1 **NACAA, AAPCA, and ECOS Cosponsored 111(d) Webinar**

**Rate -**  **to -**  **Mass Conversion Questions November 20, 2014**  1. EPA has di scussed the possibility of 111(d) appl ying to existing and new units. If EPA choos es to include new units in 111(d) , will they increase the mass the state is allowed to emit by

the amount the new unit would be allowed under NSPS? 2. If an NGCC floor is established in the final rule, will EPA recalculate the mass goal for each state and communicate the result before the state plan deadline? 3. I f the RE/EE fossil offset is established in the final rule, will the resulting numeric goal be less than in the original proposal? 4. The existing affected source approach from the rate - to - mass goal translation TSD produces a generation level (and CO2 mass) for GA that is 28% less than the generation (and CO2 mass) used to set the rate -based goal in the original rule proposal (see Table GA - 1). How can a translated mass -based goal be equivalent to the rate -based goal if it does not use the same generation lev el? **Table GA -**  **1. Final generation and CO2 emissions for selected goal calculation**  **approaches Goal approach/form**  **2030 generation**  **(MWh) 2030 CO2** 

**emissions (short tons)** * **2030 CO2**

**Rate (lbs/MWh)**  Rate -to - mass Goal Translation TSD

– Tables 1 & 4; Existing Affected Source 87,753,806 34,843,000 834 Original Goal Computation TSD 122,216,047 50,964,092 834 5. In the original proposal, EPA’s goal - setting equation adds incremental RE and EE to the 2012 baseline generation (in the denominator of the formula) but does not affect fossil generation or emissions. Inthe NODA, EPA proposed two different approaches for revising the goal - setting formula in which incremental RE and EE replace 2012 fossil generation. Inthe rate - to - mass goal translation TSD, incremental RE and EE generation replace historical fossil generation, which is similar to the NODA approaches. Is EPA’s rate - to - mass translation TSD approach intended to be equivalent to the rate -based limits established in the original proposal or is it intended to be equivalent to rate -based limits that would be determined using one or both of the approaches included in the NODA? 6. By using Table 1 of the rate - to - mass goal translation TSD, GA EPD calculates that Georgia fossil generation in 2030 would shrink to 51 % of fossil generation in 2012. By comparison, data from the Annual Energy Outlook 2014 for the SERC - SE region2

project that 2030 fossil generation will be 123 % of 2012 generation. See Table GA 2. How does EPA account for this very large disparity and is the fossil generation projected by the TSD realistic? **Table GA** **- 2.**  **Comparison of**  **Projected Fossil**  **Generation**
**– TSD**  **versus AEO**  **2014 Projection**  **Source 2012**  **fo ssil**  **generation (**  **10 6**  **MWh) 2030**  **fo ssil**  **generation**

**(10 6**  **MWh) Ratio**  **(2030/2012)** Translation TSD Table 1, (Existing Affected Sources)* 78.6 40.2 0.51

AEO 2014 SERC - SE Table 86** (GA, AL, MS partial, FL partial) 188.9 232.8 1.23

*2030 generation = historical fossil

– Block 3 incremental

– block 4 avoided generation **Calculated as sum of coal and natural gas generation AEO reference: Released May 7, 2014, Electricity

and Renewable Fuels Tables, Table 86, “ Generation by Fuel Ty pe" data 7. Could EPA choose a specific state and walk through their methodology for the two approaches to translating rate targets to mass targets, including identifying alternative inputs or data sources that states could use? 8. Would EPA look to translate a state’s rate -based target to a mass -based target in the event that the Agency

imposes a federal implementation plan? 9. PJM’s analysis of its original interpretation of the rule found substantially a higher mass -based regional cap than that refle cted in EPA’s TSD. Has EPA reviewed that anal ys is, and can the Agency explain the difference in the approach? 10. The proposed regulatory language for the 111(d) rule describes the process for converting a rate -based goal to a mass -ba sed goal at 40 C.F.R. 60. 5770. If a state plan incorporates exactly one of the methodologies and mass -based targets from EPA’s goal translation TSD, is the state ’s mass -based goal presumptively “equivalent” to the rate -based goal, as the regulations require? If not, what else would a state need to do to show it has an approvable mass -based goal?