Indiana Questions on 111(d)

8-28-2014 

1. Does EPA have a model of plans that would be acceptable to them for RE and 

EE? That is, IDEM is struggling with the documentable, measurable, and 

enforceable aspects of these requirements and an example may help us 

formulate a plan of our own.

2. We are interested in hearing more about why a net CO2 rate was used instead of 

gross. This seems to provide coal plants the ability to turn off criteria pollutant 

control devices to increase efficiency to meet the CO2 standard but could cause 

areas to not meet a NAAQS. Using a gross rate for both the baseline and goal 

would not put the different set of pollution control measure against each other.

3. On that same gross vs net discussion. It appears that the CAMD data used by 

EPA is a mixture of both net and gross MWhrs. Would EPA expect or like states 

to submit their own baseline and goal calculations based on all net output?

4. Would EPA allow state to use the goals alternative approach (higher CO2 rate 

but faster compliance deadline) even if that is not the primary approach adopted 

in the rule? That is, the rule allows States to propose and submit their own goal 

for EPA approval. Would using the alternative approach as laid out in the rule be 

something EPA envisions being the type of state derived plan that would be 

approvable? 

5. Has EPA considered using a multi-year approach for determining the base year 

as opposed to 2012 using a method similar to that used in CAIR? Is EPA open to 

the idea of using a multi-year evaluation for base year determination? 

6. Time frames: IDEM is very concerned about timing with this rule. Primarily 

IDEM is concerned that there is not enough time to get state rules in place to 

enforce the new EGU rule. Additional state legislative action may have to take 

place which may not be able to happen in time too. IDEM would also like to 

incorporate a stakeholder process into the development of the state plan since so 

many stakeholders are involved but IDEM is worried that there is not time to 

actually do this, thus opening IDEM up to potential lawsuits when our plan is 

released without stakeholder involvement. Is EPA considering extending 

deadlines back by a year or two to allow for more input given the extreme 

complexities both legislatively and logistically? 

7. How is nuclear factored in for goal calculations? A lot of northern Indiana 

citizens have paid increased rates to keep Michigan at risk nuclear facilities 

operating so they can continue to get energy from those plants. 
8. Would purchase power agreements made by utilities meet the requirements 

under the rule as enforceable?

9. Has EPA evaluated the reliability issue concerning power on peak demand days? 

A Recent MISO evaluation indicates that beginning in 2015 capacity of Indiana’s 

fleet will not meet demand for peak summer days. During those same days in the 

past Indiana has had surplus capacity that was necessary to meet excess 

demand in the NE. If there is insufficient capacity to meet our own needs, has 

there been an evaluation to show that there will be sufficient added capacity to 

meet the nation’s need? 

10.Can EPA provide an explanation as to how to treat facilities that sell part of their 

energy to the grid and part of the energy to specific industries should be treated?

11.We are interested in hearing more about the heat rate BSER of 6%. Our 

research indicates that many facilities in Indiana already have applied dense 

pack to the facilities and less than 1% heat rate efficiencies can be achieved after 

those efficiencies have been applied. Also, research indicates that efficiency 

measures become less effective over time making it difficult to maintain any set 

percentage of improvements over 15 years. 

12.Additionally, our information indicates that using block 2 to redistribute from coal 

fired EGUs on an as needed basis would also drastically impact the heat rates 

achievable by those units. It would cause more coal units to act as “peakers” 

and thus be even less efficient during those high demand times. Would the loss 

in efficiencies by the coal units be offset by the greater use of natural gas or 

would the net CO2 rate actually go up? Has EPA looked into this issue? It 

appears to us that block 1 and block 2 could work against each other in 

application. 

13.How will EPA handle the potential triggering of NSR requirements if a facility 

decides to make improvements? The current set up seems to be a stumbling 

block for facilities to make changes because it could require them to take new 

more stringent limits for criteria pollutants or potentially have to install very 

expensive controls. There would be very little incentive for facilities to do this. 

14.Is there consideration of developing a national trading program for CO2?

15.How would being a net exporter of energy affect the development of a state plan

for the rule? 

16.Can EPA explain the methodology as to how they calculated the “State 

Generation as a % of sales” value in Step 5 of the goal sheet? We have not been 

able to replicate EPA’s numbers. 

17.How would EPA like to see other renewable besides wind and solar incorporated 

into the State Plan? For example, digesters can burn methane to generate 
power from manure. These are not large scale EGU’s but many digesters on a 

large CAFO would reduce many tons of a very potent greenhouse gas. Can 

states add these units into the calculation for a state emission rate?