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An Analysis on Louisville, Kentucky’s Sustainability Initiatives with
Recommendations for Improvement
Jason McConnell
Johns Hopkins SAIS MA Energy Resources Environment
27 June 2016
Summary of Recommendations (in the order observed in the report)
1) The Office of Sustainability should release its 2014 and 2015 progress reports or release a
combined report with up-to-date information as soon as possible. Doing so would give assurance
to the public and other stakeholders that the government is following through on its promise to
keep itself accountable and transparent. During any major city-wide transition, public trust in
political institutions affects community buy-in for future projects.
2) All Louisville Metro Government departments and the Office of Sustainability in particular
should upload more datasets related to energy, environment, sustainability or climate change as
they become ready for public viewing. LMG can use the cities of Gainesville, FL and Los
Angeles, CA as models of websites with plenty of accurate and transparent data.3
3) All four partners of the PGC (Partnership for a Green City) should adopt the University of
Louisville’s more stringent sustainability goal of becoming carbon neutral by 2050. This is within
reach politically and it would reduce city GHG emissions by about 5%, a significant reduction.
This would also send a clear signal to the private sector and community that the city is serious
about sustainability. Until the other three partners can commit to such a goal, they should release
yearly GHG inventories.
4) The Kentucky PSC (Public Service Commission) should give more consideration to any LG&E
plans to build CCNG(Combined Cycle NaturalGas) power plants. Replacing coal generation
with CCNGwould reduce GHG emissions compared to traditional coal plant output and reduce
energy consumption. When approving new CCNGplants, the rates should be set at a level that is
both viable for the utility to make a reasonable profit but also closer to the national rate average
so as to further reduce energy consumption waste at the margin.
5) The Kentucky PSC should mandate a study to evaluate the value of solar in Kentucky, similar to
how Maine’s PUC mandated their study.1 With this information, the PSC will be better equipped
to judge cases that involve both solar capacity and competitors to solar.
6) The Kentucky State Legislature should adopt a Renewable Portfolio Standard for the state that
mandates a certain percentage of renewable energy either be generated or bought.
7) The Kentucky State Legislature should re-examine the state’s smaller-scale energy efficiency and
renewable energy policies to see if any are in need of adjustment that would attract more
investment from consumers on the residential, commercial and industrial level. These policies
include state tax rebates on energy efficiency improvements, solar PV purchases and installations
and Renewable Energy Credits. The need to re-examine is particularly true for Kentucky’s net
metering policy whose 30 kW limit is too low to incentivize utility customers to make a solar PV
investment.
Scope of Report
Louisville, Kentucky on the whole has made progress towards long-term resilience by mitigating
against the effects of climate change and expanding renewable energy capacity, but there is room for
improvement. Though every aspect of sustainability on a municipal level is worth expounding upon, the
1
http://www.maine.gov/mpuc/electricity/elect_generation/documents/MainePUCVOS-ExecutiveSummary.pdf

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scope of this report limits itself to analyzing Louisville’s sustainability efforts in the areas of (1)
Government accountability and transparency,(2) Energy efficiency for public buildings and (3) Energy
diversification with respect to Kentucky’s transition from coal to natural gas and state-wide policy
implementation for solar capacity expansion.
Government Accountability and Transparency
Mayor Fischer made good on his word to improve Louisville’s sustainability outlook when the
Office of Sustainability issued its first blueprint for action in March 2013. The plan emphasized
accountability, transparency and outlined specific goals in severalcategories which impressed upon the
reader that the city was serious about making structural policy reform. The plan even included a
community section detailing how residents can get involved and how these changes will impact the
community from the bottom-up. Later,the Office released a 2013 follow-up report in June 2014 and
either commented on current goals or updated them as new information came to light. However,as of this
writing the Office has yet to release any further progress reports. Not updating the citizenry of the city’s
progress threaten the assurances of accountability and transparency that earlier reports emphasized.
How easily citizens can access information also plays a major role in determining the
sustainability of any program. Though the original Sustainability Plan and subsequent progress report are
available online, the scope of the projects that the reports present are difficult to comprehend. For
example, it is unclear just how much energy the city could save if some or all of the Office’s goals were
implemented. This makes the efficacy or importance of each program unclear to the reader. Taxpayers
may not understand where their tax dollars are going or why they are going to one program over another.
Another troubling aspect is the lack of ease for corroborating information from the reports with
data outside the reports. Sources are often not cited which makes research to corroborate any findings
with outside material either difficult or impossible. For instance, though the EPA has data on Jefferson
County energy consumption per capita, there is no data readily available that showcases Jefferson County
total energy production. As the major energy producer for the municipality, LG&E presumably has this
information but it is not available to the public. Having this information would give the interested
shareholders a better idea of the city’s energy consumption trends.
This and other similar information can be put on LMG’s Open Data website.2
The Office of
Sustainability is currently working with the Mayor’s Office on an Urban Heat Island initiative and has
one dataset outlining number of trees planted, green roofs, grass planted among other indicators for each
county. However,with regards to energy, sustainability or climate change, only this one dataset is
available. The Open Data website should be listed more prominently on LMG’s website and more data
should be made available to the public as it is acquired. Two city websites, one from Gainesville, FL and
the other Los Angeles, CA are good examples of models that Louisville can and should strive to meet
with respect to transparency and accountability.3
Public Building Energy Efficiency
The Office of Sustainability has implemented several new energy efficiency programs or
expanded on existing ones to achieve their goal of reducing energy consumption per capita 25% by 2025
and reduce energy consumption in public office buildings 30% by 2018 (based on 2006 indicators). As of
this writing, examples include: 86 new Energy Star and 25 new LEED (Leadership in Energy and
Environmental Design) buildings; $3.6 million annually saved through the monitoring of ESPCs (Energy
Service Performance Contracts) for all four partners in the PGC (Partnership for a Green City); and new
2
http://data.louisvilleky.gov/
3
http://data.cityofgainesville.org/ andhttps://performance.lacity.org/

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green and white roofing, some of which is funded by the MSD (Metropolitan Sewer District) to help
alleviate combined sewer overflow.
These small and mid-scale adjustments go a long way where little progress existed before, but
there is still room for improving the rate of energy efficiency for public buildings. Though the city will
most likely reach its 2018 and 2025 goals, it is questionable how much of an impact this will have on
reducing or stabilizing GHG emissions in a significant way. According to a 2006 GHG inventory report
written by Trinity Consultants on behalf of LMG, the amount of GHG emissions that LMG, UofL and
JCPS accounted for was 911,188 metric tons or roughly 4.7% of total county emissions.4
Though JCTC
was not yet a PGC partner when the inventory was conducted, their GHG footprint is the smallest of the
four since they have the least amount of buildings to monitor. But a 4.7% carbon total carbon footprint for
public buildings means that even if every publicly-owned building went carbon neutral (assuming the city
owns roughly the same number of buildings in 2006 as it does today), it would only translate to a
reduction in GHG emissions of around 5%.
This assumes all four partners have plans to reduce their GHG emissions to zero, however, only
UofL has such a plan to become carbon neutral by 2050. UofL can offer a model for leadership that the
other three partners can follow or replicate as best they can given their differing GHG emissions
inventories. For instance, UofL has regularly released GHG inventory reports and other data related to its
2050 carbon neutral goal which increases accountability to itself and transparency to its stakeholders. And
the other partners may be joining UofL soon; according to Brent Fryrear who is the PGC Director, there is
talk of JCTC preparing their own GHG inventory.
Energy Diversification: Coal to Natural Gas
Beyond reducing the carbon footprint of publicly-owned buildings is the effect power plants have
on Louisville’s air, water and land. Power plants are,unsurprisingly, the biggest emitter of GHGs in
Kentucky according to the EPA. Louisville's public energy utility, LG&E (Louisville Gas and Electric),
generated 97% of its net kilowatt energy in 2012 using coal.5
This overreliance on one source of energy,
especially a GHG-emitting fossil fuel, reveals the need for a more diverse energy portfolio for the state.
Recognizing the need to shift away from rising coal costs and come back into EPA air quality
compliance6
, LG&E transformed its Cane Run power plant to a Combined Cycle Natural Gas (CCNG)
plant, the first of its kind in the state. This one 650 MW plant nearly replaces the combined 800 MWs of
all of LG&E's coal-powered plants and will generate 14% more energy with "50% less particulates, 99%
less sulfur dioxide and 82% less nitrogen oxides".7
As coal becomes more expensive, LG&E is looking at transitioning their PC (Pulverized Coal)
plants to CCNG (Combined Cycle NaturalGas) for the long-term. But one potential barrier to moving
away from coal lies with the KY Public Service Commission (PSC) whose priority is in keeping energy
prices as low as possible in the short-term.8
Beyond keeping customer costs low, the PSC must also consider the environmental impacts of
their decisions. Kentucky is consuming energy at higher-than-average rates mainly because energy prices
are lower than the national average which partly explains Kentucky’s higher emissions rates. One way to
counter this trend is to increase energy rates to be closer to the national average. A rate increase,though
politically difficult, would reduce energy consumption at the margin and help shift energy markets away
from coal and into other alternative sources such as natural gas and renewables by making them more
cost-competitive. Natural gas is being produced, consumed, exported and imported at greater levels since
4
"Greenhouse Gas Emissions InventoryReport." TrinityConsultants, Nov.2008. Web. 21Nov. 2015.
5
"Louisville MetroSustainabilityPlan." Office of Sustainability. Mar. 2013. Web. 10Nov. 2015.
6
"CommonlyAskedQuestions – LG&E Customers." LG&E-KU. 2015.Web. 20Nov. 2015.
7
Bruggers, James. "Sixty Years of Coal BurningEnds at LG&E Plant." TheCourier-Journal.7 July 2015.Web. 06Dec. 2015.
8
Fryrear, Brent. Telephoneinterview. 12Nov.2015.

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2009 according to EIA data sets,so if building more CCNGcapacity is the trend for Kentucky then the
state can benefit from reduced GHGs and other particulates and energy efficiency. A rate increase as new
CCNGplants come into operation would also cause consumers to shift habits towards greater energy
conservation without hurting economic or personal wellbeing.
Energy Diversification: Solar
As much as CCNG will improve Kentucky and Louisville’s energy and environment outlooks,
any plan to improve sustainability and climate change mitigation must include renewable energy capacity
expansion. Such is the case for Louisville, though it will be a relatively difficult challenge to meet for
both the city and for Kentucky for many reasons. Firstly, comparing renewable energy and traditional
energy rates is complicated both by predictions of how quickly renewable capacity costs will decrease
and current political and economic barriers. In this respect,Kentucky is at a loss as it has both a higher-
than-average residential solar PV (Photovoltaic) LCOE (Levelized Cost of Electricity)9
and lower-than-
average national energy rates (marked by cheap energy alternatives – coal and natural gas). If that were
not enough, Kentucky’s energy policies are arguably not forward-thinking compared to the energy
policies of states like California and even Maine, both of whom are actively conducting research on the
true value of solar for their regions and incorporating it into their grids. Though Kentucky has wind,
biomass and other smaller sources of renewable energy potential, the following assessment will focus
exclusively on solar capacity potential as solar PV costs have decreased the most10
in the past decade.
The best place to begin an assessment for the potential of solar in Kentucky is Lazard’s LCOE
analysis, comparing a range of different but relevant energy source types for the state. CCNG, residential
and utility-scale solar and wind can provide such a range. The 2015 model conclude that CCNG is $52-
$78/MWh, Solar Rooftop Residential PV is $184-$300/MWh, Solar PV Community is $78-$136/MWh
and Wind is $32-$77/MWh.11
Based on these numbers alone, one might be inclined to favor an energy
portfolio of natural gas with some wind and utility solar. There is some truth to this, however Lazard does
not take into account (1) geographic location of solar intensity, (2) the rate of decreasing costs for solar
nor (3) the negative or positive externalities of the energy source. Adjusting expectations with these
factors in mind significantly changes Kentucky’s and Louisville’s solar prospects for the better.
Firstly, location: Kentucky and other Midwestern states simply do not receive as much solar
radiation as do states in the western and southwestern regions like California and Arizona. Research from
the NREL indicates Kentucky has some of the weakest Concentrated Solar Power (CSP) potential in the
country, 4.5 to 4.0 kWh per meter squared per day compared to Arizona’s more than 7.5 kWh per meter
squared per day.12
This makes sense because Kentucky’s geography is not well-suited to host the amount
of large plots of land with high solar radiation that CSP technology requires to be cost competitive. So
why should the state focus on solar? Because Kentucky’s potential for energy production via solar PV
ranks much higher than CSP, about average with the nation at 4.5 to 5.0 kWh per meter squared per day.13
Knowing this, it becomes more obvious that Kentucky’s path for solar lies not so much with CSP but with
a combination of residential-level and utility-scale solar PV installation.14
The rate at which costs are coming down for solar PV complements this finding. The costs for
producing solar PVs have dropped 70% since 2009 thanks to economies of scale and better installation
practices. In fact, the latest numbers indicate that utility-scale solar is now at $0.05/kWh on average in the
US.15
Grid parity – the equilibrium of the cost to produce electricity in and out of the grid – is spreading
9
http://www.usnews.com/news/articles/2016-03-31/when-will-rooftop-solar-be-cheaper-than-the-grid
10
Comparedtowindtechnologycosts
11
https://www.lazard.com/media/2390/lazards-levelized-cost-of-energy-analysis-90.pdf
12
http://www.nrel.gov/gis/images/eere_csp/national_concentrating_solar_2012-01.jpg
13
http://www.nrel.gov/gis/images/eere_pv/national_photovoltaic_2012-01.jpg
14
Alongwith the ability to purchase renewable energyoutside the state if needbe
15
http://newscenter.lbl.gov/2015/09/30/price-of-solar-energy-in-the-united-states-has-fallen-to-5%C2%A2kwh-on-average/

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state-by-state as the costs for solar PV continue to decrease and the costs associated with fossil fuel-based
energy sources continue to increase. Federalprograms such as the Department of Energy’s SunShot
Initiative, whose goal is to reduce residential solar PV system installation to $1.50/Watt, as well as cheap
PVs from China and better installation practices have contributed to lowering costs. In short, even states
like Kentucky are getting closer to achieving grid parity if they haven’t achieved it already.
Finally, more attention is being paid to assess the true cost of energy by various state PUCs and
private energy analysts. Though these valuations vary across geography and can be flawed with the same
subjective analysis that might accompany any Life Cycle Analysis, these valuations do have many of the
same indicators in common, ones such as the avoided costs associated with coal ash clean up, building
additional pipeline for natural gas transportation or the costs for air, water and land pollution cleanup, just
to name a few. It will be up to government agencies like Kentucky’s PSC to determine which indicators
should be factored into the value of solar (when that day comes),but these indicators all point to the same
conclusion: that the price associated with non-renewable energy does not incorporate enough negative
externalities and that renewable pricing does not incorporate enough positive externalities. With this in
mind, the Lazard analyses, while helpful in providing a rough comparison of the lifecycle costs for
various energy sources, actually overvalue non-renewables and undervalue renewables.
Kentucky Solar Policies
There is one policy above all others that the KY state legislature can and should pass now, one
that will send a strong enough signal that the state is serious about transitioning to renewable energy and
one that will provide the strongest energy policy framework to propel Kentucky forward. This policy
framework is the Renewable Portfolio Standard. Kentucky should adopt a Renewable Portfolio Standard
mandating a certain percentage of renewable energy that KY utilities must either generate themselves or
purchase from renewable energy generators. A RPS of 10% would not be too ambitious as about 4% of
KY’s energy output already comes from renewable energy (mostly hydroelectric power), however a
graduated RPS to 20% would send a strong enough message to energy stakeholders by shifting major
utilities’ business models towards renewable energy purchases while bringing in new renewable energy
generators in-state.
Kentucky’s state legislature has already shown that it is capable of participating in the transition
to renewable energy. In 2015, the KY legislative body passed and the governor signed into law
Kentucky’s first PACE (Property Assessed Clean Energy) program which allows residential and
commercial interest to purchase energy efficiency and renewable energy technology as a way to improve
the value of the property and whose loans will be paid over the long-term in increased property taxes.
This innovative financial tool has already seen success in 28 other states. All combined, the value of all
PACE-loans exceeds $1 billion16
which is appropriately-large in scale as a climate change adaptation tool.
But perhaps the most remarkable aspect of the program is the bipartisan support in the KY House and
Senate the bill received by both business advocates on the political right and environmental advocates on
the political left. Though it took two years and pressure from regional entities like the Greater Cincinnati
Energy Alliance to become law, KY’s PACE program is evidence that the state political body is capable
of contributing to Kentucky’s and Louisville’s sustainability initiatives and should not be overlooked.
And despite Kentucky’s lack of an RPS,there are other forces increasing the pressure on
business-as-usual. The goal of the Louisville Sustainability Council’s Solar Over Louisville program is to
install an additional 2 MW of solar capacity by the end of 2016, a small but burgeoning amount that will
only grow over time. The program has Mayor Greg Fischer’s public support who has spoken about the
importance for sustainability to become acceptable in the mainstream and of the importance of
sustainability as an economic driver for the city.17
Local media like 89.3 WFPL and Leo have been
16
http://blogs.edf.org/energyexchange/2015/05/07/kentucky-adopts-innovative-pace-clean-energy-financing-tool/
17
http://wfpl.org/louisville-launches-solar-energy-advocacy-education-initiative/

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covering Louisville’s energy efficiency and renewable energy progress, helping to spread awareness to
residents in Louisville. Lastly, the Office of Sustainability and Mayor’s Urban Heat Island initiative put a
statewide and national spotlight on a national issue that is also uniquely problematic for Louisville while
raising awareness of sustainability in general.
And even without an RPS, Kentucky does have a mix of smaller-scale energy efficiency and
renewable energy policies that Louisvillians can take advantage of, though these policies should be
reexamined and updated in recognition of today’s growing appetite for renewable energy. Currently, the
state allows utility customers to participate in Renewable Energy Credits programs allowing them to
purchase electricity generated from renewable sources even outside the state. Energy efficiency
improvements for insulation, water heat pumps and the like are available on the residential and
commercial level. The state even has a solar PV rebate of $3 per Watt18
which is actually higher than
California’s rebate,the highest option available for Californian residents being $2.50 per Watt.19
However,one “low-hanging fruit” policy that could be amended relatively easily is Kentucky’s net
metering policy. The policy does allow customers to gain refunds for energy put back into the grid for
their solar systems, but only up to 30 kW. Furthermore, even though commercial entities can apply to
become a Qualifying Facility, the process is too cumbersome. Raising the Watt limit would remove this
barrier and incentivize utility customers to purchase solar PV arrays.
Transmission Line Expansion, Distributed Energy Resources and the Clean Power Plan
It should be noted that this research does not take into account the following nascent forces or
trends in the US energy market. The first is the potential for Kentucky to receive electricity via high-
voltage transmission lines from other regions of the country. At this time there is still not much appetite
for such a large-scale venture anywhere in the country mostly due to the lack of a state or federal-level
infrastructure program and the NIMBY (Not In My Back Yard) effect. As a result,the costs associated
with acquiring contracts for land prove too cumbersome for project managers and investors to feel
comfortable moving forward with any large-scale transmission line construction. This could change as
more attention is paid to states like Texas who have succeeded where other states failed by buying out
community properties in aggregate without inspiring local ire.
At the moment, the focus within the US is on locally-sourced renewable energy generation and
Distributed Energy Resources including storage capacity to help mitigate the highs and lows of energy
demand. Storage capacity cost reductions are making the technology attractive for rural areas where
central grids are farther in distance, the kind of rural areas Kentucky has in abundance. Thus, rural storage
capacity is something that could be worth Kentucky’s though not necessarily Louisville’s attention.
Finally, though the Clean Power Plan is a trending topic as of late, the effects of the Obama
Administration’s overarching energy plan cannot be reliably forecasted because the plan’s legal
precedence is in question. Still, if the EPA is correct that the court, when it decides to rule, will rule in the
plan’s favor, it becomes easy to envision Kentucky implementing natural gas capacity and reducing coal
capacity at an even faster rate. The EIA 2016 Energy Outlook recently released also states that if the CPP
is implemented in the near and far-term that renewable energy will outpace coal capacity by 2030, though
it is unclear how what a future Kentucky energy portfolio might look like under such a scenario.
18
http://energy.ky.gov/Programs/documents/HB2TaxCreditsTableSummary.pdf
19
http://www.gosolarcalifornia.ca.gov/csi/rebates.php