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Rights & Permissions

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Electricity from Renewable Resources: Status, Prospects, and Impediments (2009)
National Academy of Sciences (NAS)

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION 6 Deployment of Renewable Electric Energy Renewable energy technologies are poised to become an important component of the electricity supply mix. However, it is not a foregone conclusion that the United States will achieve and maintain a high rate of deployment of renewable electricity. The current financial situation (as of 2009) is impacting the renewables market at many levels, but the issues discussed in this chapter are nonetheless important for expanding the market for renewable electricity technologies. Renewables face challenges involving the deployment and commercialization of innovative technologies—the stages that follow technological innovation and development. These challenges include: the risk of introducing new technologies into competitive markets; the investment in the long-term, market-enabling research and development activities needed to help move technologies along the learning curve; and the impact of policy measures that share the risk of product innovation and market transformation. The proverbial investment valley of death1 can prevent new technologies from advancing past the demonstration phase due to a lack of capital. Manufacturing capacity, policy, business and market innovation, and access to financing must coincide with technology innovations for the continued successful deployment of renewable sources of electricity. As noted in Chapter 3, in many ways new renewable electricity technologies, and the thinking that will enable them, represent disruptive rather than incremental changes in long-established industry sectors. Disruptive technologies have two important characteristics. First, they typically present different performance attributes, such as providing a carbon-free source of electricity, that, at least at the outset, are not valued by a majority of customers. Second, the performance attributes (e.g., costs) for disruptive technologies that customers do value can improve at such a rapid rate that the new technology can overtake established markets. Figure 6-1 shows how the performance of a disruptive technology that was once lagging that of an earlier established technology can improve at a faster rate. However, such performance improvements are speculative and are not always realized. In the case of renewable electricity technologies, on a conventional cost-of-energy basis traditional sources of electricity generation initially outperform non-hydropower renewables. The attraction of technologies that use renewable resources, together with government incentives, has been responsible for much of their market presence. However, owing to improvements in renewable technologies 1 A stage after product development but before commercialization when the financial investment required to move a new technology to commercialization may exceed the ability of a new business to raise capital. 167

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION and cost increases for fossil fuels and nuclear power, renewables are gaining the ability to match the cost performance of traditional generating sources both in the wholesale power market and on the customer-side of the meter. Nearly 200,000 buildings in the United States are installing distributed systems per year, many without incentives from utilities or government. This chapter explores the logistical and market barriers to commercial-scale deployment of renewable electricity. Although individual renewable energy technologies have unique developmental and economic characteristics, there are common, non- technical challenges as well, including (1) constraints on capacity for larger-scale manufacturing and installation and limitations on the availability of trained employees for manufacturing, installation, and maintenance; (2) integration of intermittent resources into the existing electricity infrastructure and market; (3) market requirements such as capacity for competing in price and performance with conventional lower-cost coal, nuclear, and natural-gas-fired power plants; and (4) risk and related issues, including business risk and cost issues, unpredictability of and inconsistency in regulatory policies, and time requirements for building the necessary technical, business, and human infrastructures. Because of the robust regulatory and business activities related to wind and solar energy industries, many examples discussed in this chapter come from these sources. However, they are used to indicate deployment issues associated to some degree with other renewable sources of electricity. DEPLOYMENT CAPACITY CONSIDERATIONS Capacity constraints, such as restricted supplies of basic raw material inputs, limitations on manufacturing capacity, competition for larger construction project management and equipment, and limited trained workforce, have the potential to derail large-scale deployment and integration of renewable electricity resources. Thus, to grow the renewable electricity market, which is increasingly driven by the private sector, will require continued and ramped up investment in order to deploy, operate, and maintain these technologies. Materials, Manufacturing, and Development Considerations Raw and Basic Materials Renewable energy technologies potentially can be restricted by a scarcity of key raw materials. A common example is solar photovoltaics (PV). Recent shortages of poly- crystalline silicon have increased prices for PV modules, though these shortages were expected to ease by 2009 (Bradford, 2008). In addition, while silicon is relatively abundant, a scarcity of silver could limit use of traditional crystalline and polycrystalline silicon, as well as nano-silicon based cells,in the long term. Likewise, limited availability of naturally occurring indium could restrict more efficient thin film solar cell technologies using copper indium gallium selenide (CIGS). Solar cell raw material 168

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION components and limiting material are summarized in Table 6-1, and global reserves for key materials are shown in Figure 6-2 (Feltrin and Freundlich, 2008). TABLE 6-1 Critical Limiting Raw Materials Needed for Fabrication of Solar Cells Solar Cell Limiting Material Usage Poly/c-Si Silver (Ag) n-electrode a-Si Indium (In) TCO substrate CdTe Tellurium(Te) Cell material CIGS Indium (In) Cell material Dye-sensitized Indium (In) TCO Tin (Sn) TCO Platinum (Pt) TCO Con. MJC III-V Germanium(Ge) Substrate Gallium (Ga) GaAs substrate Con. MJC III-V, lift-off Indium (In) Cell material Gold (Au) Electrode NOTE: TCO, transparent conductive oxide. SOURCE: Adapted from material in Feltrin and Freundlich (2008). There are also issues related to global competition for basic materials such as steel and cement, that hinder large-scale deployment of renewables and increase renewable energy development costs. Wind turbine manufacturers are particularly affected by these material shortages. Global competition for essential elements has, in recent years, driven up the costs of commodities and limited the materials available for wind energy projects. Table 6-2 projects the raw materials needed through 2030 to support the 20 percent wind scenario (DOE, 2008a), and Figure 6-3 shows the predicted near term U.S. and global raw material usage for wind turbines. Global competition for these resources is not limited to renewables. It applies to all types of generation and to the construction sector generally. Longer term goals are achievable, but the broader use of renewables will require a well-defined strategy for deployment. 169

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION TABLE 6-2 Yearly raw materials required in 2030 to meet wind turbine demand in 20 percent wind scenario in units of thousands of metric tons Glass Carbon Reinforced fiber Permanent KWh/kga Year Magnet Concrete Steel Aluminum Copper Plastic Composite Adhesive Core 2006 65 0.03 1,614 110 1.2 1.6 7.1 0.2 1.4 0.4 2010 70 0.07 6,798 464 4.6 7.4 29.8 2.2 5.6 1.6 2015 75 0.96 16,150 1,188 15.4 10.2 73.8 9.0 15.0 5.0 2020 80 2.20 37,468 2,644 29.6 20.2 162.2 20.4 33.6 11.2 2025 85 2.10 35,180 2,544 27.8 19.4 156.2 19.2 31.4 10.4 2030 90 2.00 33,800 2,308 26.4 18.4 152.4 18.4 30.2 9.6 a Proposed scenario for energy density improvement for wind turbine growth during the 2006-2030 period. SOURCE: Adapted from material in Wiley (2007). Manufacturing and Development Wind Power Industry Developers face shortages of wind turbines due to continuing strong demand for wind power both in the United States and globally (AWEA, 2008). Wind turbine manufacturers are still in the process of making the capital investments necessary to increase their capacity to catch up with the growing demands. Projections suggest that the mismatch between turbine supplies and wind developer demands will level out as soon as 2009 (EER, 2007). Meanwhile, manufacturers continue to play catch-up with typical delays of six months or more from turbine order to delivery. Though lead times have lengthened due to the rapid growth in wind turbine installations, wind and solar PV projects have an advantage over traditional power plants because of their shorter time between purchase of the equipment and placing it on line (Bierden, 2007). Overall wind power project costs have increased due to recent increases in wind turbine prices (DOE, 2008b). Figure 6-4 shows the recent trend in turbine costs. These prices have increased due to increased costs for materials and energy inputs; component shortages; upscaling of turbine size and improvements in turbine design; declining value of the U.S. dollar; and attempts to increase profitability in the wind turbine manufacturing industry (DOE, 2008b). The increase in project costs as of year 2000 reversed the long term decline in project costs, which includes the turbine as well as other balance of system components (Figure 6-5). The upturn in the price of turbines might, however, be partially offset by an increase in the kilowatt-hour output per kilowatt turbine capacity with the use of power electronics, variable speed drives, and more stringent requirements of ride through faults in utility system operation. The increased demand for wind turbines worldwide has expanded wind turbine manufacturing facilities in the United States. Though General Electric (GE) remains the dominant turbine manufacturer, other domestic and foreign manufacturers have entered the market or expanded their operations (DOE, 2008b). Component manufacturers of blades, gearboxes, and other elements are spread across the United States (Sterzinger and Svrcek, 2004). However, lower wages have caused many manufacturers to locate 170

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION factories overseas (DOE, 2008b). In general, the strong growth nationally and internationally has resulted in an expansion of all segments of the wind industry, including manufacturers, as well as parts of the industry related to installation and operations and maintenance. There have been changes in the wind power development sector of the industry (EER, 2007). Independent power producers (IPPs) have shown increased interest in wind power projects; IPPs develop a variety of electricity generation facilities for the wholesale electricity market. IPPs have to compete against developers whose sole focus is the development of wind power projects (termed the pure play wind developers). Further, globalization has become a factor in the U.S. market with developers from Europe initiating projects in the United States. Most of these European developers provide wind through long-term contracted sales to utilities, though they also sell to power markets. A variant is the purchase of Energy East, a New York state utility, by Iberdrola S.A., a Spanish energy company that develops wind power projects worldwide. As noted in Chapter 4, there also is a market for renewable energy credits (RECs) that can be sold separately from electric power. Finally, some utilities are beginning to develop their own wind power projects instead of purchasing wind power through long term contracts with wind developers. Solar PV Industry Like wind power, the large growth rate for solar PV, both within the United States and globally, has caused shortages in manufacturing capacity and raw materials. As with wind power, it has also resulted in increasing prices and changes within the industry. As noted in the section on raw materials, the primary cause for shortages in PV is a shortage in polycrystalline silicon. Originally, the primary use of polycrystalline silicon was for semiconductors in the electronic industry, with solar PV manufacturers using a small fraction of silicon production and even using silicon recycled from the electronics industry. Recently, the solar PV industry has become the largest consumer of polycrystalline silicon, bringing new entrants into the industry that include producers specifically oriented to the solar PV industry, and even solar PV manufacturers looking to become more integrated along the supply chain (Prometheus Institute, 2006). Despite these new entrants, there was still a shortage of polycrystalline silicon, which had driven up the price for solar silicon PV modules (Figure 6-6), though this shortage was expected to subside by 2009. Recent articles project 2009 to see this decrease in costs for solar PV, though the decline in price has been attributed to both increasing supplies and decreasing demands due to the global economic slowdown (Patel, 2009). Solar companies that are expected to perform well in the current solar PV market are generally those with stable silicon supplies (EIA, 2007). Conversely, companies that are thought to have insufficient or inflated silicon supplies have not done well in the market (Greentech Media, 2007). Another current positive market characteristic is less reliance on polycrystalline silicon. There is more competition among distinctively different technologies in the solar PV industry compared to the wind turbine market. As shown in Figure 6-6, shortages of polycrystalline silicon have spurred increases in the thin-film solar PV technologies that do not require as much or any silicon. Figure 6-7 shows the impacts on shipments by U.S. manufacturers of this shift towards thin-film PV. 171

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION The rapid growth and projected demand for solar PV have spurred increases in both PV prices and demand for manufacturers to increase their manufacturing capacities. PV manufacturing in the United States is dominated by First Solar of Arizona, which has responded to market demand by expanding manufacturing capacity in Ohio and Germany, and has announced additional capacity expansion in Malaysia (Prometheus Institute, 2007). Together, this expanded capacity is expected to bring First Solar’s total manufacturing capacity to over 1 GW/year by the end of 2009. This capacity expansion substantially increased income for this company in 2008 (Greentech Media, 2008). By 2010, SunPower and SolarWorld are expected to add an additional 984 MW of capacity. The largest customer category for PV modules/cells has shifted from wholesale distributors to installers (EIA, 2007), reflecting the recent trend towards large commercial PV installations, such as those at Wal-Mart and the Google headquarters in California. The commercial sector was the largest market for PV in 2006 and grew over 100 percent from 2005 (EIA, 2007). Additionally, some PV manufacturers have begun to enter the installation business to become more fully integrated along the PV supply chain (Greentech Media, 2007). Box 6-1 provides some background on the history and characteristics of the market for solar PV. BOX 6-1 Evolution of the Market for Solar PV The market for solar PV has evolved from niche, off-grid applications to a wide array of applications that provide power to the grid. For years, the primary market for PV cells and modules was in remote, stand-alone power for communication and navigation systems, cathodic protection, and village power, and in consumer products, such as calculators, watches, and portable lighting products. Recently the grid-connected market has become the prominent use for PV modules and systems. The solar PV market has segments, distinguished by system size, such as residential (<10 kW), small commercial (10 kW to 100 kW), large industrial and public (100 kW to 1 MW), and utility scale (>1 MW). The economics of PV installations is directly related to the size of the installation and the degree of integration for the installation company across the PV supply value chain. Generally, the larger systems with greater degrees of integration into the grid will realize greater cost-reductions through economies of scale. In the United States, a bifurcated market for PV systems has developed, depending on whether the system is installed on a customer’s premises (behind the meter) or as a utility-scale generation resource. Behind-the-meter systems compete by displacing customer-purchased electricity at retail rates, while utility-scale plants must compete against wholesale electricity prices. Thus, behind-the-meter systems can often absorb a higher overall system cost structure. Much of the development of solar has occurred in this behind-the-meter market. Residential systems, one type of behind-the-meter systems, tend to be custom-designed based on roof space, pitch, and orientation. System dealers need to stock a variety of products and components, and manage product inventory; installers incur costs in project permitting and contracting for utility interconnection. Residential system installers have begun to address some of these issues. Some are customizing PV module systems that integrate racking hardware, grounding wires, wiring connections, and connections between panels. These systems can be factory-produced, reducing on-site installation costs. A homeowner will invest the needed capital to pay for the system purchase and installation, with cost recovery occurring over some period of time from displaced electricity savings. Economic payback periods can be quite long, but early- adopter residential investors are less sensitive to overall system economics because of other purchase motivations. 172

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION In another version of the behind-the-meter systems, a commercial, business or government agency might install and run a system itself, or have a system installed through a third-party ownership or solar services model. Under the solar services model, third-party companies install and own a PV system on behalf of a host business or public agency. The system is located behind the meter on a utility customer’s premises. The third-party company acts as technology integrator, project developer, and system operator, and secures the project financing as well. The solar electricity is sold to the host customer at a rate below the prevailing utility retail rate. Businesses and public agencies generally adhere to strict economic payback criteria. For example, businesses have an internal rate of return (IRR) hurdle (often >15 percent) that must be met for any corporate investment to be undertaken. At today’s costs, PV system investments may not meet the IRR hurdle. The success of this model often relies on key factors, including (1) net metering, which allows valuation of displaced grid electricity at the prevailing retail rate, and (2) the ability of the third-party entity to raise capital at rates well below the IRR hurdle of the private companies. Other factors include the availability of federal and state incentives, the existence of a time-of-use utility tariff in which the utility’s high-price rate tiers match well with the solar electricity output, and an existing market for solar renewable energy credits (RECs), the sale of which provides additional value to the solar generation. Workforce Requirements Direct Requirements Another limiting variable to the large scale manufacturing and deployment of new renewable electricity systems is the need for a trained and capable workforce that grows as market demand grows. Educating this workforce requires the development of high quality training infrastructures that include accredited institutions, skill testing, and certification. Table 6-3 shows the direct jobs and economic activity in the renewable electricity industry for 2006 (ASES, 2007). The renewable energy industry in the United States opened 450,000 jobs in 2006 (ASES, 2007). Meeting a renewable energy portfolio standard of 20 percent by 2020 is projected to require an additional 185,000 jobs related to renewable energy (UCS, 2007). However, the renewable energy sector faces a challenge in meeting an increasing demand for educated and skilled workers. In fact, these workforce needs apply across the entire energy sector since it is faced with an aging workforce and a shortage of technically skilled people. Companies developing wind, solar, biomass, and geothermal recoverable resources will require an influx of skilled employees for sales marketing, customer services, and business support services in order to support the wide-scale deployment of these energy sources. Already, the shortage of skilled workers in the solar industry is partially blamed for upward cost pressures (EIA, 2007). A variety of sector specific technical jobs, outlined in Table 6-4, will be drawn upon (Council on Competitiveness, 2007). To gain a better picture of the variety of renewable energy positions, Table 6-5 delineates selected occupations at a typical wind turbine manufacturing plant in Ohio. This table illustrates that the renewable energy sector employs a wide range of people at all levels of skills and education. 173

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION TABLE 6-4 Breakdown of Renewable-Energy-Specific-Positions Wind Solar Biomass Geothermal Chemists and Geologists, Electrical and Electrical, biochemists geochemists, and mechanical engineers mechanical, and geophysicists and technicians chemical engineers and technicians Aeronautical Material scientists Agricultural Hydrologists engineers specialists Construction workers Physicists Microbiologists Hydraulic engineers Meteorologists Construction workers, Electrical, HVAC contractors architects, and mechanical, and builders chemical engineers and technicians SOURCE: Adapted from material in Council on Competitiveness (2007). 174

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION TABLE 6-5 Selected occupations of employees at a 250-person wind turbine manufacturing company in Ohio in 2006 Occupation Employees Earnings Engine and Other Machine Assemblers 31 $36,300 Machinists 27 40,500 Team Assemblers 16 30,100 Computer-Controlled Machine Tool Operators 12 40,600 Mechanical Engineers 10 71,600 First-Line Supervisors/Managers of Production/Operating 10 59,600 Inspectors, Testers, Sorters, Samplers, and Weighers 8 40,400 Lathe and Turning Machine Tool Setters/Operators/Tenders 6 40,000 Drilling and Boring Machine Tool Setters/Operators/Tenders 4 39,800 Welders, Cutters, Solderers, and Brazers 4 39,900 Laborers and Freight, Stock, and Material Movers 4 29,800 Maintenance and Repair Workers 4 44,100 Tool and Die Makers 4 43,600 Grinding/Lapping/Polishing/Buffing Machine Tool Operators 4 34,800 Multiple Machine Tool Setters/Operators/Tenders 4 40,800 Industrial Engineers 3 70,400 Industrial Machinery Mechanics 3 46,000 Engineering Managers 3 108,300 Shipping, Receiving, and Traffic Clerks 3 32,100 General and Operations Managers 3 120,600 Industrial Production Managers 3 93,100 Industrial Truck and Tractor Operators 3 34,200 Purchasing Agents 3 56,200 Cutting/Punching/Press Machine Setters/Operators/Tenders 3 31,400 Production, Planning, and Expediting Clerks 3 45,200 Milling and Planning Machine Setters/Operators/Tenders 3 40,600 Mechanical Drafters 2 39,900 Customer Service Representatives 2 39,100 Bookkeeping, Accounting, and Auditing Clerks 2 35,600 Office Clerks, General 2 29,400 Sales Representatives, Wholesale and Manufacturing 2 55,300 Janitors and Cleaners 2 29,800 Sales Engineers 2 72,500 Accountants and Auditors 2 59,800 Tool Grinders, Filers, and Sharpeners 2 44,000 Executive Secretaries and Administrative Assistants 2 43,200 Mechanical Engineering Technicians 2 50,900 Electricians 2 49,600 Other employees 48 49,700 Employee Total (126 occupations in the industry) 250 $46,400 SOURCE: ASES (2007a). Used with permission of the American Solar Energy Society. Copyright 2007 ASES. 175

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION Indirect Requirements In addition to the basic manufacturing and operation workforce needs, there is an equally pressing need in the related electric utility infrastructure, where the turnover of an aging traditional electric utility employee base is outpacing the supply of skilled replacements. The shortfall may be as high as 10,000 by 2010 (DOE, 2006). According to the Center for Energy Workforce Development, at least half of the electric utilities’ technical workforce, including power line workers, mechanics, installers, repairers, and first and second line supervisors, may retire in five to ten years (CEWD, 2007). These traditional electric utility roles are essential to the large-scale deployment and integration of renewable energy sources. Training and Certification To meet the growing demand for skilled workers, a variety of workforce development strategies are needed (Great Valley Center, 2003). Recent initiatives attempt to address the insufficient supply of skilled workers by instituting renewable energy-specific training, certification, and licensing programs. Some leading examples include: • New York State Energy Research and Development Authority. NYSERDA supports the development of an in-state network of training programs to provide accessible and quality instructional opportunities for those already in the renewable energy trades or those planning on entering the profession. NYSERDA has invested in developing seven accredited solar training centers and continuing education programs across the state through partnerships with community colleges, trade schools, universities and trade unions. (NYSERDA, 2005) • Florida Solar Energy Center. The Center is a state-supported research and training institute in the area of renewable energy, with courses in photovoltaics and energy efficiency programs. In addition, the Center develops curricula for national and international training on renewable energy, in partnership with other organizations, and offers these programs through distance learning. • Green Energy Ohio. A partnership of the Great Lakes Renewable Energy Association and Florida Solar Energy Center, Green Energy Ohio has a 5-day Photovoltaic (PV) Installer Apprentice Program. It is designed for individuals beginning a career as a PV system integrator, combining classroom sessions with field experience to introduce students to distributed generation technologies and interconnection issues, with a focus on solar energy. • Sonoma State University Energy Management and Design. The Energy Management and Design (EMD) Program provides either a B.A. or B.S. Degree in Environmental Studies. It provides management and design training in the application of a wide variety of energy efficiency and renewable energy technologies. All EMD students must complete an internship, which provides experience in a professional setting. The program has several external relationships, including the California Energy Commission, Lawrence Berkeley National Laboratory, Pacific Gas and Electric 176

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION Company, Sacramento Municipal Utility District, California Association of Building Energy Consultants, and the Northern California Solar Energy Association. • Midwest Renewable Energy Association. The MREA hosts a series of educational and hands-on workshops throughout the year, instructed by experienced renewable energy experts in small classroom settings and on-site installation locations. Workshop participants come from varied backgrounds, including homeowners, builders, educators, architects, engineers, and others. Participants can receive Continuing Education Units for attending workshops. • Central Carolina Community College. The college offers a course on introduction to PV system design, related to the properties and installation of solar panels that produce electricity. This course has been approved by the North American Board of Certified Energy Practitioners. The federal government also is increasing its role in training. The Energy Independence and Security Act of 2007 authorizes a Department of Labor energy efficiency and renewable energy worker-training program. This legislation also establishes a grant program within the DOE Office of Solar Energy Technologies to create and strengthen solar-industry workforce training and internship programs for installation, operation, and maintenance of solar-energy devices. To improve the workforce, there is a critical need to develop quality training programs that test and certify skill acquisition and capability. The Interstate Renewable Energy Council recommends criteria necessary for the design and implementation of workforce training programs (Weissman and Laflin, 2006). They include the need for the training institution to offer programs under the auspices of recognized third-party or government accreditation standards and development of curriculum based on industry- approved task analyses. The North American Board of Certified Energy Practitioners, an industry-based, non-profit credentialing organization that assesses competency and certifies solar installers, will be adding categories of certificates over time. RENEWABLE ELECTRICITY INTEGRATION The electric system balances and delivers power generation from a portfolio of resources to power demand centers that vary in scale and location. A modern electric grid is essential for overall reliability. Large-scale integration of renewables into the electricity system may require improved technologies to expand and upgrade the transmission and distribution system capabilities, and changes to utility and grid operations that can occur during system upgrades. This section discusses the potential impacts on utility and grid operations associated with renewable electricity deployment. Other aspects of renewables integration are considered in this report in Chapter 3, which discusses the technologies themselves; Chapter 4, which provides estimates of the costs; and Chapter 7, which discusses scenarios that involve increased deployment of renewables and that include grid capacity needs. System operators seek to ensure that generation and transmission resources meet the on-peak load within the entire control area with sufficient generating reserves and transmission capability to cover contingencies, in order to meet mandatory federal system 177

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION adopt a new technology. Market growth can be illustrated through use of the diffusion curve showing demand for a product increasing as early adopters start building on the experience of innovators. Market mechanisms, such as learning-by-doing and learning- by-using, bring the product to the inflection point on the curve where demand increases rapidly. Prior to the inflection point, the demand for the technology may not be self- sustaining and could benefit from public/private partnerships to share early market risk and provide a feedback mechanism for integrating market experience with research and development activities. In addition, the shape of the diffusion curve varies by the characteristics of the technology and the local market as shown the diffusion curve in Figure 6-10. Commercialization Risk Investment is necessary to move the new technology to the point of commercialization. Similar to the diffusion curve that illustrated the different market participants as demand for the product increases, Figure 6-11 illustrates the relative financial investment necessary to bring a new technology to the point of commercialization. Figure 6-11 depicts three broad stages of development where investment is needed: (1) the technology creation stage, when the public sector focuses its investment; (2) the cash flow valley of death11 stage, after product development but before commercialization, when public sector financing may not be available and there is typically a dearth of private capital; and (3) the early commercialization stage, when a company has an improved position with respect to obtaining private sector investment (Murphy and Edwards, 2003). The risks associated with the introduction and successful deployment of a new technology are directly tied to whether the developers of the technology can successfully navigate through these various stages, especially the stage between technology innovation and commercial introduction. Issues Related to Electricity Rates Several issues related to the basic approach to electricity services rate regulation have a significant impact on the renewable electricity deployment risks. These issues particularly arise in three areas: (1) the treatment of intermittent resources; (2) the development of supporting infrastructure (hardware and policy) for bulk power (transmission); and (3) the development of supporting infrastructure (hardware and policy) for distributed energy resources. Numerous regulatory and policy initiatives have been launched to address these issues in recent years. The most significant risk facing the large scale deployment of renewable electricity in this regard is whether policymakers and regulators will move to address these issues in an orderly, predictable, and sustainable fashion. The cash flow valley of death is where the financial investment required for a new technology may 11 exceed the ability of a new business to raise capital. For clean energy technologies, this occurs during the transition from public sector financing to private sector funding. 192

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION The relationships between rates and market behavior by suppliers and consumers are complex and vary by location; indeed, rate is a term that describes a whole host of tariffs,12 rates, and charges that affect those that interact with the electricity system. A renewable electricity facility, for example, faces a wholesale rate at which it can sell electricity and another rate for sales of capacity. There is one rate for transmission service, another for interconnection, yet another for standby service, and there may be ancillary services charges as well. As delivered to the end-user customers, the final bill for the electricity may include congestion charges, and ultimately will be bundled with distribution, metering, and billing rate elements. Uncertainties about the application and charges in any of such rate elements may slow progress toward greater deployment of renewable electricity. A few examples of where growth in renewable electricity market penetration may conflict with the current rate structure and where regulatory risk associated with rates may be significant include: • The volume-based, average rate per customer class model for consumption favors baseload generation capacity and fails to create incentives for resources like photovoltaics that generate electricity on or near peak. • Net metering schemes that do not assign full retail value to generation occurring behind-the-meter may not encourage distributed generation. • Transmission capacity reservation and shortfall charges that drive high availability for dispatchable resources (such as natural gas turbines) can effectively preclude cost-effective deployment of intermittent resources. • Rate structures driven by efforts to encourage all-requirements loads and customers in order to build demand for capital investments often penalize partial requirements loads coupled with self-generation. Renewed interest in demand-response and interruptible loads may require reexamination of rate-making fundamentals. There is a chicken-and-egg problem associated with rates. Most often in the United States, rates are calculated based on extrapolation from a historical test year of experience, and adjudicated in contested rate cases. While the general constructs of ratemaking are well understood, there are variations in all the jurisdictions with authority to impose them. These jurisdictions are primarily states and the federal government, but also include municipal governments, electric co-operative boards, and multi-state electric reliability and transmission authorities. Because there has been relatively little experience in the United States with large scale deployment of renewable electricity (above the scale where significant impacts are experienced), there is relatively little actual data on which to construct fair and non-discriminatory rates. Any period of expansion in the amount of renewable electricity will therefore be accompanied by risk related to how the rate structure treats renewables. Policy and Regulatory Risk A government approved contract rate. 12 193

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION The relationships among markets to policy and regulation can be contributory, supportive, symbiotic, and parasitic. This is true for the electricity market as well as all sectors of the economy. All participants in the electricity market seem to agree that policy and regulation can have a profound impact on energy markets and that predictability and sustainability are highly valued. Electricity markets operate within a web of interlocking, overlapping, and sometimes conflicting policy prescriptions and legal and regulatory structures.13 The key risks engendered by this pervasive regime relate to the degree to which one can expect that future policies will conform to reasonable expectations. For example, uncertainty surrounding the renewal of federal production tax credit policy for renewables carries a potential impact for the renewables industry in the billions of dollars. Regulation is the tool for implementing policy in the electric industry, even when that implementation involves relaxation of regulation. As the United States Supreme Court has held, when business is “affected with the public interest,” such regulation is proper (Munn v. State of Illinois, 94 US 113 (1876). There are few industries so affected with the public interest as that of electricity. Renewable electricity will always be fundamentally affected by wider regulatory and policy conditions existing in electricity markets for several reasons. First, of course, is the ubiquity of electric service in the United States. Second, the dominant industry model is one based on spreading of costs through franchised service via regulated utilities. Even when some degree of competitive market structure exists as it does in much of the electricity sector today, the industry remains highly regulated. Third, the most significant environmental attributes of electricity are spread broadly as well through energy security and reducing greenhouse gases. Indeed, greenhouse gas emissions are part of a global budget of atmospheric gases. Finally, the technologies and businesses of renewable electricity are young and relatively immature. Development of renewables depends on research and development, as well as special subsidies and manipulation of the existing markets, for renewables to succeed against well-established incumbents that enjoy embedded subsidies of their own. Electricity Sector Regulation Regulators and policymakers in the electricity sector are often uncertain about how to deal with new market entrants, new technologies, and new product and service models. Charged with protecting the general public interest, regulators and policymakers often approach innovation with caution, and on an ad hoc basis. Regulation and policy designed for incumbent industries may not be well suited to emerging technologies and businesses, but efficient alternatives are not often apparent. New market entrants often face risk due to lack of clarity and specificity; newcomers must spend proportionally more time and money to engage with the regulatory systems than well-known incumbents. Large-scale deployment of renewable electricity will add a new dimension to this uncertainty. For example, relatively simple and clear regulatory and management solutions exist for wind penetration rates of 1 percent or 2 percent, but the need for The various incentives for renewable energy are catalogued by the Database of State Incentives for 13 Renewables and Efficiency (DSIRE), available at www.dsireusa.org. 194

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION potentially expensive regulatory changes and ancillary services may occur as system penetration rates reach 10 percent to 20 percent and higher. Moreover, effective response to system-scale issues requires comprehensive reviews and solutions. Regulatory processes, such as integrated resource planning, rate cases, and broad revisions of transmission system pricing regimes, place heavy demands on scarce regulatory resources. Climate Regulation Climate change regulation and policy are emerging in many local and regional jurisdictions around the United States. Many other countries have also implemented climate regulations. Indeed, increasing attention and concern about the potential for global climate change is having impacts on business decision-making and risk evaluation, especially companies operating in the power sector and energy-intensive industries. Renewable energy industries should benefit greatly from comprehensive and effective regulation to reduce or avoid greenhouse gas emissions. Greenhouse gas regulation will likely affect the relative costs of renewable electricity and non-renewable fossil fuel and nuclear power options and spur more rapid technology improvement in renewables. However, there are risks. Greenhouse gas regulation is itself a new thing, and changes and inconsistencies are inevitable. Because this regulation will have a direct impact on the costs and market opportunities for both incumbent and emerging technologies, the degree of orderliness and predictability of changes in regulations constitutes a significant risk factor for large scale deployment of renewables. Lash and Wellington (2007) categorize business risks associated with the public and regulatory climate change concerns as follows: • Regulatory risk. Rates and direct regulation of emissions. • Supply chain risk. Higher component and energy costs as suppliers pass along increasing carbon-related costs to their customers. • Product and technology risk. Ability to identify new market opportunities for climate-friendly products and services. • Litigation risk. Threat of lawsuits against companies that generate significant carbon. • Reputational risk. Public, or consumer, perception on the role of the company as a steward of the environment. • Physical risk. Risk posed by climate change as droughts, floods, and storms become more frequent and more severe. These risks and benefits are summarized in Box 6-4. Deployment of renewable energy technologies can help electricity generators mitigate climate-change-related risks through reduced risk exposure, direct reductions in greenhouse gas emissions, improved ability to take advantage of climate policy incentives, reduced resource use, and improved perception of corporate social responsibility (Pater, 2006). 195

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION BOX 6-4 Risks and Benefits for Renewable Electricity Generation Under Climate Regulation • Risk Management Hedge against fuel-price volatility • Hedge against grid outages • Get ahead in the futures markets • Prepare for regulatory change • Reduce insurance premiums • Reduce future risks of climate change • Emissions Generate emissions reduction credits/offsets • Reduction Reduce fees for emissions • Avoid remediation costs • Policy Initiatives Production tax credit, accelerated depreciation, property tax break • Preferential loan treatment • Renewable portfolio standard • Renewable energy certificates • System benefit funds • Rebates, feed-in tariffs, net metering • Sales-tax exemption • Local R&D incentives • Other financial incentives • Reduced Resource Reduce water use and consumption • Use Reduce energy use • Corporate Social Improve stakeholder relations • Responsibility Satisfy socially responsible investing portfolio criteria • Societal Economic Rural revitalization, jobs, economic development • Benefits. Avoided environmental costs of fuel extraction/transport • Avoided costs of transmission and distribution infrastructure expansion Environmental Policy As discussed in Chapter 5, renewable electricity deployment is particularly site- specific, whether for resource availability or access to infrastructure. The permitting process is intended to consider the local impacts on the land, water, and air that occur during the installation and operation of these technologies. As a result, local, state and national governmental policies and regulations affecting the siting of generation and associated facilities will have a major impact on renewable energy deployment. The range of local, state and national regulations confronting development also grows, and the risk of variability and inconsistency likewise increases as the scale of renewable energy deployment grows. 196

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION FINDINGS Shown in bold below are the most critical elements of the panel’s findings, based on its examination of issues related to the deployment of renewable electricity into the U.S. electricity supply. Policy, technology, and capital are all critical for the deployment of renewable electricity. In addition to enhanced technological capabilities, adequate manufacturing capacity, predictable policy conditions, acceptable financial risks, and access to capital are all needed to greatly accelerate the deployment of renewable electricity. Improvements in the relative position of renewable electricity will require consistent and long-term commitments from policy makers and the public. Investments and market-facing research that focuses on market needs as opposed to technology needs are also required to enable business growth and market transformations. Successful technology deployment in emerging energy sectors such as renewable electricity depends on sustained government policies, both at the project and program level, and continued progress requires stable and orderly government participation. Uncertainty created when policies cycle on and off, as has been the case with the federal production tax credit, can hamper the development of new projects and reduce the number of market participants. Significant increases in renewable electricity generation will also be contingent on concomitant improvements in several areas, including the size and training of the workforce; the capabilities of the transmission and distribution grids; and the framework and regulations under which the systems are operated. As with other energy resources, the material deployment of renewable electricity will necessitate large and ongoing infusions of capital. However, renewable energy requires a greater allocation of capital than the conventional fossil-based energy technologies to manufacturing and infrastructure requirements. Integration of the intermittent characteristics of wind and solar power into the electricity system is critical for large-scale deployment of renewable electricity. Advanced storage technologies will play an important role in supporting the widespread deployment of intermittent renewable electric power above approximately 20 percent of electricity generation, although electricity storage is not necessary below 20 percent. Storage tied to renewable resources has three distinct purposes: (1) to increase the flexibility of the resources in providing power when the sun is not shining or the wind is not blowing, (2) to allow the use of energy on peak when its value is greatest, and (3) to facilitate increased use of the transmission line(s) that connect the resource to the grid. The last is particularly relevant if the resource is located far from the load centers or if the system output does not match peak load times well, as is often the case with wind power. However, wind power’s development is occurring long before widespread storage will be economical. Although storage is not required for continued expansion of wind power, the inability to maximize the use of transmission corridors built to move wind resources to load centers represents an inefficient deployment of resources. Several parties are currently exploring the co-location of natural-gas-fired generation and other types of electricity generation with wind power generation to bridge this gap between storage technology and asset utilization. The co- siting of conventional dispatchable generation sources (such as natural-gas-fired 197

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION combustion turbines or combined cycle plants) with renewable resources could serve as an interim mechanism to increase the value of renewable electric power until advanced storage technologies are technically feasible and economically attractive. The location of such natural gas fired generation could be at, or near the wind resource, or at an appropriate site within the control area. Another possibility is the co-siting of two (or more) renewable resources, such as wind and solar resources, which might on average interact synergistically with respect to their temporal patterns of power generation and needs for transmission capacity. Finally, it is important to note that the deployment needs and impacts from renewable electricity deployment are not evenly distributed regionally. Development of solar and wind power resources has been growing at an average annual rate of 20 percent and higher over the past decade. Overall electricity demand is forecasted to continue to grow at just under 1 percent annually until 2030, with the southeastern and southwestern regions of the United States expected to see most of this growth. Although some of this growth may correspond to areas where renewable resources are available, some of it will not, indicating the possible need for increases in electricity transmission capacity. REFERENCES Ancona, D., and J. McVeigh. 2001. Wind Turbine⎯Materials and Manufacturing Fact Sheet, Princeton Energy Resources International. Prepared for Office of Industrial Technologies, U.S. Department of Energy. Washington, D.C. Archer, C.L., and M.Z. Jacobson. 2007. Supplying baseload power and reducing transmission requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology 46:1701-1717. ASES (American Solar Energy Society). 2007. Renewable Energy and Energy Efficiency: Economic Drivers for the 21st Century. R. Bezdek, principal investigator, Management Information Services, Inc. ASES, Washington, D.C. AWEA (American Wind Energy Association). 2008. Wind Power Outlook 2008. Washington, D.C. Bierden, P. 2007. The Process of Developing Wind Power Generators. Presentation at the Second Meeting of the Panel on Electricity from Renewable Resources. December 6, 2008. Washington, D.C. Black and Veatch. 2008. Renewable Energy Transmission Initiative RETI Phase 1B⎯Resource Report. RETI-1000-2008-003-F. Prepared for RETI Stakeholder Steering Committee, Renewable Energy Transmission Initiative (RETI), Sacramento, Calif. Bowen, J.L., and C.M. Christensen. 1995. Disruptive technologies, catching the wave. Harvard Business Review 73(1):43-53. Bradford, T. 2008. Solar Energy Market Update 2008⎯PV and CSP. Presentation at Solar Market Outlook: A Day of Data, February 19, 2008, New York, N.Y. Brown, M., J. Chandler, M.V. Lapsa, and B.K. Sovacol. 2007. Carbon Lock-in: Barriers to Deploying Climate Change Mitigation Technologies. ORNL/TM-2007/124. Oak Ridge National Laboratory, Oak Ridge, Tenn. November. 198

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION CALISO (California Independent System Operator Corporation). 2007. Annual Report. Folsom, Calif. CEWD (Center for Energy Workforce Development). 2007. An Action Plan for Workforce Development. Washington, D.C. Cornelius, C. 2007. DOE Solar Energy Technologies Program. Presentation at the First Meeting of the Panel on Electricity from Renewables, September 18, 2007, Washington, D.C. Council on Competitiveness. 2007. Energy Security, Innovation, and Sustainability. Washington, D.C. Davis, R.E., and W. Quach. 2007. Intermittency Analysis Project: Appendix A. Intermittency Impacts of Wind and Solar Resources on Transmission Reliability. CEC-500-2007-081-APA. PIER Renewable Energy Technologies Program. California Energy Commission, Sacramento, Calif. DOE (Department of Energy). 2006. Workforce Trends in the Electric Utility Industry. Prepared for the United States Congress. Washington, D.C. DOE. 2008a. 20 Percent Wind Energy by 2030⎯Increasing Wind Energy’s Contribution to U.S. Electricity Supply. DOE, Energy Efficiency and Renewable Energy, Washington, D.C. DOE. 2008b. Annual Report on U.S. Wind Power Installation, Cost, and Performance Trends. DOE, Energy Efficiency and Renewable Energy, Washington, D.C. EER (Emerging Energy Research). 2007. U.S. Wind Power Markets and Strategies, 2007-2015. Cambridge, Mass. EIA (Energy Information Agency). 2007. Solar Thermal and Photovoltaic Collector Manufacturing Activities, Renewable Energy Annual 2006. Washington, D.C. EnerNex. 2008. Detailed Analysis of 20% Wind Penetration. Addendum to Wind Integration Study for Public Service of Colorado. Prepared by EnerNex Corporation for Xcel Energy, Denver, Colo. December 1. Feltrin, A., and A. Freundlich. 2008. Material considerations for terawatt level of deployment of photovoltaics. Renewable Energy 33:180-185. GE Energy. 2005. The Effects of Integrating Wind Power on Transmission System Planning. Prepared for the New York State Energy Research and Development Authority, New York, N.Y. Gourville, J.T., and E. Sellers. 2006. Eager sellers and Stony buyers: Understanding the psychology of new-product adoption. Harvard Business Review 84(6):98-106. Great Valley Center. 2003. Workforce Implications in Renewable Energy. Modesto, Calif. Greentech Media. 2007. Silicon Shortages Slows Solar Industry⎯The Green Year in Review. Greentech Media, Cambridge, Mass. December 31. Greentech Media. 2008. First Solar Posts Blockbuster 2Q. Greentech Media, Cambridge, Mass. July 30. Hawkins, D., and M. Rothleder. 2006. Evolving role of wind forecasting in market operation. Presented at the CAISO in IEEE Power Systems Conference and Exposition, Atlanta, Ga. Available at http://ieeexplore.ieee.org. Holttinen, H., B. Lemström, P. Meibom, H. Bindner, A. Orths, F. van Hulle, C. Ensslin, A. Tiedemann, L. Hofmann, W. Winter, A. Tuohy, M. O’Malley, P. Smith, J. Pierik, J.O. Tande, A. Estanqueiro, J. Ricardo, E. Gomez, L. Söder, G. Strbac, A. 199

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION Shakoor, J.C. Smith, B. Parsons, M. Milligan, and Y. Wan. 2007. Design and operation of power systems with large amounts of wind power: State-of-the-art report. VTT Working Papers 82. VTT Technical Research Centre of Finland, Finland. October. Available at http://www.vtt.fi/inf/pdf/workingpapers/2007/W82.pdf. IEA (International Energy Agency). 2008. ETP 2008: Technology Learning and Deployment⎯A Workshop in the Framework of the G8 Dialogue on Climate Change, Clean Energy and Sustainable Development⎯Final Version 29, June 2008. Paris, France. Jamasb, T. 2006. Technical change theory and learning curves: Patterns of progress in energy technologies. Cambridge Working Papers in Economics, University of Cambridge, Cambridge, U.K. March 20, 2006. Available at http://www.dspace.cam.ac.uk/handle/1810/131682. Lash, J., and F. Wellington. 2007. Competitive advantage on a warming planet. Harvard Business Review 85(3):95-102. Lew, D. 2008. Western Wind and Solar Integration Study. Presentation at Stakeholders Meeting. August 14, 2008, Denver, Colo. Mathur, A., A.P. Chikkatur, and A.D. Sagar. 2007. Past as prologue: An innovation- diffusion approach to additionality. Climate Policy 7:230-239. MPUC (Minnesota Public Utilities Commission). 2006. Final Report: 2006 Minnesota Wind Integration Study. Volume 1. Saint Paul, Minn. Murphy, L.M., and P.L. Edwards. 2003. Bridging the Valley of Death: Transitioning from Public to Priate Sector Financing. NREL/MP-720-34036. National Renewable Energy Laboratory, Golden, Colo. NAS-NAE-NRC (National Academy of Sciences-National Academy of Engineering- National Research Council). 2009. America’s Energy Future: Technology and Transformation. The National Academies Press, Washington, D.C., in preparation. Navigant Consulting. 2008. Photovoltaic Shipments & Competitive Analysis 2007/2008. Report # NPS-Supply3. Navigant Consulting, Washington, D.C. NERC (North American Electric Reliability Corporation). 2009. Accommodating High Levels of Variable Generation: Special Report. Princeton, N.J. Newsweek. 2008. Fareed Zakaria. PayPal’s cofounder hopes to produce a practical $30,000 all-electric car in four years. NPCC (Northwest Power and Conservation Council). 2007. The Northwest Wind Integration Action Plan. Portland, Ore. Available at http://www.nwcouncil.org/energy/wind/library/2007-1.pdf. NRC (National Research Council). 2001. Energy Research at DOE: Was It Worth It? Energy Efficiency and Fossil Energy Research 1978 to 2000. The National Academies Press, Washington, D.C. NYSERDA (New York State Energy Research and Development Authority). 2005. The Effects of Integrating Wind Power on Transmission System Planning, Reliability, and Operations: Report on Phase 2—System Performance Evaluation. Albany, N.Y. March. 200

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PREPUBLICATION COPY—SUBJECT TO FURTHER EDITORIAL CORRECTION OECD (Organisation for Economic Co-Operation and Development)/IEA. 2003. Creating Markets for Energy Technologies. OECD Publishing, Paris, France. Available at http://www.iea.org/textbase/nppdf/free/2000/creating_markets2003.pdf. Parson, B., M. Milligan, J.C. Smith, E. DeMeo, B. Oakleaf, K. Wolf, M. Schuerger, R. Zavadil, M. Ahlstrom, and D.Y. Nakafuji. 2006. Grid impacts of wind power variability: Recent assessments from a variety of utilities in the United States. European Wind Energy Conference Paper. NREL/CP 500-39955. DOE, National Renewable Energy Laboratory, Washington, D.C. July. Patel, S. 2009. PV sales in the U.S. soar as solar panel prices plummet. POWER Magazine. March 1. Pater, J.E. 2006. Framework for Evaluating the Total Value Proposition of Clean Energy Technologies. Technical Report NREL/TP-620-38597. DOE, National Renewable Energy Laboratory, Washington, D.C. February. Pernick, R., and C. Wilder. 2008. Utility Solar Assessment (USA) Study: Reaching Ten Percent by 2025. Clean Edge, Inc., Washington, D.C. Prometheus Institute: For Sustainable Development. 2007. U.S. Solar Industry: The Year in Review 2006. SEIA/Prometheus Institute Joint Report. Cambridge, Mass. Sharman, H. 2005. Why Wind Power Works for Denmark. Civil Engineering 158:66-72. Sheehan, G., and S. Hetznecker. 2008. Utility scale solar power. Next Generation Power & Energy Issue 5, October. Sherwood, L. 2007. U.S. Market Trends: Solar and Distributed Wind. Presented at Interstate Renewable Energy Council, September 24, 2007, Long Beach, Calif. Stern, G. 2008. Lassoing panhandle wind: Oilman plans huge complex. EnergyBiz Magazine, January/February, pp.12-13. Sterzinger, G., and M. Svrcek. 2004. Wind Turbine Development: Location of Manufacturing Activity. Renewable Energy Policy Project,Washington, D.C. UCS (Union of Concerned Scientists). 2007. Cashing in on Clean Energy National Analysis. Cambridge, Mass. Wan, Y.H. 2004. Wind Power Plant Behaviors: Analyses of Long-Term Wind Power Data. NREL Technical Report NREL/TP-500-36551. National Renewable Energy Laboratory, Golden, Colo. Weissman, J., and K. Laflin. 2006. Trends in practitioner training for the renewable energy trades. Solar 2006: Renewable Energy⎯Key to Climate Recovery. Proceedings of 35th ASES Annual Conference held on July 9-13, 2006, in Denver, Colo. American Solar Energy Society, Boulder, Colo. Wiley, L. 2007. Utility Scale Wind Turbine Manufacturing Requirements. Presented at WPA/NWCC Wind Energy & Economic Development Forum, April 24, 2007, East Lansing, Mich. 201

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