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Technical Support Document (TSD) for the CAA Section 111(d) Emission Guidelines for Existing Power 

Plants 

Docket ID No. EPA-HQ-OAR-2013-0602 

Goal Computation Technical Support 

Document

U.S Environmental Protection Agency 

Office of Air and Radiation 

June 2014 

 
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State Emission Rate Goal Setting under 111(d) 

This Technical Support Document (TSD) provides information that supports the EPA’s determination of 

state emission rate goals under the Proposed Rule. Section VII of the preamble discusses state emission

rate goals more broadly, and the Green House Gas (GHG) Abatement Measures TSD explains the 

technical basis for the development of the Best System of Emission Reductions (BSER) that inform the 

state goal. This TSD provides detailed explanation of the data, the data underlying the state goal 

calculation, the BSER-based calculations used to determine the state goals, and the state goals. The TSD 

is organized as follows: 

1. BSER Factors Informing State Emission Rate Goals 

a. Heat rate improvement 

b. Coal-to-gas redispatch 

c. Renewable (RE) and nuclear generation 

d. End-use energy efficiency 

2. Data Used 

a. Rationale for historic data basis for state goal setting

b. Source of data 

i. Emissions & Generation Integrated Resource Database (eGRID) 

ii. Data sources for “under construction” units coming online post 2012

c. State-level data rationale and significance 

3. Example of State Goal Calculation and Discussion 

4. Appendix (attached Excel Workbook) 

 Appendix 1 – State- level goals, underlying state level data, and calculations for Proposed 

state goals

 Appendix 2 – State- level goals, underlying state level data, and calculations for the 

Alternative state goals 

 Appendix 3 – Summary table of state goals

 Appendix 4 – Block 1 & 2 only goals

 Appendix 5 – 2012 emission rates and building block application 

 Appendix 6 - Details of state-level data development 

 Appendix 7 – 2012 plant-level data and unit-level inventory

Note – This TSD also contains an excel attachment that contains the aggregate state-level data, 

calculations, and proposed state emission rate goals. The underlying plant-level data and unit-level 

inventory is also available in the Docket for this rulemaking.

   

Comment [A1]: A number of the comments in

this TSD mirror comments made in the preamble

and RIA, with a request to sit with EPA to run

through the math details in the Appendix Excel file.  

[EPA Response]:  EPA participated in the requested

meeting.

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Comment [A2]: In the TSD and the preamble

discussion (ref. preamble, pg. 41‐42), EPA should

clarify the purpose and role of the 1990 and 2005

data discussed in the preamble in terms of the state

goal calculations

Within the TSD, there is no reference to this data,

simply a sentence on pg. 4 of the TSD which

indicates “The EPA used 2012 state level data to

determine each state’s emission rate goal.”

[EPA Response]:  1990 and 2005 data are

comparison points for emission reductions.  2012 is

the basis for state goal calculation as it reflects the

most recent year for which we had complete data.  

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Formatted ... [1]

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Comment [A3]: Appendix 1 – Option 1, Column

V sums to 282 TWh for the year 2020.

If biomass is not included, then attaining the

additional ~70 TWh in the 2015‐2020 timeframe

appears of moderate stringency. If biomass is

included, then states need only meet an additional ... [2]

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In EPA’s technical evaluation, reasonable assumptions regarding application of each GHG reducing 

technology were identified (see GHG Abatement Measures TSD). The EPA used these assumptions to 

develop the two regulatory options provided in this proposal: (1) Proposed state goals based on 

reasonable assumptions related to BSER, and (2) Alternative state goals with less ambitious assumptions 

relative to those used for the Proposed state goals. 

1. BSER Factors Informing State Emission Rate Goals 

The GHG Abatement Measures TSD describes the four categories of emission reduction 

measures (building blocks) used in determining the state emission rate goals. That document 

describes EPA’s historic data review and analysis underlying each technology and informing 

EPA’s assessment of its feasibility and cost-effectiveness as part of a BSER. The technology 

estimates determined through EPA’s analysis and documented in the GHG Abatement Measures 

TSD are summarized below. These estimates are used in EPA’s calculation of state emission rate 

goals, as described in this TSD. 

a. Heat Rate Improvement 

Proposed – A 6% heat rate improvement in the state’s coal fleet 

Alternative – A 4% heat rate improvement in the state’s coal fleet 

b. Redispatch to Existing Natural Gas Combined Cycle Plants (NGCC) 

Proposed – a 70% capacity factor (CF) ceiling for the state’s NGCC fleet 

Alternative – a 65% capacity factor ceiling for the state’s NGCC fleet 

Note – These capacity factor values represent ceilings for NGCC utilization. The EPA 

used these ceilings while calculating state goal adjustments related to redispatching coal 

and/or oil and gas (O/G) steam generation to the state’s NGCC capacity. 

c. Renewable and Nuclear 

Both Proposed and Alternative state goals include under construction (5.5 GW) and at 

risk nuclear capacity (~5.8% of nuclear capacity) 

Proposed –RE at 13% by start of 2030 and thereafter* 

Alternative –RE at 9.4% by start of 2025 and thereafter* 

d. End-use Energy Efficiency (EE)* 

Proposed – 10.7% cumulative savings by start of 2030 and each year thereafter 

Alternative – 5.2% cumulative savings by start of 2025 and thereafter 

*Note – The above values RE values and EE saving rates are nationwide averages. Each 

state’s CO2 emission rate goal is informed by state-specific RE and EE values that relate 

to its pre-existing RE generation and EE savings rates respectively as described in the 

GHG Abatement Measures TSD. Also, the RE estimates above do not factor in existing 

hydro generation.

Deleted: Option 1

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Deleted: more moderate

Comment [A4]: Initial text implies that option 1

was “immoderate.”

[EPA Response]:   Thank you, change made

Deleted: Option 1

Comment [A5]: Need to pick a single font,

suggest Times New Roman.

[EPA Response]:  Thank you, change made

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Comment [A6]: The discussion on the limits on

increased dispatch to NGCC suggests the possibility

of evaluating similar constraints to redispatch away

from coal plants – e.g., idling coal and an option for

a floor level ‐‐ and the effects on coal generation in

states with mixed coal and NG fossil generation, i.e.,

zeroing out coal generation in about 10 states.  

These states are evident in the Excel appendix as

the zero coal generation post BB2 redispatch.  This

would be a valuable discussion with EPA with access

to and familiarity with the Excel file and calculation

math. ... [4]

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Deleted: The RE totals do not reflect ... [5]
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The technology assumptions described above are used to determine an emission rate (lb/MWh) 

for each state that constitutes the state goal. As these building blocks reflect both fossil and nonfossil measures, the corresponding state goal reflects a composite emission rate including fossil 

and zero emitting non-fossil technologies. The EPA proposed to use an emission-rate metric for 

state goals, rather than a mass-based metric to promote state flexibility. See preamble section VII 

for more description on the rate based standard. 

2. Data Used 

A. Rationale for Historic Data Basis for State Goal Setting 

The EPA used 2012 state-level data to determine each state’s emission rate goal. The EPA 

carefully considered using a historic year data set, a projected year data set, or a hybrid of the two 

as a starting point for applying the above technology assumptions and calculating the state’s 

emission rate goals.1

 Ultimately the EPA chose the historic data approach as it reflected actual 

historic performance at the state level. EPA chose the year 2012 as it represented the most recent 

year for which complete data were available at the time of the analysis. The EPA also considered 

the possibility of using average fossil generation and emission rate values over a baseline period 

(e.g., 2009 – 2012), but determined that there would be little variation in results compared to a 

2012 base year data set due to the rate-based nature of the goal. 

The state goal is an emission rate representing the deployment of BSER measures, and that 

deployment level is largely a function of technology-specific emission rate reduction capability 

and total NGCC capacity installed to date. Because these two critical variables do not vary 

significantly when looking at a larger baseline period, the benefits of an expanded baseline period 

are dampened, and overshadowed by the complexities introduced through creating a 

“hypothetical” year. Consequently, the EPA decided that using data from an actual year (for 

which facility representatives had reported the values as complete and accurate to the best of their 

knowledge) was preferable to using calculated values that did not reflect any real year 

supply/demand balance. 

For this work, the EPA used 2012 data compiled using the same methodology as in EPA’s 

Emissions and Generation Resource Integrated Database (eGRID) to determine the following 

2012 values at the state level, which become the basis from which state emission rate goals are 

calculated. 

 State level coal generation 

 State level coal emission rate 

 State level oil/gas steam generation 

 State level oil/gas steam emission rate 

 State level NGCC generation 

                                                            

1

 Data sources for future year or hybrid approach would be EPA Base Case Power Sector modeling. 

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Deleted: (the latter not at all) 

Comment [A7]: Does this mean to say that not

one new power plant – fossil or wind – came online

between 2009 – 2012.  Please consider whether this

parenthetical needs to be tempered.  Suggest

deleting the parenthetical.

[EPA Response]:  Thank you for your comment, we

have deleted the parenthetical and made clarifying

edits accordingly.

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 State level NGCC emission rate 

 State level NGCC capacity 

 “Other” generation 

 “Other” emissions2

All generation values are expressed as net generation. Emission rate values are net emission rates 

and expressed as lbs/MWh. The capacity expressed is nameplate capacity in Megawatts. 

B. Source of Data 

i. Emissions & Generation Integrated Resource Database (eGRID) 

eGRID is a comprehensive inventory of environmental attributes of the U.S. electric power 

system. It is the preeminent source of air emissions data for the electric power sector, based on 

available plant-specific data for all U.S. electricity generating plants that provide power to the 

electric grid and report data to the U.S. government. eGRID integrates many different data 

sources on power plants and power companies, including, but not limited to: the EPA, the Energy 

Information Administration (EIA), the North American Electric Reliability Corporation (NERC), 

and the Federal Energy Regulatory Commission (FERC). Emissions data from the EPA are 

carefully integrated with generation data from EIA to produce useful values like pounds per 

megawatt-hour (lb/MWh) of emissions, which allows direct comparison of the environmental 

attributes of electricity generation. Although 2012 eGRID data had not yet been released, the 

EPA applied its eGRID methodology for matching the publically available and reported 2012 

emissions and generation data. The EPA relies on this most recent data to calculate state goals. 

The state level totals for each technology category described in the above bullets are intended to 

reflect the electric generating units (EGUs) meeting the following criteria:3

In general, a covered EGU is a stationary combustion turbine, steam generating unit or IGCC that

is: (1) capable of combusting more than 250 MMBtu/h heat input of fossil fuel and (2)

constructed for the purpose of supplying one‐third or more of its potential net‐ electric output

capacity and more than 219,000 MWh to any utility power distribution system for sale (that is,

to the grid). In addition, for a stationary combustion turbine to be considered an EGU the heat

input must consist of over 90% natural gas.

4

                                                            

2

 “Other” includes fossil sources that are likely subject to 111(d) rulemaking, but not subject to building block 

abatement measures (e.g., IGCC, low utilization CTs, useful thermal output at cogens). 3

 The set of sources used to compile state-level totals and eventual state goal rates does not constitute an 

applicability determination for any particular EGU. The ultimate universe of EGUs subject to this rulemaking may 

vary from that used in this goal setting exercise and will be determined by the rule’s applicability language and 

actual operating conditions at that plant. 

4 See Preamble and Regulatory text for full description of 111(d) applicability criteria

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“Oother” generation

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Deleted: An covered EGU is a boiler or turbine 

that is: (1) capable of combusting more than 250 

MMBtu/h heat input of fossil fuel, (2) constructed 

for the purpose of supplying more than one-third 

of its potential net- electric output capacity . . . to 

any utility power distribution system for sale (that 

is, to the grid), and (3) constructed for the purpose 

of supplying . . . more than 25 MW net-electric 

output.

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Integrated gasification combined cycles (IGCCs) and combustion turbines (CTs) operating at a 

capacity factor greater than 33% are not part of the inventory of units subjected to building blocks 

one and two. Although they are covered units under the rule, they are excluded from the 

generating technologies that are considered eligible for blocks one and two, and instead 

designated as the “other” category. IGCCs and high utilization CTs present unique circumstances 

and are not subjected to building block application. IGCCs represent a very small sample size of 

three operating plants and have a different utilization pattern and different capital cost profile than 

NGCCs that result in a different set of redispatch economics.5 Likewise, high utilization CTs that 

may be covered by the rule are generally less efficient and have higher emission rates than 

NGCCs, and are therefore generally less cost effective for redispatch purposes. Therefore, 

IGCCs and CTs were not considered for cost-effective deployment of BSER building blocks one 

and two (i.e., there are no redispatch or heat rate improvements assumed to occur at these units). 

The historical generation and emissions from IGCCs and high capacity factor CTs are still 

averaged into the state goal to account for these units as affected sources. Therefore, their 

generation and emissions would be averaged into the state emission rate for compliance purposes. 

This category of affected units that are covered under the 111(d) applicability language, but not 

subjected to BSER technologies, is accounted for in an “other” category. The IGCC and high 

utilization CTs represents a small portion (i.e., less than 1%) of total generation and emissions 

relative to the other affected source categories, and has a small impact on the state goal rates. 

Appendix 1 shows the state-level aggregate data and corresponding calculations applied to 

achieve the state goal rate. 

ii. Data sources for under construction units 

Although the 2012 eGRID data described above forms the starting point for the goal calculation, 

the EPA’s BSER methodology also included under construction nuclear and NGCC capacity that 

was not operating in 2012. For this small subset of “existing” units, EPA relied on its National 

Electric Energy Data System (NEEDS). NEEDS includes basic geographic, operating, capacity, 

and other data on existing or under construction generating units. NEEDS was completely 

updated for EPA's new power sector modeling platform v.5.13. For a description of the sources 

used in preparing NEEDS v.5.13, see Documentation, Chapter 4: Generating Resources.6

  In 

addition to those under construction NGCC units in NEEDS, the EPA identified three other 

NGCC plants and one IGCC plant that were under construction and would likely fit the 

rulemaking’s definition of “existing” unit. These were the Dominion Brunswick plant in Virginia 

(1,358 MW), the Cheyenne Generating Station in Wyoming (220 MW), the Cane Run plant in 

Kentucky (640 MW), and the Kemper IGCC plant in Mississippi (582 MW).

                                                            

5 High utilization CTs are those that operated at a capacity factor of 33% or greater in 2012 6 http://www.epa.gov/powersectormodeling/BaseCasev513.html#needs

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Comment [A8]: Perhaps outside of the scope of

this proposal, but shouldn’t there be considerations

for emissions from reciprocating natural gas engines

used for power generation? One engine generates

<20 MW, but these engines are typically stacked at

one plant to yield >100 MW.

[EPA Response]:  This rule’s applicability is limited

to units “built with the purpose of supplying

electricity to the grid”

Comment [A9]: The previous comment was

referring to reciprocating engines that are built

expressly to supply electricity to the grid

[EPA response] – if those engines met the

applicability criteria, they would ideally be captured

here.  However, this TSD only attempts to reflect

those sources likely meeting the applicability

criteria.  The comment should be directed to the

applicability criteria section of the TSD.  The RICE

units often have restrictions on amount of hourly

use in a given year, that would potentially put them

in a category similar to low utilization CTs that are

not captured in the state goal setting because they

are not built for supplying more than 1/3 of their

electricity to the grid.

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Comment [A10]: Suggesting being very

consistent with the applicable terminology here and

elsewhere, because the issue of existing, under

construction (as of Jan 8, 2014, and hence legally

“existing” for the purposes of this rule), at risk, and

new (i.e., not existing or under construction now)

are important concepts, in order to maintain

logically consistency between RE and Nuclear in this

BSER. See comment below.

[EPA Response]:  Good point, modified language to

convey that while not captured in 2012 data, was ... [6]

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C. State-Level Data Rationale and Significance 

The EPA aggregated plant-level data to the state level for purposes of state-specific emission rate 

goal calculation. Then, for each state, the EPA made BSER-related adjustments to the historical 

state-level data to derive a new emission rate that constitutes the state goal. In making 

adjustments to aggregate state-level data, the EPA is simply suggesting that BSER assumptions 

(e.g., 6% heat rate improvement for the coal fleet) can be achieved on average at the state level. 

The EPA is not making any assertions about specific units or plants. The EPA recognizes the 

uniqueness and complexity of individual power plants, and is aware that there are site-specific 

factors that may prevent some EGUs from achieving performance equal to state-level 

assumptions. Likewise, the EPA also recognizes that some EGUs are capable of, and regularly 

do, achieve performance levels that surpass the BSER values assumed. In any case, the EPA is 

not making those unit-level evaluations in this exercise. The EPA is instead attempting to 

quantify what is feasible at the state level based on application of the BSER values to historic 

state-level data. Therefore, the ability or inability of a specific EGU to under/overachieve the 

assumed technology value cannot be taken, on its own, as an indication of the appropriateness of 

the state goals estimated using this approach. 

 

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3. Example of State Goal Calculation and DiscussionEPA’s methodology for calculating state goals is described in the steps below. The implementation of each step is illustrated in the table below its 

description, using the state of Ohio as an example. The mathematical calculations are fundamental to translating the building blocks into a 

quantifiable state goal.Step 1: Calculation of unadjusted 2012 state fossil emission rate for covered sources As noted above, the EPA begins the state goal emission rate calculation by starting with actual historic data at the state level. Plant-level data aresummed to state-level values describing: coal generation, coal emission rate, NGCC generation, NGCC emission rate, OG steam generation, OG steam emission rate, “other” emissions, “other” generation, and NGCC capacity. These categories are identified as they represent the historical generation that is subject to building block application and/or would likely be subject to the state goal. For combined heat and power (CHP) units that are covered under the rule, the emissions and energy output associated with the useful thermal output not used for electricity production are included in the state goal and would be reported under the 111(d) reporting guidelines if the unit meets the 111(d) applicability criteria. The emissions and energy output associated with the useful thermal output are captured in the “Other” category. The emission rates shown reflect total emissions divided by total net energy output (e.g. net electricity generation + useful thermal output).7 However, only the electricity generation portion of CHP is available for redispatch purposes, and therefore only this portion of the cogeneration operation is reflected in the generation totals for each technology category. There are four coal facilities that co-fired biomass in 2012 that did not report emissions under Part 75, in these cases an emission rate factor is used to estimate stack CO2 emissions attributable to the type of biomass reported.8,9 These technology specific values become the basis for calculating the state’s emission rate. All emission rates provided in the state goal determination are on a net basis. 7 A separate state goal rate is calculated for IPM power sector modeling that reflects total emissions from CHP units, but just their net electricity generation in the denominator. This was necessary as IPM is a dispatch model that optimizes around net electricity demand, so it reflects total emissions associated with cogeneration operation, but only the generation associated with meeting net electricity demand. These corresponding modeling goals expressed in lb/net MWh of electricity generation can be found in the docket file titled “State Goals on a lb/MWh of Electricity Generation Basis”.8 http://www.theclimateregistry.org/downloads/2013/04/2013-Climate-Registry-Default-Emissions-Factors.pdf 9 Please see section VIII of the preamble for more information on biomass in the context of this rulemaking.
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2012 Rate (lbs/MWh) 

2012 mass (lbs) 2012 Generation (MWh) 

2012 Capacity 

Starting 

Covered 

Fossil Rate 

(lbs/MWh) 

A B C D E F G H I J 

Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

Gen 

NGCC 

Gen 

Other 

Gen 

NGCC 

MW 

Ohio 2,126 1,332 963 284,732,506 86,473,075 321,602 20,907,183 214,178 4,343 1,897 

Note, when the values in the above cells shaded green and blue are applied to the equation below, the state’s 2012 “unadjusted fossil” emission rate (or historical fossil rate) for likely covered sources equals 1,897 lb/MWh. 

ሻܹ݄ܯሺ	݊݋݅ݐܽݎ݃݁݊݁	ݕ݃ݎ݁݊݁	݈݅ݏݏ݋݂	݈ܽݐ݋ݐ ሻܱ2ܥ	݈ܾሺ	ݏ݊݋݅ݏݏ݁݉݅	݈݅ݏݏ݋݂	݈ܽݐ݋ݐ ൌ ݁ݐܽݎ	݊݋݅ݏݏ݁݉݅	݈݅ݏݏ݋݂	݁݀ݐݏݑ݆݊ܽ݀ݑ	݈݅ܿܽݎ݋ݐݏ݅ܪ

This can be rewritten as 

Historical fossil emission rate = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions 

 Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

Step 2: BSER Block One - Calculation of state fossil emission rate goal for covered sources resulting from heat rate improvement (HRI) After this historical data is collected for each state, the EPA begins to adjust particular variables to the data to reflect each building block element 

of BSER. The EPA assumes that a 6% heat rate improvement at the facility will directly translate to a 6% reduction in the net CO2 emission rate. 

Therefore, in conjunction with determining state goals under the Proposed state goals in this proposal, the EPA adjusts the state-level coal 
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emission rate (column A) downwards by 6% to reflect the 6% heat rate improvement. In the case of Ohio, this results in a drop from 2,126lb/MWh to 1,999 lb/MWh. This completes the building block 1 treatment for the Proposed state goals.10

Emission Rate (lbs/MWh) 

Emissions (lbs) Generation (MWh) 

2012 Capacity 

State Goal 

Post Block 1 

(lbs/MWh) 

A B C D E F G H I J 

Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

Gen 

NGCC 

Gen 

Other 

Gen 

NGCC 

MW 

Ohio 1,999 1,332 963 284,732,506 86,473,075 321,602 20,907,183 214,178 4,343 1,795 

Note that when the total emission rate is recalculated with heat rate improvement reflected in the adjustment to the state’s coal emission rate, the 

state emission rate drops from 1,897 lb/MWh to 1,795 lbs/MWh. This is not the final state emission rate goal rate, rather an emission rate 

reflecting building block 1 application before moving onto the remaining blocks. The bold areas in the equation below reflect the values that are adjusted from their historical level at this step. State Emission Rate Post Block 1 = (coal gen. x coal emission rate)+ (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” Emissions  Coal gen. + OG gen. + NGCC gen. + “Other” gen. Step 3a: BSER Block Two - Calculation of state fossil emission rate goal resulting from heat rate improvement and redispatch to existing NGCC capacityIn the GHG Abatement Measures TSD, the EPA described how historical 2012 data illustrated that a significant number of NGCC plants had a net generation that was greater than or equal to its nameplate capacity x 8784 * 0.7 – in other words a 70% or greater net capacity factor. It also 10 EPA makes a similar adjustment for the Alternative state goals, but uses a 4% HRI improvement assumption when reducing the coal rate 
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provided analysis supporting a 70% capacity factor as cost-effective and historical data that illustrated the ability to increase utilization at NGCCsunder favorable market conditions. That portion of the TSD also describes the engineering analysis that suggests the average availability of a NGCC is significantly greater than 70%. Building block 2 was intended to reflect the potential redispatch to the state’s existing NGCC fleet up to a 70% capacity factor level. To operationalize the 70% CF ceiling in the state goal setting, the state’s 2012 existing NGCC nameplate capacity is multiplied by 8,784 hours (the number of hours in the 2012 year) and then by 70% to get total potential net NGCC generation at a 70% capacity factor. However, this 70% capacity factor represents a redispatch ceiling, and the state’s NGCC generation is only adjusted up to this ceiling if its historic fossil sources support such a level.11 Therefore, if this ceiling value (MWh) is less than the sum of the state’s 2012 coal, OG steam, and NGCC net generation, the historic NGCC generation is increased to this calculated MWh ceiling value representing the NGCC fleet at a 70% capacity factor, and historic coal and OG steam generation are ramped down by an equivalent amount of generation. If the generation of existing NGCC at a 70% capacity factor is greater than the sum of the state’s 2012 coal, OG steam, and NGCC net generation, the historical NGCC generation is only adjusted to equal the total of the 2012 net fossil generation from these sources. In summary, adjusted NGCC net generation is equal to the lesser of existing NGCC fleet at 70% capacity factor or 2012 total fossil generation from BSER subjected sources. This preserves the historical total covered fossil generation in the state for BSER subjected sources, but reapportions it assuming a 70% state-average capacity factor ceiling for the NGCC fleet. The increase in NGCC generation is subtracted from the coal and OG steam generation in proportion to the state’s historic generation. For example, if coal historically accounted for 90% of the total coal and OG steam generation in the state, then its historic generation would be reduced by 90% of the amount that NGCC generation increases. Likewise, the OG steam generation would be reduced by 10% of the amount by which NGCC generation is increased. 

Emission Rate (lbs/MWh) 

Emissions (lbs) Generation (MWh) 

2012 Capacity 

State Goal 

Post Block 

2.1 

(lbs/MWh) 

A B C D E F G H I J 

Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

Gen 

NGCC 

Gen 

Other 

Gen 

NGCC 

MW 

Ohio 1,999 1,332 963 284,732,506 80,700,563 300,133 26,701,164 214,178 4,342.5 1,739 

11 Fossil sources here refers to those units subject to BSER redispatch building block treatment (i.e., coal, o/g steam, and NGCC)
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Note – in the above example, the total covered fossil generation has not increased in the state from the historic totals shown in step 1. It has only 

been reapportioned assuming a 70% capacity factor for NGCC. NGCC generation is adjusted upwards by approximately 6,000,000 MWh, and 

coal and O/G are adjusted downward by the same amount. This increase in NGCC generation reflects the existing fleet increasing from a 

historical level of approximately 55% CF up to the ceiling of 70% CF. When these updated generation values are folded into the state goal calculation, the emission rate drops from 1,795 lb/MWh in Step 2 to 1,739 lb/MWh. The values in bold below reflect the historic data points that 

have been adjusted to reflect building block implementation at this point in the process.1213State Emission Rate Post Block 2.1 = (coal gen. x coal emission rate)+ (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions 

Coal gen. + OG gen. + NGCC gen. + “Other” gen.

Step 3b: BSER Block Two, cont. - Calculation of state fossil emission rate goal resulting from heat rate improvement and redispatch to existing and under construction NGCC capacityStep 3a is repeated for “under construction” NGCC capacity that would also be considered an existing covered fossil source. For this step, “under construction” is defined as anything that came online in 2013 or that was under construction, site prep, or testing by January 8, 2014. The EPA looked at reported data for 2012 and calculated the average performance of NGCCs that came online in the past 5 years and observed that 55% was the average capacity factor for these units.14 Therefore, the EPA assumed that a 55% capacity factor would be a reasonable representation for the expected generation of “under construction” NGCCs capacity under a business as usual scenario. The EPA conservatively designated the generation associated with this 55% capacity factor as unavailable for redispatch to reduce CO2 (i.e., not qualifying for building block 2), instead, 

reserving that amount of generation potential to meet other system needs presumed to have motivated the construction of the “under constuction” 

12 While a 70% capacity factor ceiling is assumed in the state goal setting exercise, the majority of states are not expected to operate their existing fleet at this 

level in EPA’s projected compliance scenarios.

13 In the Alternative state goal calculations, the EPA makes similar adjustments to the historic data but utilize a 65% capacity factor ceiling in place of the 70% CF shown above 14 http://ampd.epa.gov/ampd/

4,342.5 MW x 8784 hours x 70% CF = 26,701,164
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NGCCs. Because these sources are nevertheless covered under the state emission rate goal, the emissions and generation from this 55% generation are added to the “other” category and averaged into the state goal calculation. The EPA assumes that while these units would operate at 

55% capacity factor under a business as usual scenario, the average availability for these units is greater than 55%, and they too could ramp up to 

70% CF ceiling, on average, under a BSER framework and displace relatively higher CO2-emitting generation. Thus, 15% of their ultimate CF 

(70% - 55%) is assumed to be available for redispatch purposes. The MWh associated with this 15% additional CF displaces coal and OG steam generation in the same manner as in step 3a. 

The portion of the “under construction” NGCC unit’s generation that is not considered available for redispatch (i.e., the first 55%) is captured in the “other” category. The generation and emissions from these sources are still included in the emission rate quantified as the state goal by averaging in their unadjusted emissions and generation. For “under construction” NGCC units that have no 2012 historical data, the generation associated with the 55% baseline capacity factor is obtained by using the “under construction” capacity and historical average emission rate for NGCCs in the state.15 The emissions total for these units is calculated by multiplying the generation at a 55% CF by the average emission rate for existing NGCCs in the state. 

2012 Rate (lbs/MWh) 

2012 mass (lbs) 2012 Generation (MWh) 

2012 Capacity 

"En Route" 

NGCC 

State Goal 

Post Block 

2.2 

(lbs/MWh) 

A B C D E F G H I J K 

Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG Steam Gen 

NGCC Gen Other Gen 

NGCC 

MW 

NGCC 

MW 

Ohio 1,999 1,332 963 2,791,474,084 79,993,008 297,502 27,411,350 2,818,195 4,343 539 1,715 

15 Note, both Wyoming and Kentucky had “en route” NGCC capacity, but did not have existing covered NGCC in the state from which a proxy emission rate could be derived for the “en route” capacity. Therefore, the nationwide average NGCC emissions rate of 907 lb/MWh became the assumed emission rate for the “under construction” NGCC in these two states. 

4,343 MW x 8784 hours x 70% CF = 26,701,164

539 x 8784 x 15% CF = 710,186

Total NGCC = 27,411,350539 x 8784 x 55% CF =2,604,017Total “other”= 2,604,017 + 214,178 = 2,818,195
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Note that when the total emission rate is recalculated to reflect the “under construction”NGCC capacity, the state’s emission rate at this step drops from 1,739lb/MWh to 1,715 lbs/MWh. This is not the final state emission rate goal rate, rather an interim rate reflecting building blocks one and two application before moving onto the remaining blocks. The bold areas in the equation below reflect the values that are adjusted from their 

historical level at this stage. Note the “Other” category is bolded here as it reflects the addition of the 55% utilization of under construction 

NGCC.State Emission Rate post block 2.2 = (coal gen. x coal emission rate)+ (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

Step 4a: BSER Block Three - Calculation of state fossil emission rate goal resulting from heat rate improvement, redispatch to existing and under construction NGCC capacity, and under construction and at risk nuclear In Step 4a, the total under construction nuclear capacity is determined.16 Additionally, an amount of the nuclear capacity that is “at risk” of being retired is identified as approximately 5.8% of the nuclear fleet (see GHG Abatement Measures TSD for further discussion on how the percent assumption was derived). This under construction and at risk nuclear capacity was incorporated into the state goals as zero emitting generation. This was achieved by applying a 90% capacity factor to the nuclear capacity identified as under construction or “at risk” and then applying the resulting MWh figure into the denominator of the state goal calculation. Nuclear is not considered a “dispatchable” resource as is NGCC capacity. That is, its utilization will remain fairly constant in both a business-as-usual and policy scenario due both its low variable operating cost relative to fossil sources and technical limitations regarding start-up and shut-down time. The differing dispatch economics between NGCC and nuclear leads to a different treatment in the goal setting. Existing nuclear is not assumed to increase generation in the same manner as the NGCC fleet is assumed capable of in the above steps. Instead of redispatching from coal to nuclear in the same fashion as the previous steps, the expected generation for under construction and “at risk” nuclear is simply added to the state goal denominator – resulting in a lower state goal emission rate. However, it is important to note that this “under construction and preserved” nuclear capacity is also part of the inventory that the state can count towards compliance with its state goal (i.e., zero emitting generation that can be averaged with that of the covered fossil sources in order to obtain a rate that is equal to or less than the state emission rate goal). 16 Watts Bar in TN, Vogtle in GA, and Summer in SC 
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Emission Rate (lbs/MWh) 

Emission (lbs) Generation (MWh) 

2012 Capacity 

"Under 

Construction

" NGCC 

Under 

Construction 

and “at risk” 

nuclear 

State Goal 

Post Block 

3.1 

(lbs/MWh) 

A B C D E F G H I J K L 

Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG Steam 

Gen NGCC Gen Other Gen 

NGCC 

MW NGCC MW MWh 

Ohio 1,999 1,332 963 

2,791,474,08

4 79,993,008 297,502 27,411,350 2,818,195 4,343 539 993,077 1,699 

Ohio has 0 MW of under construction nuclear and 125.617 MW of “at risk” nuclear capacity share as described in the “GHG Abatement Measures TSD”referred to as Nuclearuc+ar in the equation below. This results in an expected nuclear generation amount of 933,077 MWh that is incorporated into the state goal calculation (based on 90% capacity factor). When this value is added into the state goal calculation, the state’s emission rate drops from 1,715 lb/MWh to 1,699 lb/MWhState Emission Rate Post Block 3.1 = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + NuclearUC+AR gen. 

Step 4b: BSER Block Three, cont. - Calculation of state fossil emission rate goal resulting from heat rate improvement, redispatch to existing and under construction NGCC capacity, under construction and at risk nuclear, and Renewable (RE)
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The GHG Abatement Measures TSD describes how the RE generation total for each state was derived from a combination of existing renewable generation in the state and target RE levels informed by existing Renewable Portfolio Standards (RPS) in the region. Although the amount of assumed RE generation varies by state to reflect the different existing portfolios of renewable resources and the amount of renewable fuels available in different regions of the country, the nationwide average assumed under the Proposed state goals is approximately 13% RE by the end of 2029.17 A potential RE generation value is calculated for each state annually for all years between 2020-2029 to reflect the annual growth as states move toward a particular regional RE benchmark. The state-specific RE generation values that relate to this goal nationwide average are available in the Excel attachment to this TSD and the GHG Abatement Measures TSD. These RE MWh totals include both existing renewable resources in the state and new renewable generation. 

Emission Rate (lbs/MWh) 

Emissions (lbs) Generation (MWh) 

2012 Capacity 

"Under 

construction

" NGCC 

Under 

Construction 

and at risk 

Nuclear 

Existing 

and New 

RE 

State 

Goal Post 

Block 3.2 

(lbs/MWh

) 

A B C D E F G H I J K L M 

Coal Rate 

OG Steam 

Rate 

NGC

C 

Rate 

Other 

Emissions Coal Gen 

OG Steam 

Gen NGCC Gen Other Gen 

NGCC 

MW NGCC MW MWh MWh 

Ohio 1,999 1,332 963 2,791,474,084 

79,993,008 297,502 27,411,350 2,818,195 4,343 539 993,077 

13,775,59

4 1,512 

Ohio had 1,738,622 MWh of RE in 201218 (approximately 1% of total net generation) and would grow to 13,775,594 MWh by 2029 (approximately 10.6% of current net generation) under the building block three assumptions. This 13,775,594 MWh of RE generation would be added into the state goal by adding it in the denominator. The RE value and resulting state goal shown above reflect the 2029 year. When this is added into the state goal calculation, the state’s emission rate drops from 1,699 lb/MWh to 1,512 lb/MWh.State Emission Rate Post Block 3.2 = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions17 See “GHG Abatement Measures TSD” 18 http://www.eia.gov/electricity/data/state/
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 Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclearuc+ar gen. + RE gen. 

Step 5: BSER Block 4 - Calculation of state fossil emission rate goal resulting from heat rate improvement, redispatch to existing NGCC, “under construction” NGCC, under construction and at risk nuclear, RE, and demand-side EEA state-specific percent value is determined for each state reflecting the amount of total MWh sales that could potentially be avoided through demand-side energy efficiency measures (see GHG Abatement Measures TSD). Annual percentage savings rates for MWh sales are derived for each state for all years between 2020 and 2029 in the Proposed state goals. A different set of annual percent savings are derived for 2020-2024 for the Alternative state goals. Because of the temporal nature of demand-side energy efficiency, this building block, along with RE portion of building block three, are the only BSER components that increase each year. The GHG Abatement Measures TSD explains the rationale and derivation of these annual savings rates. Once these state-specific percent savings rates for sales are derived, they are multiplied by the state’s 2012 historical retail sales and scaled by a factor of 1.0751 to obtain an avoided generation value in MWhs.19 The 7.51% scaling factor effectively converts the retail sales figure into a corresponding total net generation value that accounts for transmission and distribution losses. 20The lesser of 1) this avoided net generation value, or 2) the avoided net generation value multiplied by the state’s generation share of its sales is then applied to the denominator. This last step helps assure that building block four reductions for net importer states are linked to their own instate generation. This step further reduces the state goal. However, the state may also count EE measures towards compliance with its state goal. Therefore, if a state achieves the assumed avoided generation based on EE, it does not have to further lower its emission rate from covered fossil-fuel fired 

generators determined in the previous steps. Instead, adding the avoided generation to the denominator (i.e., averaging in the avoided generation 

at a 0 lbs/MWh emission rate) will lower the state’s emission rate used for compliance with the state goal. 

19 http://www.eia.gov/electricity/data/state/ “Retail Sales of Electricity by State and Sector” 20 The 7.51% scaler represents the historical difference between total net generation of electricity (4,036 TWh) and retail sales of electricity (3,754 TWh). http://www.eia.gov/electricity/state/pdf/sep2010.pdf
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Emission Rate (lbs/MWh) Emission (lbs) Generation (MWh) 

2012 Capacity 

"Under 

Constructio

n" NGCC 

Under 

Construction 

and at risk 

Nuclear 

Existing 

and New 

RE 

Avoided 

Sales via 

demandside EE 

Post 

Block 4 

(lbs/MW

h) 

A B C D E F G H I J K L M N 

Coal 

Rate 

OG 

Steam 

Rate 

NGC

C 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

Gen NGCC Gen 

Other 

Gen 

NGCC 

MW NGCC MW MWh MWh MWh 

Ohio 1,999 1,332 963 2,791,474,084 

79,993,008 297,502 27,411,350 2,818,195 4,343 539 993,077 

13,775,59

4 

16,284,58

4 1,338 

As described in the demand-side energy efficiency section of the GHG Abatement Measures TSD, the 2029 percent of generation savings due to energy efficiency is calculated to be 11.557% in Ohio.21 This value is then multiplied by the retail electricity sales in the state (152,456,864 MWh)22 and multiplied by 1.0751 to reflect the net generation commensurate with these sales (i.e., inclusive of transmission and distribution 

losses). This results in 18,942,382 MWh of avoided generation. This value is then multiplied by 85.97% (Ohio’s share of sales coming from in 

state power generation) to reflect the amount of avoided in-state generation that results from the energy efficiency investments. This final 

adjustment results in 16,284,584 MWh of avoided generation for Ohio that is assumed for 2029. This avoided generation value is added into the 

denominator and results in the state goal being decreased from 1,512 lbs/MWh to 1,338 lbs/MWh. This concludes the application of all four building blocks for the year 2029, and the 1,338 lb/MWh rate reflects Ohio’s adjusted emission rate for the year 2029.State Emission Rate Post Block 4 = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions 

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen.uc+ar + RE gen. + EE gen. 

Steps 6 & 7: Interim and Final State Goals The completion of the previous five steps results in a 2029 emission rate for the state. However, as noted above, the RE and EE assumptions change for each year from 2020 through 2029. Thus this procedure is repeated for each of those years using the corresponding RE and EE 21 11.557% reflects rounded value. See Appendix 1 for actual calculated value of 11.55683...% used to arrive at MWh shown above. Most values shown throughout this example are rounded for visual purposes. See Appendix for unrounded number.22 http://www.eia.gov/electricity/data/state/ 
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assumption for that year. This results in a set of annual adjusted emission rates for the years 2020-2029. However, this rulemaking only issues 

two state goals – an interim and final state goal. Thus, goals are derived by averaging, or taken directly from and the annual adjusted emission rate 

values.  For The Proposed state goals:  Interim State Goal – Average of the adjusted yearly emission rates for the period 2020-2029  Final State Goal – The 2029 emission rate (as calculated above) becomes the state goal for 2030 and each year thereafter  For The Alternative state goals:  Interim State Goal – Average of the adjusted yearly rates for the period 2020-2024 Final State Goal – The 2024 emission rate becomes the state goal for 2025 and each year thereafter The EPA recognizes that the emission rate goals calculated here include measures that may yield reductions in mass emissions but may not yield emission rate reductions in practice when observing monitored and reported emission and generation data from affected units. As such, it is not fully informative to compare the state goals calculated here to observable emission rates across affected units either historically or in future years. For more discussion about how states can demonstrate compliance with these emission rate goals, please see the “State Plans Considerations TSD”. For more discussion on emission reductions, please see the Regulatory Impact Analysis.Finally, the assumptions used to arrive at each state’s goal are not prescriptive of necessary actions that a state must take. As described in the preamble, these values are used only for calculating a state goal. A state may choose to comply with that state goal through any combination of abatement measures that differ in class and magnitude from those assumed in the state goal calculation.Example of Final State Goal Calculation for Ohio: Final Proposed State Goal Rate for Ohio – ((1,999 x 79,993,008) + (1,332 x 297,502) + (963 x 27,411,350) + 2,791,474,084) = 1,338 lb/MWh ((79,993,008 + 297,502 + 27,411,350 + 2,818,195 + 993,077 + 13,775,594 + 16,284,585) 
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See the accompanying Excel Workbook for all state level data, calculations, and final state level emission rate goals used to calculate the Interim and Final State Goals for Options 1 and 2. This workbook shows all the calculations used to transform the historical covered fossil emission rate to the Interim and Final State Goal (columns BA and BB) for the Proposed state goals, and (columns AL and AM) for the Alternative state goals. 
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APPENDIX 

Appendix 1 - State level goals, underlying state level data, and calculations for The Proposed state 

goals

See “Appendix 1” worksheet in the Excel Attachment titled “State Goal Data and 

 Computation” 

Appendix 2 - State level goals, underlying state level data, and calculations for The Alternative state 

goals

 See “Appendix 2” worksheet in the Excel Attachment titled “State Goal Data and 

 Computation”

*The above referenced workbook has the data and formulas embedded for state goal calculations. 

Therefore, a commenter suggesting an adjustment to a building block assumption or any historic statelevel data can replace the current assumed values with the suggested amount and see the resulting statelevel goal under such assumptions. 

Deleted: Option 1

Deleted: Option 2
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Appendix 3 – Summary of state goals under the proposed Existing Source Performance Standard

Proposed State Goals

State 

Interim Goal 

(2020-2029) 

 Final Goal 

(2030 and 

after) State 

Interim 

Goal 

(2020-

2029) 

 Final Goal 

(2030 and 

after) 

Alabama 1,147 1,059 Montana 1,882 1,771 

Alaska 1,097 1,003 Nebraska 1,596 1,479 

Arizona 735 702 Nevada 697 647 

Arkansas 968 910 

New 

Hampshire 546 486 

California 556 537 New Jersey 647 531 

Colorado 1,159 1,108 New Mexico 1,107 1,048 

Connecticut 597 540 New York 635 549 

Delaware 913 841 North Carolina 1,077 992 

Florida 794 740 North Dakota 1,817 1,783 

Georgia 891 834 Ohio 1,452 1,338 

Hawaii 1,378 1,306 Oklahoma 931 895 

Idaho 244 228 Oregon 407 372 

Illinois 1,366 1,271 Pennsylvania 1,179 1,052 

Indiana 1,607 1,531 Rhode Island 822 782 

Iowa 1,341 1,301 South Carolina 840 772 

Kansas 1,578 1,499 South Dakota 800 741 

Kentucky 1,844 1,763 Tennessee 1,254 1,163 

Louisiana 948 883 Texas 853 791 

Maine 393 378 Utah 1,378 1,322 

Maryland 1,347 1,187 Virginia 884 810 

Massachusetts 655 576 Washington 264 215 

Michigan 1,227 1,161 West Virginia 1,748 1,620 

Minnesota 911 873 Wisconsin 1,281 1,203 

Mississippi 732 692 Wyoming 1,808 1,714 

Missouri 1,621 1,544 

   

Deleted: 53

Comment [A32]: The proposed rule only relates

to the existing fleet of fossil power plants and the

state‐based BSER to implement CO2 rate (and

ultimately mass) reductions.  This is not a CO2

emission rate for EGUs in any state in 2030.  For

instance, if this were the state rate for all EGUs in

2030, then we would be legitimating a whole bunch

of states at 1700 – 1900 lbs/MWhr.  This rule only

relates to reductions from the fossil EGU sources

that exist today, and we have another rule (the

NSPS) for new fossil EGUs.  

At the other end of the spectrum, if this were the

state EGU rate in 2030, then a whole bunch of

states would be extremely hard pressed to build a

new NGCC (even at the NSPS proposed rate of 1000

lb/MWhr), because there state based emission rates

are so low, such as Washington at 235 lb/MWhr.   

And, this is very good reason not to include any new

post 2014 NGCC or even Coal‐CCS in this

denominator.  

[EPA Response]:  Thank you for your comment, we

believe these observations are fully consistent with

the process we have documented here for ... [41]

Deleted: Option 1

Deleted: State ... [42]

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The Alternative State Goals

State 

Interim 

Goal 

(2020-

2024) 

 Final 

Goal 

(2025 

and 

after) State 

Interim 

Goal 

(2020-

2024) 

 Final 

Goal 

(2025 

and 

after) 

Alabama 1,270 1,237 Montana 2,007 1,960 

Alaska 1,170 1,131 Nebraska 1,721 1,671 

Arizona 779 763 Nevada 734 713 

Arkansas 1,083 1,058 New Hampshire 598 557 

California 582 571 New Jersey 722 676 

Colorado 1,265 1,227 New Mexico 1,214 1,176 

Connecticut 651 627 New York 736 697 

Delaware 1,007 983 North Carolina 1,199 1,156 

Florida 907 884 North Dakota 1,882 1,870 

Georgia 997 964 Ohio 1,588 1,545 

Hawaii 1,446 1,417 Oklahoma 1,019 986 

Idaho 261 254 Oregon 450 420 

Illinois 1,501 1,457 Pennsylvania 1,316 1,270 

Indiana 1,715 1,683 Rhode Island 855 840 

Iowa 1,436 1,417 South Carolina 930 897 

Kansas 1,678 1,625 South Dakota 888 861 

Kentucky 1,951 1,918 Tennessee 1,363 1,326 

Louisiana 1,052 1,025 Texas 957 924 

Maine 418 410 Utah 1,478 1,453 

Maryland 1,518 1,440 Virginia 1,016 962 

Massachusetts 715 683 Washington 312 284 

Michigan 1,349 1,319 West Virginia 1,858 1,817 

Minnesota 1,018 999 Wisconsin 1,417 1,380 

Mississippi 765 743 Wyoming 1,907 1,869 

Missouri 1,726 1,694 

   

Deleted: Option

Deleted: 

Deleted: State ... [65]

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Appendix 4 – Blocks 1 & 2 only State Goals

The table below provides the interim and final goals from just blocks 1 and 2, before the introduction of

nuclear, renewable, and EE into the denominator.  Note – there is no difference between the Interim

and Final rates through the first two building blocks as the increasing annual potential only applies to

block 3 and block 4.

Proposed State Goals Alternative State Goals

State

Interim Goal

(2020 ‐ 2029

average)

Final Goal

(2030 and

thereafter)

Interim Goal (2020 ‐ 

2024 average)

Final Goal (2025 and

thereafter)

Alabama 1,329 1,329 1,405 1,405

Alaska 1,252 1,252 1,252 1,252

Arizona 900 900 900 900

Arkansas 1,115 1,115 1,196 1,196

California 838 838 838 838

Colorado 1,521 1,521 1,586 1,586

Connecticut 809 809 812 812

Delaware 1,013 1,013 1,068 1,068

Florida 910 910 991 991

Georgia 1,296 1,296 1,375 1,375

Hawaii 1,751 1,751 1,762 1,762

Idaho 858 858 858 858

Illinois 1,865 1,865 1,924 1,924

Indiana 1,834 1,834 1,883 1,883

Iowa 1,846 1,846 1,900 1,900

Kansas 2,186 2,186 2,230 2,230

Kentucky 1,986 1,986 2,031 2,031

Louisiana 1,099 1,099 1,162 1,162

Maine 848 848 848 848

Maryland 1,868 1,868 1,908 1,908

Massachusetts 886 886 886 886

Michigan 1,511 1,511 1,574 1,574

Minnesota 1,369 1,369 1,446 1,446

Mississippi 843 843 843 843

Missouri 1,784 1,784 1,832 1,832

Montana 2,295 2,295 2,343 2,343

Nebraska 1,941 1,941 1,987 1,987

Nevada 882 882 882 882

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New Hampshire 878 878 878 878

New Jersey 905 905 905 905

New Mexico 1,447 1,447 1,511 1,511

New York 927 927 970 970

North Carolina 1,329 1,329 1,391 1,391

North Dakota 2,226 2,226 2,273 2,273

Ohio 1,714 1,714 1,766 1,766

Oklahoma 1,186 1,186 1,255 1,255

Oregon 852 852 852 852

Pennsylvania 1,480 1,480 1,537 1,537

Rhode Island 918 918 918 918

South Carolina 1,514 1,514 1,576 1,576

South Dakota 1,456 1,456 1,521 1,521

Tennessee 1,798 1,798 1,855 1,855

Texas 1,083 1,083 1,150 1,150

Utah 1,559 1,559 1,614 1,614

Virginia 1,135 1,135 1,216 1,216

Washington 811 811 811 811

West Virginia 1,933 1,933 1,974 1,974

Wisconsin 1,619 1,619 1,689 1,689

Wyoming 2,151 2,151 2,199 2,199

    Deleted: ¶

Proposed State Goals ... [66]
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Appendix 5 – 2012 emission rates and building block application 

The table below provides a block-by-block summary for each state and attempts to compare those rates to 

both the state’s current and business as usual emission rate from relevant sources. It summarizes the 

current state emission rates (highlighted in yellow) and the resulting emission rate following the 

application of each successive BSER building block. Column C shows the 2012 emission rate from 

existing sources that could count towards the state goal. Column C provide an emission rate that can be 

compared the state goal as it covers the same generating sources as those subject to the state goal. 

These block-by-block values are purely illustrative and meant to assist in the understanding of the state 

goals. For example, the table illustrates that block 1 & 2 application has no impact on Idaho’s state goal 

relative to its current emission rate as the state does not have any covered coal sources to which a heat 

rate improvement or redispatch assumption is applied. On the other hand, a state like Ohio does see its 

emission rate decrease based on blocks 1 and 2 assumptions. 

The state goal development blocks are not prescriptive in terms of abatement measures or magnitude of 

that measure. States have the flexibility to select their own portfolio of abatement measures to comply 

with the state goal. 

2012 Emission Rate and Building Block Application for Proposed Final State Goal (2030) 

A B C D E F G 

State 

2012 Fossil 

Rate 

(lbs/MWh) 

2012 Fossil, 

RE, 

NuclearUC+AR Block 1 

Block 1 & 

2

Blocks 1, 

2, & 3 

Blocks 

1,2,3 & 4 

(i.e.,Final 

State 

Goal)

Alabama 1,518 1,444 1,385 1,264 1,139 1,059 

Alaska 1,368 1,351 1,340 1,237 1,191 1,003 

Arizona 1,551 1,453 1,394 843 814 702 

Arkansas 1,722 1,634 1,554 1,058 996 910 

California 900 698 697 662 615 537 

Colorado 1,959 1,714 1,621 1,334 1,222 1,108 

Connecticut 844 765 764 733 643 540 

Delaware 1,255 1,234 1,211 996 892 841 

Florida 1,238 1,199 1,169 882 812 740 

Georgia 1,598 1,243 1,187 1,008 926 834 

Hawaii 1,783 1,540 1,512 1,512 1,485 1,306 

Idaho 858 339 339 339 291 228 

Illinois 2,189 1,894 1,784 1,614 1,476 1,271 

Indiana 1,991 1,924 1,817 1,772 1,707 1,531 

Iowa 2,197 1,552 1,461 1,304 1,472 1,301 

Kansas 2,320 1,940 1,828 1,828 1,658 1,499 

Kentucky 2,166 2,158 2,028 1,978 1,947 1,763 
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Louisiana 1,533 1,455 1,404 1,043 978 883 

Maine 873 437 437 425 451 378 

Maryland 2,029 1,870 1,772 1,722 1,394 1,187 

Massachusetts 1,001 925 915 819 661 576 

Michigan 1,814 1,690 1,603 1,408 1,339 1,161 

Minnesota 2,013 1,470 1,389 999 1,042 873 

Mississippi 1,140 1,093 1,071 809 752 692 

Missouri 2,010 1,963 1,849 1,742 1,711 1,544 

Montana 2,439 2,246 2,114 2,114 1,936 1,771 

Nebraska 2,162 2,009 1,889 1,803 1,652 1,479 

Nevada 1,091 988 970 799 720 647 

New Hampshire 1,119 905 887 710 532 486 

New Jersey 1,035 928 916 811 616 531 

New Mexico 1,798 1,586 1,513 1,277 1,163 1,048 

New York 1,096 978 970 828 652 549 

North Carolina 1,772 1,647 1,560 1,248 1,125 992 

North Dakota 2,368 1,994 1,875 1,875 1,865 1,783 

Ohio 1,897 1,850 1,751 1,673 1,512 1,338 

Oklahoma 1,562 1,387 1,334 1,053 964 895 

Oregon 1,081 717 701 565 452 372 

Pennsylvania 1,627 1,531 1,458 1,393 1,157 1,052 

Rhode Island 918 907 907 907 867 782 

South Carolina 1,791 1,147 1,088 970 866 772 

South Dakota 2,256 1,135 1,067 732 900 741 

Tennessee 2,015 1,581 1,492 1,410 1,322 1,163 

Texas 1,420 1,284 1,235 979 861 791 

Utah 1,874 1,813 1,713 1,508 1,454 1,322 

Virginia 1,438 1,302 1,258 1,047 894 810 

Washington 1,379 756 728 444 298 215 

West Virginia 2,056 2,019 1,898 1,898 1,687 1,620 

Wisconsin 1,988 1,827 1,728 1,487 1,379 1,203 

Wyoming 2,331 2,115 1,988 1,957 1,771 1,714 

*GA, SC, & TN 2012 rates reflect under construction nuclear plants of Vogtle, Summer, and Watts Bar. 

 
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Appendix 6- Description of state-level data development 

The unit-level emissions and generation data derived using the eGRID methodology was relied upon for 

determining state level totals ultimately used in the goal calculation. One notable difference is that 

published editions of eGRID match emissions and generation at the plant level, while the development of 

the state-level data matches emissions and generation at the unit level in order to filter out units that are 

not likely subject to the Rule’s applicability criteria. Also, the data for this state-level data goal setting 

were limited to the following elements at the unit level: CO2 emissions, nameplate capacity, net 

generation, state location, and information used to place the unit in each category. The data sources are 

from reports from units that submit data to the EPA under 40 CFR Part 75, and Energy Information 

Administration data from forms EIA-860 and EIA-923. The data were assembled at the unit level and 

were aggregated to the state-level generation totals, capacity totals, and emission rates for the following 

categories: coal steam, Oil Gas Steam (O/G steam), Natural Gas Combined Cycle (NGCC) and Simply 

Cycle Combustion Turbines (CTs), and Integrated Gasification Combined Cycle (IGCC). The year 2012 

historical values for these categories were then modified for each state to derive the state goal emission 

rates as described in the main body of the TSD. 

Industrial units that are not grid connected are excluded. Units for which fossil fuel was less than 10% of 

the heat input in year 2012 were also excluded. 

For units that report to the EPA under 40 CFR Part 75, reported CO2 emissions were used. These 

emissions are either determined from continuous emissions monitors that measure CO2 concentration and 

stack gas volumetric flow or, for units that combust certain gaseous and liquid fuels, fuel flow meters and 

fuel testing as required under appendix D and E of 40 CFR Part 75. 

For units that do not report to the EPA under 40 CFR Part 75, CO2 emissions are calculated from fuel use 

reported in the EIA-923 and emission factors under EPA’s Inventory of U.S. Greenhouse Gas Emissions 

and Sinks or The Climate Registry Default Emission Factors. If no unit level fuel use exists in the EIA923 dataset and prime mover fuel data exists, and there is more than one unit at a plant that has the same 

prime mover (e.g. steam turbine, combustion turbine, etc.), then prime mover fuel level emissions are 

distributed to each generator in the prime mover by proportionately by nameplate capacity. For most 

cases (where all units in the prime mover would likely be covered by the rule), this apportionment does 

not matter because emissions are summed to the state level. However, if there is a smaller unit in the 

prime mover that would not likely be covered by the rule, then this apportionment may not exactly match 

the amount of fuel actually burned and the associated emissions for each unit. 

Net generation is taken from EIA-923 data. If no unit-level net generation exists in the EIA-923 dataset 

and prime mover fuel data exists, and there are more than one unit at a plant that have the same prime 

mover (e.g. steam turbine, combustion turbine, etc.), then prime mover fuel level net generation is 

distributed to each generator in the prime mover by proportionately by nameplate capacity. 

Logic for determination of source CATEGORY: 

CATEGORY Category Name Includes 

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COALST Coal Steam - likely covered by rule 

Coal is designated as primary fuel. Nameplate capacity 25 

MW or greater or if heat input capacity is 250MMBtu/hr 

or greater 

OGST Oil Gas Steam - likely covered by rule All steam units not in “Coal Steam” category. Nameplate 

capacity 25 MW or greater. 

NGCC 

Natural Gas Combined Cycle Units - likely 

covered by rule. Duct burners and heat 

recovery steam generators are included with 

combustion turbines that are 25 MW. 

NG is primary fuel or if actual fuel use is >90% NG. 

Combustion turbine parts having nameplate capacity 25 

MW or greater. Any associated duct burners and heat 

recovery steam generators are included. 

SST Simple Cycle Combustion Turbines – 25 

MW & likely covered by rule 

Nameplate capacity 25 MW or greater & 33% capacity 

factor & 219,000MWh 

IGCC IGCC IGCCs at: Wabash, Polk, Edwardsport, Kemper23

   

                                                            

23 EPA assumed 800 lb/MWh and 70% capacity factor for the Kemper unit as it was not yet operating in 2012.  

http://www.netl.doe.gov/publications/proceedings/11/co2capture/presentations/4‐Thursday/25Aug11‐

%20Nelson‐Kemper‐Capture%20at%20Kemper%20IGCC.pdf

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Appendix 7 – 2012 Plant-level Data and Unit-level Inventory 

See Appendix 7 Excel attachment titled “Appendix 7 – Plant-level data and unit-level 

inventory” 

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Page 2: [2] Comment [A3] Author 

Appendix 1 – Option 1, Column V sums to 282 TWh for the year 2020.

If biomass is not included, then attaining the additional ~70 TWh in the 2015‐2020 timeframe appears of

moderate stringency. If biomass is included, then states need only meet an additional ~10 TWh in that

timeframe, which appears very conservative. Therefore, if biomass isn’t included in the RE targets, then

EPA’s ruling excludes a major potential GHG abatement tool; if biomass is included in the RE targets,

then the proposed rulemaking should include a higher deployment number in 2020 and for subsequent

years.

[EPA Response]:  Dedicated biomass is included in this total.  RE totals are grown from 2012 levels

starting in 2017, so there are only three years of RE growth assumed to occur by the year 2020 in the

context of quantifying RE for incorporation into state goals.  This methodology is further addressed in

the GHG abatement measures TSD, and this comment is beyond the scope of this goal setting TSD

which deals with just the mechanics of quantifying state goals – not the individual building block

levels themselves.

Page 2: [3] Deleted Author 

Appendix 8 – 2012 unit-level data 

Page 3: [4] Comment [A6] Author 

The discussion on the limits on increased dispatch to NGCC suggests the possibility of evaluating similar constraints

to redispatch away from coal plants – e.g., idling coal and an option for a floor level ‐‐ and the effects on coal

generation in states with mixed coal and NG fossil generation, i.e., zeroing out coal generation in about 10 states.  

These states are evident in the Excel appendix as the zero coal generation post BB2 redispatch.  This would be a

valuable discussion with EPA with access to and familiarity with the Excel file and calculation math.

[EPA Response]:  State goals do not require any particular dispatch pattern, and many of the states that appear

to have no coal generation in the computation of state goals are still projected to maintain some level of coal‐

fired generation in the compliance scenarios described in the RIA.  Also, some of the indicated states are already

expected to fully reduce coal‐fired generation even without the imposition of this rule (e.g., Oregon and

Washington, whose coal‐fired facilities are already scheduled to retire).

Page 3: [5] Deleted Author 

 The RE totals do not reflect existing hydro generation. 

Page 6: [6] Comment [A10] Author 

Suggesting being very consistent with the applicable terminology here and elsewhere, because the issue of

existing, under construction (as of Jan 8, 2014, and hence legally “existing” for the purposes of this rule), at risk,

and new (i.e., not existing or under construction now) are important concepts, in order to maintain logically

consistency between RE and Nuclear in this BSER. See comment below.

[EPA Response]:  Good point, modified language to convey that while not captured in 2012 data, was still legally

an existing unit – so treated as such in state goals
Page 8: [7] Comment [A12] Author 

This approach seems like it might conflict with the approach discussed in the preamble on pages 103‐

104, in the discussion of Building Block 1, which indicates that improvement to useful thermal energy

would also be credited: “Heat rate improvements are changes that increase the efficiency with which an

EGU converts fuel energy to electric energy (and useful thermal energy in the case of units that

cogenerate steam for process use as well as electricity), thereby reducing the amount of fuel needed to

produce the same amount of electricity and lowering the amount of CO2 produced as a byproduct of

fuel combustion.” & “The heat rate of an EGU is the amount of fuel energy input needed (Btu, higher

heating value basis) to produce 1 kWh of net electrical energy output (and useful thermal energy in the

case of cogeneration units).”

Commenters including useful thermal energy when considering cogeneration units.

[EPA Response]:  Thank you, we have revised language here accordingly.

Page 8: [8] Comment [A13] Author 

For purposes of calculating state goals, co‐fired biomass units are presumed to emit CO2 at a level based

on the type of biomass (TSD, p. 8).  It should be noted that the calculations of biomass contributions

may be impacted by future biomass rulemakings.  Further, these future biomass rulemakings could

contribute to future coal unit retirement decisions.  A clarifying statement about future counting of

biomass emissions would be helpful in this context.

[EPA Response]: Biomass related emissions are addressed in the preamble and we have inserted a

footnote with a cross‐reference here.

Page 8: [9] Deleted Author 

Therefore, they will appear slightly higher than the emission rates viewed on a gross generation basis. 

Page 10: [10] Deleted Author 

 2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 2012 Capacit

 A B C D E F G H I 

   Coal Rate 

OG Steam 

Rate 

NGCC 

Rate Other Emissions Coal Gen OG Steam gen NGCC Gen Other Gen NGCC MW

Ohio 2,056 2,196 963 0 84,726,936 343,627 20,907,183 0 4,343 

Page 11: [11] Deleted Author 
 2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 2012 Capacit

 A B C D E F G H I 

   Coal Rate 

OG Steam 

Rate 

NGCC 

Rate Other Emissions Coal Gen OG Steam gen NGCC Gen Other Gen NGCC MW

Ohio 2,056 2,196 963 0 78,956,358 320,223 26,701,164 0 4,343 

Page 13: [12] Deleted Author 

 2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 

2012 

Capacity 

"En Route"

NGCC 

 A B C D E F G H I J 

   Coal Rate 

OG 

Steam 

Rate 

NGCC 

Rate Other Emissions Coal Gen 

OG Steam 

gen NGCC Gen Other Gen NGCC MW NGCC MW

Ohio 2,056 

 

2,196 963 2,506,741,578 78,249,041 317,354 27,411,350 2,604,017 4,343 539 

4,343 MW x 8784 hours x 70% CF = 26,701,164
Page 14: [13] Comment [A17] Author 

For this step‐by‐step equation discussion, I would suggest bolding only those terms that are added in the step that

is being presented. That will highlight the step more clearly.

[EPA – adjustment made, thank you]

Page 14: [14] Comment [A18] Author 

Terminology issue – is this Nuclear at the five reactors actually “new” under the legal terminology, or is it under

construction as of Jan 8 2014 and hence “existing” in the kind of legal language in the NSPS? Or, do we have a mix

of under construction and not quite under construction nuclear?  This is not aimed at being pedantic, because as

you will see under the RE comments below there appears to be a logical inconsistency in the way that this proposal

deals with RE (all existing and new) and nuclear (not existing, but the underconstruction, at risk, and aka “new”.)

[EPA Response]:  We have modified the language accordingly.

Page 14: [15] Comment [A19] Author 

The approach for preserved nuclear plants assumes that those at‐risk plants that will be kept active will

operate at a capacity factor of 90%.  Given the advanced age of these units, that may be an aggressive

assumption.  A capacity factor of 85% may be more prudent.

[EPA Response]:  We have not found any statistically significant correlation between age and capacity factor at

nuclear units.

Page 14: [16] Comment [A20] Author 

?

[EPA Response]:  Modified language accordingly

Page 14: [17] Comment [A21] Author 

4,343 MW x 8784 hours x 70% CF = 26,701,164

539 x 8784 x 15% CF = 710,186

Total = 27,411,350
A little misleading, as the “new and preserved” nuclear is actually added to EPA’s generation of the state goal, and

hence the state is going to have to build and keep the nuclear or else find another source of zero emission MWhr

[EPA Response]:  Good point, modified language

Page 14: [18] Deleted Author 

Therefore, the fossil sources do not necessarily have to lower their own emission rate to help the state 

achieve the lower state goal reflected subsequent to adding in this nuclear technology provided that the 

nuclear capacity continues to operate at a 90% capacity factor provided they maintain the same level of 

nuclear capacity.. 

Page 15: [19] Deleted Author 

 2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 

2012 

Capacity 

"En Route" 

NGCC 

New

Pres

Nu

 A B C D E F G H I J 

  

Coal 

Rate 

OG 

Steam 

Rate 

NGCC 

Rate Other Emissions Coal Gen 

OG Steam 

gen NGCC Gen Other Gen 

NGCC 

MW NGCC MW M

Ohio 

 

2,056 

 

2,196 963 2,506,741,578 78,249,041 317,354 27,411,350 2,604,017 4,343 539 

 1

[

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Page 15: [21] Comment [A22] Author 

Should this number be 1,351,858? (171MW*0.9*8784)? Please check.

[EPA Response]:  Had actually used 171.39 MW *.9*  8760.  But the 8,760 should be updated to 8784 for the

2012 leap year and to be consistent with hrs used elsewhere.  Will update.

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Page 15: [24] Comment [A23] Author 

This value is not what we would normally call nuclear gen since it is only gen from new & preserved capacity. The

most clear and explicit practice to write equations would have this presented with some kind of modifier such as

Nuclear(subscript NP).  

[EPA respone – change made]

Page 15: [25] Comment [A24] Author 
It’s not immediately clear whether biomass is included in building block 3.  To the extent biomass is

included in state RPSs (e.g., NC includes swine and poultry waste in its RPS), commenters expects that it

is, but in that case the level of RE deployment anticipated by EPA in this TSD seems quite low.  In 2012,

non‐hydro RE excluding biomass accounted for 170 TWh of generation, and biomass accounted for an

additional 58 TWh. We expect that current in‐service and in‐construction wind, solar, and geothermal

would add an additional ~40 TWh/year, leading to a total of ~270 TWh.

[EPA Response]:  The quantification of RE for BSER (that is then incorporated here into state goal

calculations) is documented and explained in the GHG Abatement Measures TSD.

Page 16: [26] Deleted Author 

Existing[A2] and new renewable generation is incorporated into the state goal in a similar manner as the 

nuclear generation. Renewable generation has low variable operating cost and utilization that is dictated 

by the renewable resources available. Like nuclear generating capacity, its utilization from renewable 

generating sources is not considered “dispatchable”. In other words, is not expected to vary significantly 

between a business-as-usual scenario and a policy scenario[A3]. Therefore, the generation from these 

sources is added into the denominator in a similar fashion as nuclear. Consequently, all non-hydro RE 

generation (existing and new build) would be eligible for demonstrating compliance with the state goal. 

Page 16: [27] Comment [A25] Author 

This is the apparent logical inconsistency between nuclear and RE.  It would likely be mathematically distorting to

add all existing nuclear under the denominator.  The converse does not overtly appear to be problematic, i.e., to

remove the small amounts of existing non‐hydro RE from the denominator, and a) subtract this existing RE from

the ultimate state goal and b) give the state kudos in the text/table for having this level of existing non‐hydro RE.  

The benefit of subtracting existing non‐hydro RE from the spreadsheet goals would be to maintain logical

consistency with the way we are treating “new” and at risk nuclear, as compared to how we are treating existing

nuclear.   

It is possible that subtracting the existing RE from the ultimate state goals may lead to an inconsistency in the way

the EPA calculated goal appears when place side‐by‐side with specific state mandates in out years.  We would be

happy to discuss this balancing of logical consistency with optics.

[EPA Response]:  Existing RE and existing nuclear are quantified differently because their BSER foundations are

different.  EPA is proposing to include only that portion of existing nuclear in BSER that is at risk of retirement,

whereas EPA is proposing to include total RE generation as part of BSER.  The difference in their quantification

for state goal purposes is consistent with their different circumstances in BSER.

Page 16: [28] Comment [A26] Author 

Yes – we looked at this comparison out to 2030 of base v. policy projections in the RIA, and it is quite disconcerting

that all this effort to empower RE has very little impact in 2030 according to the modeling.  Can EPA explain this –

should we be looking for more RE?

[EPA Response]:  This language was not actually intended to compare the quantity of RE generation represented

in the calculation of state goals with the compliance projections described in the RIA; such a comparison would
be outside the scope of this TSD, which is intended to demonstrate how the state goals are calculated. As such,

we have deleted this language.  That being said, in response to your question, the quantification of individual

BSER measures is not a prescription for what states may actually elect to do when considering all available

measures in developing state plans to demonstrate compliance with state goals.

Page 16: [29] Comment [A27] Author 

This is more a comment for the Goals TSD, but there are three constraints on generating a state’s RE goal: regional

average, state RE starting point, and state historic rate of progress.  The end results are disconcerting differences

between state goals – such as MA at 24% in 2029, and KY at 1.9% in 2029.  

Also, as in the MA and ME examples, one wonders why we are reducing a small number of state RE goals below

what the state has itself set.  

[EPA Response]:  This TSD is focused on the computation of state goals; this building block specific issue is

addressed in the GHG Abatement Measures TSD.

Page 16: [30] Deleted Author 

Option 1 

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Option 1 

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Option 1 

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Option 1 

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Option 1 

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Option 1 

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Option 1 

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Option 1 

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Option 1 

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 2012 Rate (lbs/MWh) 

2012 mass 

(lbs) 2012 Generation (MWh) 

2012 

Capacity 

"En 

Route" 

NGCC 

New and 

Preserved 

Nuclear 

Exi

Ne

Hy

 A B C D E F G H I J K 

  

Coal 

Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

gen 

NGCC 

Gen 

Other 

Gen 

NGCC 

MW 

NGCC 

MW MWh 

Ohio 

 

2,056 

 

2,196 

 

963 

 

2,506,741,578 

 

78,249,041 

 

317,354 27,411,350 

 

2,604,017 4,343 539 

 

1,351,239 13

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Page 16: [35] Comment [A28] Author 

This TSD does not explain another math calculation that sets the denominator requirement for RE MWhr, namely

multiplying the state RE goal by the total state MWhr purchases for 2012, which includes existing hydropower,

nuclear, and RE that exists in 2012.  This strongly differentially impacts a small number of states that have large

hydropower in 2012, e.g., Idaho and Washington, because the relatively substantial new non‐hydro RE goal

requirement (generated because of large existing zero emission hydro) is assigned to a relatively small fossil energy

MWhr rate base.  This is best discussed through looking at details (appendix, graphs) on individual state rate

reductions resulting specifically from BB3.   

[EPA Response]:  Thank you for your comment.  The GHG Abatement Measures TSD documents the process by

which RE generation was quantified for incorporation into state goals.  

Page 16: [36] Deleted Author 

non-hydro 

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non-hydro 

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non-hydro 

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 2012 Rate (lbs/MWh) 

2012 mass 

(lbs) 2012 Generation (MWh) 

2012 

Capacity 

"En 

Route" 

NGCC 

New and 

Preserved 

Nuclear 

Existi

New 

Hydr

 A B C D E F G H I J K L

  

Coal 

Rate 

OG 

Steam 

Rate 

NGCC 

Rate 

Other 

Emissions Coal Gen 

OG 

Steam 

gen 

NGCC 

Gen 

Other 

Gen 

NGCC 

MW 

NGCC 

MW MWh MW

Ohio 

 

2,056 

 

2,196 

 

963 

 

2,506,741,578 78,249,041 

 

317,354 27,411,350 

 

2,604,017 4,343 539 

 

1,351,239 13,77

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Page 22: [41] Comment [A32] Author 

The proposed rule only relates to the existing fleet of fossil power plants and the state‐based BSER to implement

CO2 rate (and ultimately mass) reductions.  This is not a CO2 emission rate for EGUs in any state in 2030.  For

instance, if this were the state rate for all EGUs in 2030, then we would be legitimating a whole bunch of states at

1700 – 1900 lbs/MWhr.  This rule only relates to reductions from the fossil EGU sources that exist today, and we

have another rule (the NSPS) for new fossil EGUs.  

At the other end of the spectrum, if this were the state EGU rate in 2030, then a whole bunch of states would be

extremely hard pressed to build a new NGCC (even at the NSPS proposed rate of 1000 lb/MWhr), because there

state based emission rates are so low, such as Washington at 235 lb/MWhr.   

And, this is very good reason not to include any new post 2014 NGCC or even Coal‐CCS in this denominator.  

[EPA Response]:  Thank you for your comment, we believe these observations are fully consistent with the

process we have documented here for expressing state goals for application to existing sources subject to this

rule.

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State

2020 State

Goal

Interim Goal

(2020‐2029)

Final Goal

(2030 and

after)     State

2020

State

Goal

Interim Goal

(2020‐2029)

Final Goal

(2030 and

after)

Alabama 1,196 1,113 1,024    Montana 2,034 1,900 1,781

Alaska 1,185 1,039 878     Nebraska 1,713 1,587 1,471
Arizona 767 724 691    Nevada 757 697 644

Arkansas 1,077 1,012 950     New Hampshire 630 542 485

California 618 580 558    New Jersey 783 657 531

Colorado 1,254 1,164 1,112     New Mexico 1,188 1,088 1,000

Connecticut 651 588 533    New York 749 647 557

Delaware 985 922 848     North Carolina 1,172 1,064 977

Florida 811 750 692    North Dakota 1,857 1,821 1,788

Georgia 962 885 826     Ohio 1,594 1,468 1,349

Hawaii 1,481 1,388 1,304    Oklahoma 984 916 879

Idaho 264 241 225     Oregon 472 408 375

Illinois 1,512 1,391 1,293    Pennsylvania 1,323 1,200 1,067

Indiana 1,723 1,627 1,549     Rhode Island 866 816 773

Iowa 1,409 1,351 1,310    South Carolina 880 802 736

Kansas 1,728 1,597 1,516     South Dakota 868 794 731

Kentucky 1,955 1,861 1,778    Tennessee 1,336 1,234 1,142

Louisiana 1,170 1,080 993     Texas 1,029 932 855

Maine 445 423 407    Utah 1,446 1,375 1,318

Maryland 1,521 1,325 1,166     Virginia 978 869 793

Massachusetts 732 646 567    Washington 376 294 235

Michigan 1,433 1,337 1,261     West Virginia 1,872 1,766 1,636

Minnesota 948 891 851    Wisconsin 1,363 1,265 1,185

Mississippi 775 717 673     Wyoming 1,897 1,801 1,701

Missouri 1,705 1,621 1,544

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State

2020 State

Goal

Interim Goal

(2020‐2024)

Final Goal

(2025 and

after)     State

2020

State

Goal

Interim Goal

(2020‐2024)

Final Goal

(2025 and

after)

Alabama 1,274 1,243 1,208    Montana 2,084 2,031 1,980

Alaska 1,192 1,142 1,086     Nebraska 1,760 1,710 1,661

Arizona 785 767 751    Nevada 760 736 714

Arkansas 1,153 1,128 1,101     New Hampshire 632 593 553

California 630 611 599    New Jersey 788 740 688

Colorado 1,317 1,274 1,232     New Mexico 1,244 1,203 1,163

Connecticut 664 640 617    New York 799 756 715

Delaware 1,058 1,036 1,010     North Carolina 1,233 1,189 1,145

Florida 818 795 771    North Dakota 1,899 1,887 1,874

Georgia 1,025 992 958     Ohio 1,657 1,611 1,566

Hawaii 1,497 1,464 1,429    Oklahoma 1,061 1,022 986

Idaho 268 259 252     Oregon 483 449 418

Illinois 1,577 1,529 1,484    Pennsylvania 1,389 1,342 1,293

Indiana 1,774 1,738 1,704     Rhode Island 871 854 837

Iowa 1,468 1,447 1,428    South Carolina 921 889 858

Kansas 1,769 1,698 1,644     South Dakota 913 885 856

Kentucky 2,006 1,971 1,937    Tennessee 1,384 1,345 1,307

Louisiana 1,242 1,208 1,171     Texas 1,101 1,059 1,016

Maine 456 448 440    Utah 1,502 1,476 1,451

Maryland 1,573 1,495 1,417     Virginia 1,061 1,011 955

Massachusetts 741 708 675    Washington 389 350 316

Michigan 1,508 1,470 1,434     West Virginia 1,915 1,877 1,835

Minnesota 1,023 1,001 981    Wisconsin 1,444 1,404 1,366

Mississippi 777 754 729     Wyoming 1,941 1,902 1,862

Missouri 1,757 1,726 1,694   

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Proposed State Goals Alternative State Goals
State

Interim Goal (2020 ‐ 

2029 average)

Final Goal (2030

and thereafter)

Interim Rate

(2020 ‐ 2024

average)

Final Rate (2025

and thereafter)

Alabama 1,329 1,329 1,405 1,405

Alaska 1,252 1,252 1,252 1,252

Arizona 900 900 900 900

Arkansas 1,115 1,115 1,196 1,196

California 838 838 838 838

Colorado 1,521 1,521 1,586 1,586

Connecticut 809 809 812 812

Delaware 1,013 1,013 1,068 1,068

Florida 910 910 991 991

Georgia 1,296 1,296 1,375 1,375

Hawaii 1,751 1,751 1,762 1,762

Idaho 858 858 858 858

Illinois 1,865 1,865 1,924 1,924

Indiana 1,834 1,834 1,883 1,883

Iowa 1,846 1,846 1,900 1,900

Kansas 2,186 2,186 2,230 2,230

Kentucky 1,977 1,977 2,025 2,025

Louisiana 1,099 1,099 1,162 1,162

Maine 848 848 848 848

Maryland 1,868 1,868 1,908 1,908

Massachusetts 886 886 886 886

Michigan 1,511 1,511 1,574 1,574

Minnesota 1,369 1,369 1,446 1,446

Mississippi 843 843 843 843

Missouri 1,784 1,784 1,832 1,832

Montana 2,295 2,295 2,343 2,343

Nebraska 1,941 1,941 1,987 1,987

Nevada 882 882 882 882

New Hampshire 878 878 878 878

New Jersey 905 905 905 905

New Mexico 1,447 1,447 1,511 1,511

New York 927 927 970 970

North Carolina 1,329 1,329 1,391 1,391

North Dakota 2,226 2,226 2,273 2,273

Ohio 1,714 1,714 1,766 1,766

Oklahoma 1,186 1,186 1,255 1,255

Oregon 852 852 852 852
Pennsylvania 1,480 1,480 1,537 1,537

Rhode Island 918 918 918 918

South Carolina 1,514 1,514 1,576 1,576

South Dakota 1,456 1,456 1,521 1,521

Tennessee 1,798 1,798 1,855 1,855

Texas 1,083 1,083 1,150 1,150

Utah 1,559 1,559 1,614 1,614

Virginia 1,135 1,135 1,216 1,216

Washington 811 811 811 811

West Virginia 1,933 1,933 1,974 1,974

Wisconsin 1,619 1,619 1,689 1,689

Wyoming 2,145 2,145 2,195 2,195