# 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 likely9 

# 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

10Sulfur Dioxide (SO 2 tons)

↓ 82% through 2010 1 ↓90 % through 2015 1

Nitrogen Oxide ( NO x tons) ↓ 48 % through 2010 1 ↓75 % through 2015 1 

# Westar Energy emission reductions

NOTE: 1. CSAPR reduction goals:

• SO 2 – 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 Energy0

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 Allocations14 • Requests annually through 2016 an additional

• Group 2 SO 2 Annual allowances

• NO x Annual allowances and

• NO x 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 SO 2 allowances, 2.000 NO x Annual allowances and 1,000 NO x 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 SO 2 allowances 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&L16 • Sunflower requires an additional 236 annual NO x allowances and 256 seasonal NO x allowances adequate to operate the Holcomb 1 EGU to meet forecasted energy production requirements beginning in 2012.

• Mid

- Kansas Electric requires an additional 1,487 NO x allowances and 895 seasonal NO x allowances 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.