Synapse Releases 111(d) Cost Estimate Tool for States

July 1, 2014

Synapse has developed a tool to estimate states’ electric-sector costs and benefits of Section 111(d) of the Clean Air Act. The Excel-based tool, now available on the Synapse website, is based on EPA’s national estimates of implementing its four “building blocks” (learn more about the 111(d) building blocks by watching the Synapse webinar “Get to Know 111(d): Components and Implications of the Draft Rule for States” here).

In the proposed 111(d) rule, EPA presents estimates equivalent to a national net benefit of $13 billion to the electric sector in 2030, not including additional costs to energy efficiency program participants or climate-damage reduction and health benefits. The agency does not provide state-level compliance costs or benefits. We estimate state costs to implement the EPA’s building blocks by assuming EPA’s average national costs by measure and using the avoided cost of energy to calibrate the results. (Importantly, 111(d) has flexibility built in allowing states to design their own lower-cost compliance strategies.)

The tool was developed as part of Synapse’s ongoing work supporting clients in analyzing and drafting comments on the EPA rule. The example below presents Texas’ estimated electric-sector costs and benefits of 111(d) compliance for 2030. These results reflect Texas complying singly—EPA asserts that states complying jointly will have lower costs (and greater net benefits). The tool is free and easy to use; if you have questions about generating results for your state, please contact Elizabeth A. Stanton at or Pat Knight at

Texas’ estimated electric-sector net benefits for 2030 are $884 million.