NEPOOL GIS Overview – An Emissions Reporting and Tracking Tool: Source Based and Load Based

1. NEPOOL GIS Overview –An Emissions Reporting and Tracking Tool: Source Based and Load Based Devon Walton NEPOOL GIS Administrator APX, Inc CPUC/CEC Workshop on Linking Load-based and Source-based Greenhouse Gas Cap and Trade Systems: Issues and Solutions, San Francisco, April 19, 2007

2. Summary • Overview of the NEPOOL GIS Program • Users of the NEPOOL GIS • NEPOOL GIS as a Source-based Emissions tool • NEPOOL GIS as a Load-based Emission tool • Some Lessons Learned

3. Lake Superior Lake Lake Huron Ontario Lake Lake Michigan Erie APX Infrastructure Juneau The NEPOOL GIS modules described here could be deployed in other regions relatively quickly and with modest effort. BRITISH MANITOBA COLUMBIA Lake Winnipeg VANCOUVER ISLAND Vancouver 2002 NEPOOL GIS Victoria Olympia MAINE Winnipeg Augusta WASHINGTON NORTH DAKOTA Montpelier NEW MINNESOTA 2007 M-RETS HAMPSHIRE Helena VERMONT Salem Concord Bismark MONTANA NEW Boston Y0RK MASSACHUSETTS OREGON WISCONSIN St. Paul Albany Providence SOUTH DAKOTA RHODE ISLAND Hartford Boise CONNECTICUT MICHIGAN Pierre 2005 PJM GATS 2007 WREGIS IDAHO PENNSYLVANIA WYOMING Windsor Lansing Madison Trenton NEW JERSEY IOWA Harrisburg NEVADA NEBRASKA OHIO Dover Cheyenne Annapolis INDIANA Des Moines DELAWARE ILLINOIS Washington D.C. Lincoln Sacramento Salt Lake City Columbus MARYLAND Carson City WEST Indianapolis VIRGINIA Richmond Denver Springfield UTAH Jefferson City Charleston Topeka VIRGINIA Frankfort COLORADO KANSAS CALIFORNIA KENTUCKY Raleigh MISSOURI NORTH CAROLINA Nashville TENNESSEE OKLAHOMA Columbia Santa Fe ARKANSAS ARIZONA SOUTH Oklahoma City Atlanta MISSISSIPPI 2001 Texas RECs Little Rock CAROLINA Phoenix NEW MEXICO Montgomery GEORGIA ALABAMA Jackson TEXAS Tallahassee Baton Rouge Austin BAJA LOUISIANA CALIFORNIA NORTE FLORDIA

4. What is the NEPOOL GIS? • New England Power Pool Generation Information System is a multi-purpose system for the Power and Utility Industry: • Tracking all Generation – NEPOOL, behind-the-meter, and imported power from adjacent control areas. • Tracking all Load – by load asset, for all load assets in NEPOOL. • Tracking all Emissions – providing regional, quarterly reports for all self-reported emissions. Unreported emissions are replaced with proxy data. • Creating Serialized Certificates for every 1MW of generation, renewable or not. • Creating Certificates of Obligation for every 1MW of load consumed. • Facilitating and Tracking RPS Compliance for Massachusetts, Maine, Connecticut and Rhode Island. Also Energy Efficiency & Conservation Certificates in Connecticut. • Accounting Mechanism for Certificate Transactions, including ownership recording, retirement, and full audit trail and history. • Reporting for a multitude of Public, Private, and Regulatory data needs.

5. GIS Overview – 235 Participants • Generator Owners • NEPOOL Generators all the way down to home owners • Load Serving Entities • If you serve load in NEPOOL, the GIS is creating your Obligation • Traders and Brokers • The GIS serves as a Certificate accounting mechanism for the physical transfer of the Certificates • Regulators • Provides access to account information and data for purposes of tracking State RPS Compliance and emissions related reporting • The Public • Provides access to public information regarding certificate statistics, emissions data, load, and generation • System Administrator • Responsible for all of the day-to-day operations of the system

6. Source-based Emissions Tracking in the NEPOOL GIS • All Generators must enter their monthly emissions prior to Certificate creation • Generators importing from adjacent control areas that expect unit-specific Certificate creation must also enter their monthly emissions • Certificates are created for every MWh of energy produced • Each serialized certificate contains emission rate information for CO2, SO2, NOx, CO, PM, VOCs, Hg – (all in lbs per MWh) • Certificates related to Imported Energy can be either unit specific or the system mix of the exporting region – emission data on the certificate reflects either

7. Source-based Emissions Tracking in the NEPOOL GIS • GIS provides emissions reports by generating unit, by State, and by Region. • The NEPOOL System Mix report provides data on total emissions by fuel type at Certificate Creation – accounts for all system emission data for every MW generated for the given time period. • The NEPOOL Residual Mix report provides data on fuel type emissions remaining after Certificate Retirement – accounted as weighted average emission data for every MW not explicitly tied to obligation by LSE’s for their disclosure.

8. Source-based Emissions Reporting Source-based tracking reports provide emissions data by generating unit and by fuel type for the region.

9. NEPOOL GIS as a Load-based Emissions Tracking System • GIS tracks all Load served in the NEPOOL Region. GIS creates a Certificate of Obligation for every MWhr of this reported load. • The system requires that every created Certificate of Obligation be matched with a created Certificate of Energy (renewable or non-renewable). • Any unmatched Certificates of Obligation in an LSE’s account at the end of a quarterly trading period are forcefully matched with a Residual Mix Certificate of Energy (the weighted average of all remaining Certificates of Energy that had not be otherwise ‘used’ or retired). • GIS publishes reports by LSE, that provide total emissions for load served based on Certificates of Energy deposited in each LSE account.

10. Load-based Emissions Reporting Load Serving Entities create multiple “sub-accounts” for each State in which they serve load. At the end of each trading period, this report displays the Certificates retired (i.e. matched with a Certificate of Obligation) and the Carbon Emissions associated with each.

11. Load-based Emissions Reporting State Regulators can determine the carbon footprint for load served in their State based on certificates that LSEs have deposited in state ‘sub-accounts”.

12. NEPOOL GIS Lessons Learned • Mistakes happen in emissions reporting. Procedures are needed to handle them. • Accuracy of emissions data must be verified. Who’s verifying the accuracy of entries? • Ensuring compliance with reporting rules is necessary. Requirements without penalty can result in requirements not being met. • Tracking all generation, all load, and all emissions in a trusted repository gives regulators a rich “toolkit” to manage and implement policy • 650 Million+ Certificates with emissions data, including full transaction history, can be maintained securely with high reliability and availability via a transparent web-based system for all stakeholders

13. Potential Extensions • Allowances and Offsets • Functionality can be enhanced to track Allowances and Offsets (verified emissions reductions) in Carbon Trading programs • Tracking System will then support a unified regulatory approach, linking REC, Energy Efficiency and Carbon Trading programs • Carbon Avoidance • For Renewable Energy or Energy Efficiency • Enhancing a Tracking System to calculate the avoided emissions for every MWh of energy is not difficult • The formula for avoided emissions can take into account several factors, such as geography and the emissions footprint for the state or region • Extending current infrastructure is the most efficient and cost effective approach to handle Emission Allowances and Avoided Emissions for the power/utility industry.

14. Summary • NEPOOL GIS Tracks • All Generation • All Emissions • All Load • All Power Imports and related Emissions • All Transactions of Certificates • All Participants and Account Holders • All Jurisdictional and Validity Information • Energy Efficiency & Conservation Certificates (CT Class III) • NEPOOL GIS functions could be enabled in the other US regional power industry tracking systems, based on stakeholder approval. • Proven and available today. • Existing tracking systems can support both load-based and source-based approaches to GHG management. • There is no technology barrier.

15. Contact Information Devon Walton GIS Administrator – APX, Inc. 5201 Great America Parkway, Suite 522 Santa Clara, CA 95054 212-737-1708 dwalton@apx.com