounted to the present for comparability with alternative projects. Any chosen project must also account for expected future policy constraints such as more stringent air quality standards, and possibly GHG abatement or sequestration. Different investments will be optimal for differently situated utilities. Some might choose gas-fired units whose emissions are easier to control but whose fuel prices are less stable. [*88] Others might choose coal-burning technologies in the expectation that satisfactory abatement or sequestration technologies will be available at reasonable cost. Still others might invest in demand management. The utility's optimal choice will depend on expectations of the future and on the legacy generation the utility is bringing forward. Renewables have been available as supply options for some time, but most utilities appear to have determined that they can meet their service obligations and remain in environmental compliance by investing in conventional plants and demand management. In states with RPS, utilities have generally chosen to make the required compliance investments in renewables, but not to build renewables beyond those amounts. A national RPS affects both those states with existing programs and those without. In the latter it forces the costly modification of supply plans that utilities expect will be in compliance with air quality and GHG regulations. The fact that renewables have lower emissions cannot by itself justify a requirement that they be built in lieu of conventional generation. Economic efficiency means production at least cost, where costs reflect the market values of all relevant resources. Whether lower allowable concentrations of pollutants or emissions of GHG are warranted is properly the subject of rulemakings like those that have set currently standards, rather than an ad hoc regulation like RPS. RPS reverses standards and institutions to efficiently control pollution Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP VII. Conclusions A national RPS has appeared in legislation or proposed legislation eighteen times since 1997. n129 Its continuing appeal is more the result of its rhetorical force and political expediency than its likely consequences for electricity and the environment. RPS

at any level reverses decades of hard-won progress in determining standards and developing institutions for the efficient control of criteria pollutants. It is also inefficient as GHG policy. It concentrates on using a certain technology rather than directly addressing emissions, and its alternatives in a comprehensive GHG policy have yet to be spelled out. Current trends suggest that wind power will constitute the great majority of compliance investments, but ensuring the reliability of a wind-dependent grid will require major transmission investments and continued reliance on conventional generation. Biomass and geothermal power have not yet passed the market test and solar power is a negligible presence, leaving wind to power any renewable future. Wind's intermittency implies that it will primarily displace gas-fired generation, while coal plants that pollute more heavily remain base-loaded. Among the few NEMS forecasts we can accept with confidence are its projections of substantial new investment in coal, gas, and possibly nuclear generation to keep up with even conservative estimates of load growth.

12

RPS Neg

Georgia novice packet

Environment – Ext 4 – air pollution answers Their studies reflect methodological bias Schwartz, 03 - ADJUNCT SCHOLAR, COMPETITIVE ENTERPRISE INSTITUTE (Joel, “PARTICULATE AIR POLLUTION: WEIGHING THE RISKS,” April, http://cei.org/pdf/3452.pdf) Note: PM = particulate matter However, epidemiological analyses are susceptible to various methodological biases and errors that could cause misattribution of health effects to PM when they are caused by another pollutant or by factors unrelated to pollution, such as weather or diet. Some epidemiologists believe that epidemiologic methods are not even capable of accurately teasing out very small increases in health risks. Although epidemiologic studies have had mixed results on the link between particulates and health, the media and politicians have often failed to convey the nuances, uncertainties, and controversies surrounding the science of PM health effects.9 Air pollution has been declining for decades Schwartz, 03 - ADJUNCT SCHOLAR, COMPETITIVE ENTERPRISE INSTITUTE (Joel, “PARTICULATE AIR POLLUTION: WEIGHING THE RISKS,” April, http://cei.org/pdf/3452.pdf) Note: PM = particulate matter Air pollution sources and trends. Appropriate policy depends not only on current pollution levels, but also on expected future pollution levels. This paper begins with a summary of air pollution trends, current levels, and prospects, based on pre-existing trends and regulations already on the books. It shows that PM and other kinds of air pollution have been declining for decades— few areas of the United States now have high air pollution levels, relative either to current health standards or past levels. The study concludes that baseline trends—mainly turnover of the vehicle fleet—combined with existing requirements for industrial sources, will result in large reductions in all major air pollutants in coming years. This means that air pollution has been largely addressed as a long-term problem, but also that these already-adopted measures will take time to come to fruition. Particulate matter levels are too low to have health effects Schwartz, 03 - ADJUNCT SCHOLAR, COMPETITIVE ENTERPRISE INSTITUTE (Joel, “PARTICULATE AIR POLLUTION: WEIGHING THE RISKS,” April, http://cei.org/pdf/3452.pdf) Note: PM = particulate matter The report concludes that current PM levels are generally too low to increase risk of death due to long-term exposure and that EPA’s current annual-average PM2.5 standard is more stringent than necessary to protect public health. The weight of the evidence for short-term health effects is less clear. Although many studies have reported increases in death and disease due to daily increases in PM levels, a number of researchers have raised substantive concerns over whether PM is the pollutant responsible for the observed health effects, whether pollution reduces life-expectancy by more than a few days, whether there is a threshold level below which PM has no health effects, and whether the confounding effects of non-pollution factors such as weather have been adequately addressed.Recently discovered software glitches may also have caused dozens of studies to overestimate the acute health effects of PM. A detailed review of the dozens of studies of short-term PM health effects is beyond the scope of this report, which aims to give the reader an understanding of the key issues and the current state of the science. The report concludes that there is still substantial uncertainty in the degree of increased mortality due to daily variation in PM levels, though the evidence suggests that PM is at worst shortening life by no more than a few days in already-frail individuals. In addition, progressive refinements in the research literature have tended to reduce the size of the estimated effects. It also concludes that the issue is currently moot for policy purposes, since no more than a few percent of monitoring locations exceed the federal health standard for daily PM10 or PM2.5 levels.

13

RPS Neg

Georgia novice packet

Competitiveness frontline 1. Several policy steps are necessary to ensure U.S. competitiveness Segal, 4 – Senior Fellow in China Studies at the Council on Foreign Relations (Adam, Foreign Affairs, “Is America Losing Its Edge?” November / December 2004, http://www.foreignaffairs.org/20041101facomment83601/adam-segal/is-america-losing-its-edge.html) // JMP Of equal importance, policymakers must also reinforce the United States' entrepreneurial climate, its greatest asset. The building blocks of American innovation-flexible capital and labor markets, transparent government regulation, and a business environment that rewards risk-need to be strengthened. Making the R&D tax credit permanent and expanding it to include more types of collaborative research, for example, would help provide incentives for innovation in as many technological sectors as possible. With innovative capacity rapidly spreading across the Pacific, the United States cannot simply assume that it will remain the epicenter of scientific research and technological innovation. Instead, it should meet the challenge from Asia head-on. The United States must actively engage with new centers of innovation and prepare itself to integrate rapidly and build on new ideas emerging in China, India, and South Korea. Above all, it must not assume that future innovation will occur automatically. Only through renewed attention to science funding, educational reform, the health of labor and capital markets, and the vitality of the business environment can the United States maintain its edge-and the most innovative economy in the world.

2. A federal RPS will drive manufacturing jobs overseas Yeatman & Ebell, 7 – * Energy Policy Analyst at the Competitive Enterprise Institute and ** Director of Energy and Global Warming Policy at CEI (William Yeatman and Myron Ebell, “Gone with the Wind: Renewable Portfolio Standard Threatens Consumers and the Industrial Heartland,” 6-12-2007, No. 114, http://cei.org/pdf/5982.pdf) // JMP

Regions With a Comparative Disadvantage. By and large, states that have adopted renewable portfolio standards were already burdened with high electricity rates; most of them also have high wind potential. But not every state suffers high electricity costs, nor is every state endowed with windy plains. For example, the Southeast is a region where consumers enjoy some of the lowest electricity rates in the land, largely due to reliance on coal-fired generation. On the other hand, the Southeast has the least wind potential in the country, closely followed by the Midwest. The impact of a federal RPS on manufacturing regions with low electricity costs and low wind energy potential promises to raise electricity rates considerably. (Map 4) According to the Commerce Department’s Bureau of Economic Analysis’ industry specialization index, which measures states’ level of industrial specialization, the Upper Midwest and the Southeast are more dependent on the manufacturing sector than other regions. Although manufacturers have moved their factories from states with high electricity costs to these states with lower electricity costs, a federal RPS would then tend to drive these industries to foreign countries with lower electricity rates.

14

RPS Neg

Georgia novice packet

Competitiveness frontline 3. Renewables not linked to security – they don’t impact competitiveness Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic)

Others hope that a national RPS can bring U.S. domination of the world's renewables markets. One advocate sees it as a necessary response to renewables-based export policies that are taking shape in Japan. n39 He believes Americans must emulate the cooperation between Japan's manufacturers and government planners, a vision of invincibility from the 1970s and 1980s that died with the recession and banking crisis of the 1990s. n40 Experience gives little reason to expect that such concerted policy formation can make either nation dominant. The U.S. will continue to export those in which it has a cost [*91] advantage and import those in which it does not. n41 International trade in renewables raises no security issues, since they are ordinary manufactures that no nation or group can credibly monopolize.

4. RPS won’t impact world markets – renewables can already cross borders Michaels, 8 – Professor of Economics at CSU Fullerton (Robert J., Energy Law Journal, “National Renewable Portfolio Standard: Smart Policy or Misguided Gesture?” 29 Energy L. J. 79, Lexis-Nexis Academic) // JMP

B. RPS as Technology Policy and Foreign Policy Some believe that a national RPS will help drive down the costs of renewables. n36 It is, for example, possible that large purchase orders will bring forth larger plants that capture economies of scale that have not been realized in today's relatively smaller ones. Renewables, however, have no obvious characteristics that would lead to economies in production exceeding those of similar manufactured goods, most of whose markets support at least several U.S. and foreign producers. Renewables can easily cross national boundaries in both directions, and a federal RPS will have little impact on already-competitive world markets. n37 The development of renewables has attracted technology investors, venture capitalists, and large firms (e.g. General Electric) with available internal funds.

15

RPS Neg

Georgia novice packet

Competitiveness – ext 2 – go overseas A federal RPS will jack up energy prices and push manufacturing jobs abroad Yeatman & Ebell, 7 – * Energy Policy Analyst at the Competitive Enterprise Institute and ** Director of Energy and Global Warming Policy at CEI (William Yeatman and Myron Ebell, “Gone with the Wind: Renewable Portfolio Standard Threatens Consumers and the Industrial Heartland,” 6-12-2007, No. 114, http://cei.org/pdf/5982.pdf) // JMP As part of comprehensive legislation to raise energy prices, Congress is once again considering proposals to set a renewable portfolio standard (RPS) for electric utilities. Such a requirement would raise electricity prices for consumers and industry, but would negatively affect some regions of the country much more than others. As the Bush Administration Statement of Policy of June 12, 2007 correctly states: A limited Federal RPS would result in higher electricity costs for consumers in areas where renewable resources are less available and could place new strains on electricity reliability needs. Although 21 states have already passed a renewable portfolio standard, this is not an argument in favor of a federal RPS. These RPS states tend to have a much higher potential for renewable energy, less energy-intensive manufacturing, or both. In the RPS states that do have considerable manufacturing, the effect of adopting an RPS has been to raise electricity prices and push manufacturing into states or other countries with lower electricity prices. Therefore, a federal RPS would require states with low electricity prices and proportionately lower renewable energy potential, such as is found in our industrial heartland, to raise electricity prices to a level that would force their industries to migrate overseas to countries with cheaper energy rates and no renewable portfolio standards. A federal RPS will undermine many manufacturing industries Yeatman & Ebell, 7 – * Energy Policy Analyst at the Competitive Enterprise Institute and ** Director of Energy and Global Warming Policy at CEI (William Yeatman and Myron Ebell, “Gone with the Wind: Renewable Portfolio Standard Threatens Consumers and the Industrial Heartland,” 6-12-2007, No. 114, http://cei.org/pdf/5982.pdf) // JMP Conclusion. Depending on the current cost of electricity and renewable energy potential, the economic impact of a federal renewable portfolio standard is modest in some regions of the country and dire in others. State legislators have weighed the economic costs and benefits of an RPS in their states and acted accordingly. Congress should not impose a federal renewable portfolio standard on those states that have correctly judged that such a mandate would raise their consumer electricity prices and destroy jobs in energy-intensive industries. While Members of Congress from some regions of the country may be tempted to economically disadvantage states in other regions by voting for a federal RPS, they should recognize that it is not in the nation’s interest to undermine any of our manufacturing industries.

16

RPS Neg

Georgia novice packet

Competitiveness – ext 3 – renewable not key RPS not necessary for U.S. competitiveness and renewable are not linked to security and defense Michaels, 8 – Adjunct Scholar at CATO and Research Fellow at the Independent Institute (Robert J., Electricity Journal, “A National Renewable Portfolio Standard: Politically Correct, Economically Suspect,” April 2008, vol. 21, no. 3, Lexis-Nexis Academic) // JMP B "Infant industries" and technology development If renewables are indeed the future, some advocates think that a national RPS can both hasten its arrival and mitigate its shocks. Their claims are analogues of those long made by seekers of "infant industry" tariff protection from foreign competition. Among the variants are: (1) If a national RPS brings large and dependable orders, renewables manufacturers will invest in high-capacity plants with low production costs; (2) Those costs will be high when renewables are a novelty, but an RPS will bring added production experience that will lower them; (3) As operating experience accumulates, existing renewables will be used more efficiently and innovators will devise further design and operating improvements; and (4) With a national RPS, the U.S. can outpace other nations and possibly dominate world renewables manufacture, benefiting both workers and capitalists. There is no evidence that economies of scale are more extensive in renewables than in comparable goods, and they are clearly not a "natural monopoly" where a single producer serves the entire market most efficiently.47 Most

manufacturing industries support a number of U.S. producers, and markets for many are expanding to cover the world.48 Both national and international competition will exist with or without a federal RPS. The existing renewables industry has also had few problems accessing the capital markets. New technologies are attracting venture capital and firms as large as General Electric are using their own cash, all without a national RPS. There are also no important economies of scale outside of manufacturing. Engineering and construction are within the expertise of numerous contractors, most quite small relative to their markets. All competitive producers face pressure to reduce costs, with or without mandatory purchase requirements like an RPS. Competition

to innovate comes from both other renewables makers and producers of non-renewables that are substitutes for some buyers. An RPS cuts the degree of pressure that comes from the latter by foreclosing them from part of the market. Producers also reduce costs by observing and imitating successful practices of others, including foreigners. A growing market in intellectual property allows Americans access to new technologies without duplicating the research of others.49 Innovations extend beyond technology to new operating practices and contract provisions which can also be imitated. Some see RPS as a tactic that can make the U.S. the world's leading renewables producer, possibly in response to the alleged growth of a governmentally guided renewables industry in Japan.50 Others claim that a large percentage of the jobs created by an RPS will be in exporting renewables.51 Another author is concerned about a drop in the U.S. share of global solar collector production from 44 percent in 1996 to below 9 percent in 2005.52 The simple fact is that the case for free trade in renewables is no different from the case for free trade in anything else.53 If Americans are relatively more productive in renewables they will supply other nations. If not, someone else will and Americans will produce other goods and services.54 More

realistically, the U.S. will both import and export renewables. A declining share of solar production probably indicates that others should do the job (or possibly that solar is overrated). International trade in renewables raises few security issues because they are manufactured in so many nations and because they embody few if any materials essential for national defense.

RPS won’t boost jobs or export dominance Michaels, 8 – Adjunct Scholar at CATO and Research Fellow at the Independent Institute (Robert J., Electricity Journal, “A National Renewable Portfolio Standard: Politically Correct, Economically Suspect,” April 2008, vol. 21, no. 3, Lexis-Nexis Academic) // JMP VII Conclusions Backers of a national RPS have produced an impressive list of objectives. For every one of them an RPS will at best be an inefficient policy, and at worst it will be outrightly pernicious.

As environmental policy, it violates every economic principle of efficient emissions control, including those that are embodied in existing programs to regulate criteria pollutants. A national RPS will impact emissions controlled under existing programs, but supporters have been silent on how to integrate it with existing policy. Of course, even if a national RPS is a costly source of environmental benefits it might produce others that would tip the cost-benefit balance in its favor. Unfortunately, it does the opposite.

Some of the claimed benefits are fallacies from macroeconomics (job creation in a non-depression economy) and international economics (the importance of self-sufficiency and export dominance). Others reflect personal preferences, like the hope that renewables will reverse rural outmigration and bring communal ownership. Renewables are but one of many possible tools for fuel risk management, and fixed-price renewables contracts do little more than transfer risk from utilities to captive customers. "Energy independence" is almost entirely an oil-related problem, and "national security" is more effectively ensured by hardening vulnerable assets than by building renewables.

17

RPS Neg

Georgia novice packet

Competitiveness – ext 4 – no innovation RPS won’t effectively reduce pollution or cause innovation Michaels, 8 – Adjunct Scholar at CATO and Research Fellow at the Independent Institute (Robert J., Electricity Journal, “A National Renewable Portfolio Standard: Politically Correct, Economically Suspect,” April 2008, vol. 21, no. 3, Lexis-Nexis Academic) // JMP IV Renewables and the Environment A Setting efficient rules From the start, RPS proposals have used language familiar to economists. Pollutants produced along with power impose health and environmental costs on third parties. These "externalities" are evidence of "market failure" that requires corrective policy, and RPS was initially proposed to carry out that policy.33 Other rationales exist (and are discussed below), but an RPS is most commonly viewed as environmental regulation. Any type of regulation can be economically efficient or inefficient - restrictively defined, efficiency means that a given goal is attained at the smallest sacrifice of economic value, as measured by the prices of other goods foregone. More generally, an efficient policy maximizes the value of benefits relative to costs, again at market prices.34 A consensus on standards for efficient environmental regulation has emerged among economists and policymakers, who are increasingly using them to set emissions levels, draft rules, and enforce compliance. They can be distilled down to a few principles, each of which strongly counsels against

a national RPS. Set permitted concentrations individually based on costs and benefits. Broadly, EPA sets acceptable levels for major "criteria pollutants" such as sulfur and nitrogen dioxides by examining the costs and benefits of alternative concentrations.35 The science and decision-making are both imperfect, and the standards that emerge have political as well as economic and scientific elements.36 Allowable concentrations must be set individually because pollutants have different critical levels and the costs and benefits of reducing them differ. By contrast, no

state or proposed federal RPS percentage has been set in a way that remotely resembles those in general use for criteria pollutants. The percentages have been set arbitrarily and the exact mix of avoided emissions will depend on the kinds of renewables that are built. Renewables that can be base-loaded can replace coal, whose emissions of pollutants and GHG exceed those of the gas units that intermittent renewables displace. Deal with all sources and allow trading of allowances. To maximize net benefits, regulation should attack all sources of the pollutant. Exempt sources may have lower abatement costs than ones subject to the regulation. An increasing number of pollutants are being handled by "cap-and-trade" systems that set ceiling concentrations, issue allowances for rights to emit, and allow their exchange. Those who can cheaply cut their emissions will gain by doing so and selling their allowances to those who cannot. Decentralized trades use only the participants' private knowledge, and regulators need not intrude to acquire the information they would need to set quotas for individual polluters. Innovation is encouraged because someone who devises a better control technology can profit both by selling its permits and selling the invention. An

RPS by contrast deals with only one of many sources of a pollutant. Only by incredible accident can it be an efficient tool for achieving a given reduction. The RPS may also fail to encourage innovation. Regulators allow utilities to pass the costs of prudently acquired power from renewables on to ratepayers. Utilities using unorthodox renewables may face greater risk of disallowances than those using more established ones. Regulate the pollutant directly. Since the pollutant itself is the source of harm, efficient policy should concentrate on it rather than on the technology or inputs that produce it. A cap-andtrade system does this by rewarding only actual reductions, however they are achieved. Innovators may devise novel abatement methods, and efficient mitigation will vary with prices in ways that regulators cannot foresee. An

RPS is a design standard that restricts the allowable set of technologies even if there are cheaper ways to reduce the pollutant. Even if an RPS encourages innovation in the allowable technologies, it will probably discourage experimentation with technologies (including demand management) that do not qualify under it.37 Match geography with costs and benefits. To the extent possible, a pollutant should be regulated over an area wide enough to include all relevant sources and narrow enough to subsume only locations where actual harm occurs. For example, EPA's Clean Air Interstate Rule for SO2, NOx and some particulates will only apply in Midwestern and Eastern states where they significantly affect air quality and winds seldom blow them away.38 A national

RPS will result in inefficiently low concentrations in areas that are already in compliance, and must be coordinated with other programs in non-attainment areas. It may have too large a footprint for some criteria pollutants, and too small a footprint for GHG. If GHG affect the entire planet, the impacts of requiring a small portion of one industry in one nation to change its technology will be costly to the industry and its customers, and symbolic for everyone else.

18

RPS Neg

Georgia novice packet

A2 – Competitiveness key to hegemony Economic power is not zero-sum Julius, 5 – Chairman of Chatham House, formerly the Royal Institute of International Affairs (Deanne, Harvard International Review, “US Economic Power,” Winter 2005, vol.26, no.4, p.14-18) // JMP What is Economic Power? The very concept of economic power is more nebulous than that of military power. The ultimate test of military power-war-is the classic zero-sum game. If Country A has a more powerful military than Country B, then Country A is likely to win in a war between the two. And in the lead-up to war, Country B is more likely to back down. So having military superiority is clearly n good thing. There is no parallel in economics because economic competition is not a zero-sum game. Country A may be richer than Country B, but both will be better off through trade if the other grows richer. In the general case of a free-trade agreement between a rich and a poor country (say, the United States and Mexico), the poor country gains more. Similarly, in joining a common currency such as the euro, the poorer countries will benefit more than the richer ones. European experience since 1999 supports this: Portugal and Greece have grown faster than their historical rates while Germany and France have grown more slowly. But on the economic battlefield, the success of one country does not imply the defeat of another. Military strength is not necessarily connected to economic power Julius, 5 – Chairman of Chatham House, formerly the Royal Institute of International Affairs (Deanne, Harvard International Review, “US Economic Power,” Winter 2005, vol.26, no.4, p.14-18) // JMP The concept of national power has both military and economic dimensions. While the two are related, they can also exist independently. The Soviet Union during the 1960s and 1970s, for example, was a military superpower but economically weak and isolated, while Japan during the 1980s was an economic superpower with a weak military. Much attention has been devoted, on both sides of the Atlantic, to the military aspect of US power and how it is exercised both in unilateral action and through alliances like NATO. By contrast, the question of economic power has been relatively neglected, perhaps because it is more difficult to define and measure. This article is an attempt to remedy the imbalance and provoke further discussion on the emerging shape of the world economy and the ability of the United States to influence it.

19