Questions about the Clean Power Plan and possible impacts in Arizona:

1. The EPA goals for reductions in carbon emissions that are articulated in the plan

are based on the idea that significant reductions are possible by transitioning from 

coal to gas powered electric generating sources. Do the goals sufficiently take 

into account limitations that may be due to the way electricity can be distributed

from those plants to consumers 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 limitations on the ability of such plants to provide 

both the electric base load and still meet peak demand, especially 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 state 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 electricity?

5. We see a number of actions that have been taken already by Arizona's electric 

utilities to reduce carbon emissions. What appears to be 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 publicly 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 maintain the supply of electricity at low 

rates to the Salt River Project for the purpose of pumping water from the 

Colorado River to Phoenix if it turns out that Navajo Generating Station is partly

or completely 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 system 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 incorporated into their assessment of carbon 

emissions reductions the potential gains of implementing a state wide building 
code standard for energy efficiency?

10. What kind of energy efficiency measures does ADEQ think are best for AZ? 

Demand side efficiency upgrades or supply side? 

11. Which coal plants in AZ might be best to retrofit for plant efficiency, to meet the 

emissions reduction targets in the clean 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 carbon sequestration? Does the test site in Cholla factor into 

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—especially 

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 give 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?