i

BASIN ELECTRIC 

POWER COOPERATIVE 

1717EASTINfERSTATEAVENUE 

FAX: 701-557 5315 

CHRIS VANDEVENTER 

LEGISLATIVE REPRESE.NTATIVE 

COMMUNICATIONS 6 ADMINISTRATION 

DIRECT:701-557-5416 

CELL: 701426-9847 

cvandevemer@bepc.com ATouchxwneRnegyCooperumcKt 
Testimony offered by Basin Electric Power Cooperative 

Before the Environmental Protection Agency 

Clean Power Plan 

Denver, Colorado and Washington, DC 

July 30, 2014 

Basin Electric Power Cooperative is a generation and transmission cooperative based 

in Bismarck, North Dakota. We serve more than 2.9 million consumers through 136 

rural electric cooperatives across 9 states. We have a diverse energy portFolio including 

coal, wind, natural gas, and nuclear. More than a decade ago, we built the first 

commercial-scale wind projects in the Dakotas. Commitment to the environment was 

one of our founding principles more than 50 years ago. 

Roughly 77 percent of the energy Basin Electric provides to its membership comes from 

coal. The Clean Power Plan as proposed could have serious impacts on affordability 

and reliability in our member systems. In 2013 we recommended several areas we 

wanted EPA to focus on in developing this rule. You responded to some, but left others 

on the table. As you listen to the comments today, and the written comments provided 

later, we urge you to keep all options open in crafting the final rule. 

We appreciate EPA's willingness to consider a flexible approach to compliance. 

Unfortunately, the Clean Power Plan has raised more questions than it provides 

answers. Given the ambiguity and apparent contradictions in the draft rule, we request 

that you extend the comment period for an additional 60 days. With that, we would like 

to share some initial comments: 

1. Regional plans. As a multi-state utility, we support a regional approach. However, 

what works for one state may not work for another. Therefore, states should have 

the option to develop utility-specific compliance plans without the need to join a 

multi-state plan. 

2. Heat Rate. We designed and built our power plants to operate at maximum 

efficiency. There may be opportunities to improve generating efficiency where 

economical, but current New Source Review rules generally don't allow projects 

that result in higher levels of efficiency. EPA should ensure energy efficiency 

improvements pursued by utilities under this rule and approved by a state plan 

should not trigger NSR. 

3. Early action. Any project that reduces CO2 emissions should be allowed for 

compliance as long as those reductions are verifiable and measurable. Through 

our subsidiary DGC, the Great Plains Synfuels Plant has captured and delivered 

more than 28 million tons of CO2 for ultimate sequestration in oil fields in 

southern Saskatchewan. As Administrator McCarthy said when she visited in 

March: "This facility is about the innovation in the United States. This facility is 

about what we can do when we work together." EPA should permit states to 

include innovation like this in their plans. 
4. Re-dispatch. A 70 percent capacity factor for combined cycle plants might 

technically be possible, but permitting, transmission constraints, higher 

maintenance costs, and energy demand all affect a plant's ability to run. Your 

own analysis indicates NGCC plants will run on average just 56 percent of the 

time. EPA should recalculate the state targets to assume a more realistic 

capacity. 

5. Renewable Energy. Do renewable energy credits or so-called green tags stay 

with the generating state or follow the load to the state in which the electricity is 

consumed? The rule appears to leave this matter up to the states. By 2016 we 

will have more than 1,000 megawatts of wind on our system. The uncertainty 

over the counting of green tags will certainly impact our ability to comply with the 

rule in our service area. 

Finally, we have specific concerns about how EPA counted Basin Electric's 

combined cycle generation in South Dakota. Deer Creek Station was under 

construction for the majority of 2012, and went operational late in the year. It ran 

just 90 hours during its startup phase. Yet, EPA assumed the plant had a 1 

percent capacity factor for the entire year. This is inaccurate and unfairly 

penalizes South Dakota in determining that state's emissions target. EPA should 

correct South Dakota's target to reflect that Deer Creek was under construction 

during 2012. 

Thank you for holding this hearing and for taking the time to hear our concerns. We will 

be submitting formal written comments at a later date.