Consultation with the Fort Mojave I

Tribe

Clean Power Plan Proposal an

Supplemental Proposal

August 22, 2014
Overview

► EPA Clean Power Plan Proposal► Why is EPA Proposing this Rulemaking?► Affected EGUs Located in Indian Country► Request for Comments in Proposal► Next Steps► Determination of the Best System of Emission Reduction► Questions for Consideration
EPA Clean Power Plan Proposal

► Under Clean Air Act section 111(d), EPA issued the Clean Pow

proposal on June 2; proposal was published in the Federal ReJune 18

► EPA proposed emission guidelines for states to follow in deve

to address greenhouse gas (GHG) emissions from existing foselectric generating units (EGUs); specifically, we proposed:

► State-specific rate-based goals for carbon dioxide (CO

2) emission

power sector

► Guidelines for states to follow in developing plans to achieve the 

goals

► Affected EGUs located in Indian country would not be encomp

a state’s CAA section 111(d) plan

► EPA did not propose goals for areas of Indian country with affe

in the June 18 proposal

► EPA intends to publish a supplemental proposal to establish goal

affected plants identified in Indian country

► EPA intends to seek comment on how tribes with renewable ener

demand-side energy efficiency (EE) programs can be included in 
Why is EPA Proposing this Rulemaking

► CO

2 is a potent greenhouse gas (GHG) that contributes to climate 

► CO

2 is the primary GHG pollutant, accounting for nearly 75% of glo

emissions and 82% of GHG emissions across the country

► GHG pollution is causing potentially rapid, damaging and long-last

our climate that can have a range of severe negative effects on huand the environment

► May 2014 report of the National Climate Assessment concluded th

change impacts are already manifesting themselves and imposing costs; report documents increases in extreme weather and climate recent decades, damage and disruption to infrastructure and agricprojects continued increases in impacts across a wide range of cosectors, and ecosystems

► By 2030, the rule would achieve CO

2 emission reductions from the 

of approximately 30 percent from CO

2 emission levels in 2005 and 

emissions of other air pollutants, including SO

2, NOx and directly e

from the electric power industry

► EPA projects that, in 2030, the significant reductions in the harmfu

pollution and in other air pollution, to which this rule would lead, wonet climate and health benefits of $48 billion to $82 billion
Determination of the Best System of Emis

Reduction

► To set goals for each state, EPA first determined the Best Syst

Emission Reduction (BSER)

► Because the power sector is interconnected, EPA determined 

4 types of measures, or “building blocks,” together are the besreduce carbon pollution from fossil fuel-fired power plants

► BSER is made up of 4 building blocks: 

(1) measures to make coal plants more efficient (e.g., heat rate i(2) increased use of high efficiency, natural gas combined cycle 

units (e.g., redispatch)

(3) generating electricity from low- or zero-emitting facilities(4) demand-side EE

► After determining the BSER, EPA then set the goals based on 

of the BSER to each state

► The goals EPA is setting for states do not lay out a set of requ

mechanisms a state must use to reduce carbon pollution; rathsetting a numeric goal that a state must meet through the meachoose
Building Block for BSER Strategy EPA Used 

to Calculate the State Goal

Examples of State Compliance Measures

1. Make fossil fuel-fired

power plants more efficient

Efficiency Improvements

• Efficiency improvem• Co-firing or switchin• Coal retirements• Retrofit CCS (e.g., W

Texas)

2. Use lower-emitting 

power sources more

Dispatch changes to existing natural gas combined cycle (CC)

• Dispatch changes to 

natural gas CC

3. Build more zero or lowemitting energy 

sources

Renewable EnergyCertain Nuclear

• New Natural gas-fire

Cycle Units

• Renewables• Nuclear (new and u• New coal with CCS

4. Use electricity more 

efficiently

Demand-side energy efficiency programs

• Demand-side energ

programs

• Transmission efficie

improvements

• Energy storage
Affected EGUs Located in Indian Cou

► EPA is aware of four potentially affected power plants located i

country

► South Point Energy Center on Fort Mojave tribal lands within Arizo► Four Corners Power Plant on Navajo tribal lands within New Mexi► Navajo Generating Station on Navajo tribal lands within Arizona► Bonanza Power Plant on Ute tribal lands within Utah

► We are not aware of any potentially affected EGUs that are ow

operated by tribal entities

► We understand that South Point Energy Center is a natural gas-fir

cycle power plant owned and operated by Calpine
Request for Comments in June 18 Proposa

► The 120-day comment period for the proposal began on June 

will end on October 16th

► EPA requests comment on:

► Whether a tribe wishing to develop and implement a CAA section 

plan should have the option of including the EGUs located in its aIndian country in a multi-jurisdictional plan with one or more statetreating the tribal lands as an additional state) 

► How a federal plan would work in a multi-jurisdictional approach

► EPA invites comment on how the Best System of Emission Re

(BSER) should be applied to potentially affected EGUs in India

► EPA also invites comment on sources of data for setting RE a

demand-side EE targets

► In setting goals specific to an area of Indian country, the EP

to base the goals on the collection of affected EGUs locatethat area of Indian country, and we request comment on thiapproach
Next Steps 

► EPA intends to publish a supplemental proposal to establis

emission performance goals covering affected power plants Indian country

► EPA intends to hold a public hearing for the supplemental p

Arizona

► EPA intends to take final action on the June 2014 proposal 

supplemental proposal by June 2015
Questions for Consideration

► Which building blocks should apply to goal-setting for areas of 

country?

► Do you have data you would like us to consider when determinin

and the goals? 

► We are interested in offering opportunities for tribes to particip

program (e.g., through EE programs or RE resources) to help 

goals even if an affected EGU is not located in the tribe’s area country.

► Do you agree? Do you have recommendations for how to do this

► Are there other issues particular to your area we should be aw