CROSS STATE 

AIR POLLUTION RULE 

Coalition of Kansas Utilities

US Environmental Protection Agency

November 7, 2011

Kansas City, Kansas

1

A Major Concern For Kansas Customers
Coalition of Kansas Utilities

• Kansas City Power and Light

– Heather Humphrey

– Paul Ling

• Westar Energy

– Greg Greenwood

– Marty Bregman

– Bill Eastman

– Dan Wilkus

• Kansas City Board of Public Utilities

– Don Gray

– Darrell Dorsey

– Pat Cassidy

– Tiffany Le

• Sunflower Electric Power Corp.

– Wayne Penrod

2
Impossible Timeline

3

• This is the first time that Kansas has been subject to 

a transport rule, and Kansas needs an initial 

compliance timeline similar to those states already in 

CAIR

• It is not possible to have additional controls in place 

by 2012. An emission control project takes 2-5 years 

to complete depending on technology/funding

 Kansas Utilities have cost effective plans to reduce 

emissions under BART and Ozone requirements
System Reliability at Stake

4

BEFORE CSAPR AFTER CSAPR
Reliability impacts: Westar Energy

5

• Implement rolling blackouts to shed load

• Blackouts would occur from April through August

• Most significant impact in June, with Westar reducing 

its generation by 33,881 MWh. 

• 47MW of rolling blackouts would occur every hour of 

every day in June.

• At any time, between 1,900 and 5,900 customers 

would be without electricity.
Reliability impacts: Sunflower 

Electric Power Corp.

6

• Holcomb would be limited to 75% of its traditional 

dispatch during May to September ozone season. 

• The gas steam units will consume much of their 

allocation to accommodate the Holcomb 1 outage. 

They will effectively consume their annual 

allocation by early May. The ozone season 

allocation will be consumed by early July. 
Reliability impacts: BPU

7

• BPU solved for allowance allocations and 

determined that they would be out of allowances 

by May 10th and Wyandotte County and Johnson 

County water supply will not have electricity.
Safety, economy at risk

8

• Will result in serious, life-threatening heat related 

health risks and significantly compromise public 

safety

• Will impact Kansas jobs, public services and large and 

small businesses

• Importation of electric power not likely

• Purchase of allowances not likely
9

Asking for a simple remedy

• Approve the Coalition of Kansas Utilities’ request for 

stay 

• Allow Kansas utilities time to implement existing 

emission reduction plans WITHOUT jeopardizing 

system reliability and harming customers
APPENDIX

10
Sulfur Dioxide (SO2 tons)

↓82% through 20101

↓90% through 20151

Nitrogen Oxide (NOxtons)

↓48% through 2010 1

↓75% through 2015 1

Westar Energy emission reductions

NOTE:

1. CSAPR reduction goals:

•SO2 – 73% by 2014

•NOx – 54% by 2014 

Actual Projected

Actual Projected
• Westar requests time to install the Regional Haze emission controls that are 

under construction

• Westar also requests an additional 5,000 NOx Annual allowances and 3,000 

NOx Ozone allowances annually through 2015 to meet the existing obligations 

of serving Westar’s customer’s electric needs

12

Requests: Westar Energy
0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

1,000 

Allocations Required to Meet Needs

Allocations Available Under CSAPR

2012 SO2 Allocations Granted Under CSAPR vs. 

2012 Projected Required Allocations to Meet Electric Needs

CSAPR Allocations Run Out and

All BPU Units Shut Down May 10th

BPU Allocations
14

• Requests annually through 2016 an additional 

• Group 2 SO2 Annual allowances

• NOx Annual allowances and 

• NOx Ozone allowances

Requests: BPU
• Requests time to install the Regional Haze emission controls that are already 

under construction pursuant to the Regional Haze Agreement that KDHE and EPA 

agreed to that will address the allowance shortfall at La Cygne Generating Station

• Requests an additional 3,000 Group 2 SO2allowances, 2.000 NOx Annual 

allowances and 1,000 NOx Ozone allowances annually through 2015 to meet the 

existing obligations of CSAPR for KCP&L at La Cgyne Generating Station

• Requests additional technical adjustments consistent with the October 6 CSAPR 

revisions that were intended to promote the development of the allowance 

market. Specifically, KCP&L requests the ability to use Group 1 SO2allowances for 

compliance in a Group 2 state through 2015 

• Requests the ability to use the next five years of allowances for compliance in 

earlier years

15

Requests: KCP&L
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• Sunflower requires an additional 236 annual NOxallowances and 256 seasonal 

NOxallowances adequate to operate the Holcomb 1 EGU to meet forecasted 

energy production requirements beginning in 2012.

• Mid-Kansas Electric requires an additional 1,487 NOxallowances and 895 

seasonal NOxallowances adequate to operate its natural gas based steam 

turbine generators combustion turbine generators to meet forecasted energy 

production requirements beginning in 2012.

Requests: Sunflower Electric Power Corp.