GHG EGU 111(d) 

Emission Guidelines –

State Plan Implementation

June 24, 2014
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General Overview of Proposal

► Proposal sets an interim (2020-2029) and final goal (2030) 

EGUs in each state to reduce carbon pollution

► Rate-based performance level (lb CO2/MWh)

► EPA is not prescribing measures states need to implement 

goal

► States have flexibility to choose what goes into their plan – 

when to get the necessary reductions, provided the goals aestablished timeframe

► Choose form of goal (rate or translate to mass)► Choose what works best in a state, tailored to state needs 

objectives

► Opportunity to build on existing energy efficiency and rene

programs 

► Flexible over time and place – states can look across the e

system to achieve reductions from affected EGUs, and hameet the interim goal on average basis

► Option to work with other states through multi-state plan, w

lower costs

► Fits into existing state and utility electricity sector planning 
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Timing for State Plan Submittals 

► Individual and multi-state plans due June 30, 2016 ► Some states may reasonably need additional time to subm

plans, due legislative approval process, rulemaking, compleassociated with regional approaches

► Providing states with additional time to submit complete pla

justified, and if states provide specific information

► Proposed timing of extensions to submit a complete plan, if ju

supported:

• Individual state plans: a one-year extension (June 30, 2017) • Multi-state plans: a two-year extension (June 30, 2018); would su

progress report on June 30, 2017
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By June 30, 2016

state submits initial multistate 111(d) plan and 

request for 2-year extension

EPA reviews initial 111(d) 

plan and determines if 

extension is warranted

by June 30, 2017

state submits progress 

report on final 11(d) plan 

development

by June 30, 2018

states submits multistate 111(d) plan

State submits Negative Declaration

State submits complete Implementation Plan by June 30, 2016

State submits Initial Implementation Plan by June 30, 2016 and request 1-year extensio

State submits Initial Multi-state Implementation Plan by June 30, 2016 and request 2-ye

June 1, 2015

EPA Promulgates 

final 111(d) 

Emission 

Guidelines

by June 30, 2016

state submits negative 

declaration

EPA publishes FR notice

by June 30, 2016

state submits 111(d) plan

by June 30, 2016

state submits initial 111(d) 

plan and request for 1-year 

extension

EPA reviews initial 111(d) 

plan and determines if 

extension is warranted 

by June 30, 2017

state submits complete 

111(d) plan

2015 2

111 (d) State Plan Timeline

EPA reviews plan and 

publishes final action 

within 12 months on 

approval/disapproval

EPA reviews plan and 

publishes final action 

within 12 months on 

approval/disapproval

EPA rev

publishe

within 1

approva

2016 2017 2018
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Initial Plan Content

► If a state seeks an extension, must submit an initial pl

following content by June 30, 2016:

► Description of plan approach and progress made in developing comp► Initial quantification of the level of emission performance that will be a

the plan

► Commitment to maintain existing measures that limit or avoid CO2 em

RPS, unit-specific limits on operation or fuel utilization), at least until tis approved

► Comprehensive roadmap for completing the plan, including process, 

methods, and schedule (including milestones) specifying when all neccomponents will be complete (e.g., projection of emission performanclegislation, regulations and agreements; necessary approvals)

► Identification of existing programs state intends to rely on to meet its ► Executed agreement(s) with other states (e.g., MOU), if regional app

pursued

► Commitment to submit a complete plan by the applicable required da

the state will take to show progress in addressing incomplete plan co

► Description of steps already taken toward developing complete plan► Evidence of opportunity for public comment on the initial plan
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Evaluating the Sufficiency of Plans

► The EPA will evaluate the sufficiency of each plan bas

plan addressing twelve plan components and on four criteria to determine whether a state’s plan is “satisfacCAA section 111(d)(2)(A)

► Four general criteria 

1. A state plan must contain enforceable measures that r

CO2 emissions from affected EGUs

2. Measures in the plan must be projected to achieve em

performance equivalent to or better than the applicablspecific CO2 goal on a timeline equivalent to that in th

guidelines

3. EGU CO2 emission performance under the state plan 

quantifiable and verifiable 

4. The state plan must include a process for state report

implementation (at the level of the affected entity), CO

performance outcomes, and, if necessary, implementacorrective measures
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Required State Plan Components 

► State plans must include 12 components:1. Identification of affected entities (affected EGUs an

responsible parties)► A state may identify affected EGUs as the only entities subjec

requirements in its state plan

► A state plan may include other non-EGU affected entities that 

enforceable obligations under the plan

2. Description of plan approach and geographic scop

► A state may participate in a multi-state plan or develop a state► A multi-state approach may provide participating states with g

and options

3. Identification of required emission performance lev

affected EGUs► Emission performance level must be equal to or better than st

emission performance goal for affected EGUs

► A state may convert its goal from a rate basis to a mass basis► See “Projecting EGU Emission Performance in State Plans” T

discussion of considerations related to this translation
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Required State Plan Components (con

4. Demonstration that plan is projected to achieve requ

emission performance level► State plan must demonstrate that the suite of enforceable meas

plan are projected to achieve the required emission performancaffected EGUs specified in the plan (on a rate or mass basis, a

► During the initial 2020-2029 plan performance period, demonstratio

average basis (rate goal) or cumulative basis (mass goal), 

► Plan must demonstrate it will achieve the required final emission p

level in 2030

► This demonstration includes a detailed description of the analytic p

and assumptions used to project future CO2 emission performance

► Considerations related to projecting the emission performance of a

under a state plan are discussed in the “Projecting EGU CO2 EmisPerformance in State Plans” TSD
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Required State Plan Components (con

5. Identification of milestones

► Periodic programmatic milestones are required to demonstrat

implementation (for plans that are not “self-correcting”)

► “Self-correcting” plans inherently assure full achievement of the state plan’

emission performance through requirements that are enforceable against a

► Milestones must have specific achievement dates appropriate 

programs and measures in the plan

► State plan demonstration must also indicate the plan’s trajecto

performance improvement

► State must compare the collective emission performance achieved by affe

state during the previous two-year period with performance projected in the beginning in 2022 and for each year during the interim performance period

► See preamble Section VIII.B.2.d

6. Identification of corrective measures

► A plan without self-correcting mechanisms must specify correc

that will be implemented if the state plan fails to achieve its premission performance trajectory by more than 10 percent of thprojection and a process and a schedule for implementing suc

► See preamble Sections VIII.B.2.d and VIII.B.2.e
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Required State Plan Components (con

7. Identification of emission standards and any other 

► State plan must identify the applicable emission standards for 

entities (e.g., individual affected EGUs, groups of affected EGstate’s affected EGUs in aggregate, affected entities that are 

► State plan must identify any implementing and enforcing mea

emission standards, including the schedule for compliance foentity

► Averaging times for emission standards for an affected entity:

• Rate-based emission performance level – cannot exceed • Mass-based emission performance level – cannot exceed 

8. Demonstration that each emission standard is qua

non-duplicative, permanent, verifiable, and enforce► State plan must describe how each emission standard has the

characteristics, recognizing the non-traditional nature of some affected entities

► An emission standard is quantifiable if it can be reliably meas

technically sound methods in a replicable manner
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Required State Plan Components (con

9. Identification of monitoring, reporting, and recordke

requirements ► Plan must include monitoring and reporting requirements for C

and energy output (if applicable) from affected EGUs

► Plan must include monitoring and reporting requirements for o

entities if include in the plan

► For additional information see Part 75 Monitoring and Reporti

Considerations TSD and State Plan Considerations TSD

10. Description of state reporting 

► Annual reports, due six (6) months after calendar year end► Must include all information in 40 CFR 60.5815 (Part 75 repor► EGUs may report emissions directly to EPA, if a state wants t

the Part 75 reporting program; this option may save state reso

► State must report all information necessary to demonstrate pl

performance and implementation, including programmatic milimplementation of corrective actions (if relevant)

► For additional information see Part 75 Monitoring and Reporti

Considerations TSD and State Plan Considerations TSD
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State Plan Components (cont.)

11. Certification of hearing on state plan 

► State plan must provide certification that it held a hearing on the state 

witnesses (with their organizational affiliation, if any) appearing at the brief written summary of each presentation or written submission, purrequirements of the EPA framework regulations at 40 CFR 60.23-60.2

12. Supporting material 

► State must provide supporting material and technical docume

applicable plan components 

• Must demonstrate that it has the legal authority for each impleme

enforcement component in its plan, as part of a federally enforcestandard, by providing material related to the state’s legal authorimplement and enforce each component of the plan, such as staregulations, public utility commission orders, and any other applicinstruments

• Must provide analytical materials used in translating a rate-based 

based goal if a mass-based goal is used, analytical materials useemission performance that will be achieved through the plan, releimplementation materials, and any additional technical requiremeguidance the state proposes to use to implement elements of the 
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Summary of Required State Plan Com

► Identification of affected entities (affected EGUs and other 

parties)

► Description of plan approach and geographic scope► Identification of state emission performance level ► Demonstration that plan is projected to achieve emission p

level

► Identification of milestones► Identification of corrective measures► Identification of emission standards and any other measur► Demonstration that each emission standard is quantifiable

duplicative, permanent, verifiable, and enforceable (recogtraditional nature of some potentially affected entities) 

► Identification of monitoring, reporting, and recordkeeping r► Description of state reporting ► Certification of hearing on state plan ► Supporting material 
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Clean Power Plan ToolboxGoal: Provide centralized, streamlined information to assist states witdevelopment and submittalCurrently:

► Links to proposal and technical support documents► Federal resources to assist states in evaluating state plan approa

► Not required for state plan development

► Information on current state policies and programsAfter the rule is finalized:► Additional information states will need to include in their state plan

► Checklist► Tools, if appropriate

This is a dynamic resource that will be updated periodically, and we ainformal feedback on additional information that would be helpful to scan provide comments through the website
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http://www2.epa.gov/cleanpowerplanto
Regional Contacts

Region Name Email 

1 Shutsu Wong wong.shutsu@epa.gov 617

2 Gavin Lau lau.gavin@epa.gov 2123 Mike Gordon gordon.mike@epa.gov 2154 Ken Mitchell mitchell.ken@epa.gov 4045 Alexis Cain cain.alexis@epa.gov 3126 Rob Lawrence lawrence.rob@epa.gov 2147 Ward Burns burns.ward@epa.gov 9138 Laura Farris farris.laura@epa.gov 3039 Ray Saracino saracino.ray@epa.gov 415

10 Madonna Narvaez narvaez.madonna@epa.gov 206