Environmental Protection Agency 

Clean Power Plan Talking Points 

July 29, 2014 

Page 1 

Rs 

PLATTE RIVER 

POWER AUTHORITY 

Estes Park • Fort Collins • Longmont • Loveland 

Re: Clean Power Plan Talking Points 

• My name is Deborah Schaneman. I am the Environmental Services and Compliance 

Director for the Platte River Power Authority in Fort Collins, CO. 

• I want to thank you for the opportunity to comment today on the important issue of 

carbon emissions. 

• Platte River Power Authority is a political subdivision of the State of Colorado. Platte 

River was formed by the municipalities of Estes Park, Fort Collins, Longmont and 

Loveland and provides wholesale power to these communities. Like the municipal 

utilities it serves, Platte River is a non-profit municipal utility. 

• In 2013 the Platte River Board of Directors adopted a strategic plan to analyze 

diversification of our resource portfolio in a manner designed to reduce carbon 

emissions. The guidance from our Board included a 20% reduction in carbon emission 

by 2020 and an 80% reduction by 2050. Consequently, the direction from our Board 

tracks with the pending rulemaking. 

• Although I have been immersed in this issue since June 2, as have numerous other staff 

members at Platte River, as an organization Platte River is still analyzing this 

complicated proposal. Platte River intends to be fully engaged in this rulemaking 

process and plans to file detailed written comments at a later date. 

• In the time allotted today I will focus on two important concerns. 

• First, Platte River has serious concerns about how the four building blocks were 

analyzed to identify the emission guideline for Colorado. Specifically, we believe that 

Colorado is being unfairly penalized for being proactive in its approach to carbon 

emissions. By employing 2012 as a starting point in its analysis, the EPA fails to credit 

much of what Colorado utilities did during the first decade of this century. Let me give 

one example. The first building block assumes a 6% efficiency improvement at the 

generation source. Beginning in 2005, Platte River invested $16.55 million to improve 

the heat rate of Rawhide unit one north of Fort Collins. These efficiency improvements 

were completed by 2009 and lowered the heat rate by 4.1%. Additional incremental 

efficiency improvements are technically possible, but Platte River has already taken the 

biggest possible bite. Failure to recognize initiatives that occurred prior to 2012 

penalizes proactive utilities by disadvantaging them relative to utilities that have failed 
Environmental Protection Agency 

Clean Power Plan Talking Points 

July 29, 2014 

Page 2 

to address the issue. Moreover, failure to recognize and credit concrete actions taken 

prior to 2012 results in a state target that is unrealistic. 

• Second, the proposed rule establishes an average emission rate for the period 2020 

through 2029, which is unnecessary and creates needless administrative difficulties. To 

achieve the 2030 emissions goal, additions and removals of generation assets will be a 

significant element of many compliance efforts; this is particularly true for Platte River 

which does not presently operate any natural gas combined cycle generation. Changes 

in the makeup of a resource portfolio take long periods of time to plan and implement, 

and are by their nature "lumpy". The commissioning and/or decommissioning of 

resources create significant issues associated with rate impacts and reliability. To the 

extent that significant portfolio changes need to be made subsequent to 2020, it may not 

be possible to meet the averaged emission rates set forth in the proposed rule. Simply 

put, the extensive nature of the changes required by this rule means that utilities may 

reasonably require a glide path longer than the time allowed between the finalization of 

this rule and 2020 to modify their portfolios. If left unchanged the rule will unavoidably 

penalize utilities that are undertaking bona fide yet prudent efforts at compliance 

through modifications of their resource portfolios that necessarily extend beyond 2020. 

Platte River suggests that the EPA set a reasonable emissions goal for 2030 and trust the 

states to develop reasonable compliance plans to achieve reductions rather than 

specifying fixed interim requirements the effect of which may be to complicate 

compliance. 

• In summary, carbon emissions are a significant issue. It is reasonable to expect electric 

utilities to assist in meeting the challenge involved in curbing carbon emissions. But to 

ensure the smoothest possible implementation, the final rule must be perceived as fair 

and subject to effective - but flexible - implementation by the states. Not only must past 

efforts be recognized and taken into account, but it is also important to ensure that the 

final rule avoids implementation pitfalls that fail to recognize the practical realities of 

resource portfolio management and reliable utility operation. 

• Thank you again for the opportunity to comment. 

Respectfully submitted, 

Deborah R Schaneman 

Environmental Services and Compliance Director