**Q uestions**  **about the Clean Power Plan and possible impacts in Arizona**  **:**

1. The EPA goals for reductions in carbon emissions that are articulated in the p lan are based on the idea that significant reductions are possible by transitioning from coal to gas powered electric generating sources . Do the goals sufficientl y take into account limitations that may be due to the way electricit y can be distributed from those plants to consume rs across the state

— or is the assumption that needed changes to the infrastructure can be made given the timeframe that is available ? 2. If there is a significant transition from coal

- fired plants to natural gas fired electric generating sources , are there li mitations on the ability of such plants to provide both the electric base load and still meet peak demand, especiall y in the summer months in areas such as Phoenix? 3. Why did the EPA use the figures in the building block 3 in Arizona that are less than the s tate Renewable Portfolio Standard goal? Does ADEQ anticipate that Arizona could draw more from renewable sources in trying to meet the goals than is anticipated in building block 3? 4. How does ADEQ anticipate that the carbon emissions reduction goals might effect Arizona as a net exporter of electricit y ? 5. We see a number of actions that have been taken already b y Arizona's electric utilities to reduce carbon emissions. What appears to b e the disposition of these companies to making additional changes in order to meet the state goals? 6. To what extent is the governors office

— including the new governor elect

— working with ADEQ to formulate a plan for meeting the EPA goals ? The past governor publicl y indicated that she was intending to join those states that are making legal challenges to the EPA’s proposed plan. Does ADEQ expect that the new governor might adopt a similar disposition? If that happens, will the ADEQ continue to work with the EPA for the purposes of submitting a state plan? 7. What plans are being considered to help mainta in the supply of electricity

at low rates to the S alt River Project for the purpose of pumping water from the Colorado River to Phoenix if it turns out that Nav ajo Generating Station is partly or completel y decommissioned? 8. Arizona does not have a state wide building code that mandates a baseline level of energy efficiency

in buildings constructed in the state. According to its mission statement, ADEQ is an agency that sets and enforces building and monitoring codes pertaining to air, water, and waste pollution management that “protect and enhance public health and the environment .” There is great potential to reduce carbon emission on the demand side end of electrical consumption by augmenting energy efficiency

standards in homes and business across Arizona. How is ADEQ positioned to set and enforce a standardized building code s ys tem in Arizona to enhance energy efficiency

in Arizona homes and businesses? 9. In an attempt to maximize carbon emission reductions related to building block 4 of the Clean Power Plan, has ADEQ incorpor ated into their assessment of carbon emissions reductions the potential gains of implementing a state wide buildingcode standard for energ y efficiency ?

10. What kind of energy

efficiency

measures does ADEQ think are best for AZ? Demand side efficiency

upgrades or suppl y side? 11. Which coal plants in AZ might be best to retrofit for plant efficiency , to meet the emissions reduction targets in the c lean power plan? 12. Under building block 1, there are no assumptions that coal fired plats will collect and sequester carbon emissions. Having said that, what does ADEQ take to be the potential for carbo n sequestration? D oes the test site in Cholla factor i nto ADEQ's planning? 13. What regional cap and trade partnerships are being considered as the state looks at its options for meeting the goals? To what extent does the adjusted timeline for meeting the emissions reduction goals figure into the ADEQ’s current attitudes towards such partnerships as possible avenues for complying with the plan? 14. We see that ADEQ has raised questions about the options open to the state for meeting the carbon emissions reduction goals. In particular, the assumption that Arizona will have no emissions from coal fired plants seems to constrain its options for drawing on building blocks 3 and 4 in order to meet the interim targets. ADEQ claims that it this is a problem that several states face

— especiall y those in the western regions. Does EPA acknowledge these difficulties? If this is a real problem for some states, then that seems to provide reasons for thinking that the Clean Power Plan might be revised to gi ve these states stronger incentives for drawing on building blocks 3 and 4 in meeting the goals. How might the plan be revised to provide such incentives for these states?