Consultation with the Fort Mojave IndianTribeClean Power Plan Proposal andSupplemental ProposalAugust 22, 2014Overview►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 Consideration2EPA Clean Power Plan Proposal►Under Clean Air Act section 111(d), EPA issued the CleanPower Planproposal on June 2; proposal was published in the Federal Register onJune 18►EPA proposed emission guidelines for states to follow indeveloping plansto address greenhouse gas (GHG) emissions from existing fossil fuel-firedelectric generating units (EGUs); specifically, we proposed:►State-specific rate-based goals for carbon dioxide (CO2) emissions from thepower sector►Guidelines for states to follow in developing plans to achieve the state-specificgoals►Affected EGUs located in Indian country would not be encompassed withina state’s CAA section 111(d) plan►EPA did not propose goals for areas of Indian country with affected EGUsin the June 18 proposal►EPA intends to publish a supplemental proposal to establish goals for the fouraffected plants identified in Indian country►EPA intends to seek comment on how tribes with renewableenergy (RE) anddemand-side energy efficiency (EE) programs can be included in plans3Why is EPA Proposing this Rulemaking?►CO2is a potent greenhouse gas (GHG) that contributes to climate change►CO2is the primary GHG pollutant, accounting for nearly 75% of global GHGemissions and 82% of GHG emissions across the country►GHG pollution is causing potentially rapid, damaging and long-lasting changes inour climate that can have a range of severe negative effects on human healthand the environment►May 2014 report of the National Climate Assessment concluded that climatechange impacts are already manifesting themselves and imposing losses andcosts; report documents increases in extreme weather and climate events inrecent decades, damage and disruption to infrastructure and agriculture, andprojects continued increases in impacts across a wide range ofcommunities,sectors, and ecosystems►By 2030, the rule would achieve CO2emission reductions from the power sectorof approximately 30 percent from CO2emission levels in 2005 and also reduceemissions of other air pollutants, including SO2, NOx and directly emitted PM2.5,from the electric power industry►EPA projects that, in 2030, the significant reductions inthe harmful carbonpollution and in other air pollution, to which this rule would lead, would result innet climate and health benefits of $48 billion to $82billion4Determination of the Best System of EmissionReduction►To set goals for each state, EPA first determined the Best System ofEmission Reduction (BSER)►Because the power sector is interconnected, EPA determinedthat a set of4 types of measures, or “building blocks,” together are the best system toreduce 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 improvements)(2) increased use of high efficiency, natural gas combinedcycle (NGCC)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 applicationof the BSER to each state►The goals EPA is setting for states do not lay out a set of requiredmechanisms a state must use to reduce carbon pollution; rather, EPA issetting a numeric goal that a state must meet through the measures theychoose5Building Block for BSER Strategy EPA Usedto Calculate theState GoalExamples of StateCompliance Measures1. Make fossil fuel-firedpower plants moreefficientEfficiencyImprovements• Efficiency improvements• Co-firing or switching to natural gas• Coal retirements• Retrofit CCS (e.g., WA Parish inTexas)2. Use lower-emittingpower sources moreDispatch changes toexisting natural gascombined cycle (CC)• Dispatch changes to existingnatural gas CC3. Build more zero or lowemitting energysourcesRenewable EnergyCertain Nuclear• New Natural gas-fired CombinedCycle Units• Renewables• Nuclear (new and up-rates)• New coal with CCS4. Use electricity moreefficientlyDemand-side energyefficiency programs• Demand-side energy efficiencyprograms• Transmission efficiencyimprovements• Energy storage6Affected EGUs Located in Indian Country►EPA is aware of four potentially affected power plantslocated in Indiancountry►South Point Energy Center on Fort Mojave tribal lands within Arizona►Four Corners Power Plant on Navajo tribal lands withinNew Mexico►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 thatare owned oroperated by tribal entities►We understand that South Point Energy Center is a natural gas-fired combinedcycle power plant owned and operated by Calpine7Request for Comments in June 18 Proposal►The 120-day comment period for the proposal began on June 18thandwill end on October 16th►EPA requests comment on:►Whether a tribe wishing to develop and implement a CAA section 111(d)plan should have the option of including the EGUs located in its area ofIndian country in a multi-jurisdictional plan with oneor more states (i.e.,treating 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 Reduction(BSER) should be applied to potentially affected EGUs in Indian country►EPA also invites comment on sources of data for setting REanddemand-side EE targets►In setting goals specific to an area of Indian country, the EPA intendsto base the goals on the collection of affected EGUs located withinthat area of Indian country, and we request commenton thisapproach8Next Steps►EPA intends to publish a supplemental proposal to establish CO2emission performance goals covering affected powerplants located inIndian country►EPA intends to hold a public hearing for the supplemental proposal inArizona►EPA intends to take final action on the June 2014 proposal and thesupplemental proposal by June 20159Questions for Consideration►Which building blocks should apply to goal-setting for areas of Indiancountry?►Do you have data you would like us to consider when determining the BSERand the goals?►We are interested in offering opportunities for tribes to participate in theprogram (e.g., through EE programs or RE resources) tohelp attain CO2goals even if an affected EGU is not located in the tribe’s area of Indiancountry.►Do you agree? Do you have recommendations for how to do this?►Are there other issues particular to your area we shouldbe aware of?10