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1 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

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2 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 P roposed 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 bas is 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.

Deleted: ed targets

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Formatted ... [1]

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Deleted: Option 1 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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3 In EPA’s technical evaluation, reasonable assumpti ons 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 determini ng 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-eff ectiveness 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 CO 2 emission rate goal is informed by state-specific RE and EE values that relate

to its pre-existing RE generation and EE savi ngs 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: emission rate

Deleted: Option 2

Deleted: more moderate Comment [A4]: Initial text implies that option 1

was “immoderate.”

[EPA Response]: Thank you, change made

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

suggest Times New Roman.

[EPA Response]: Thank you, change made

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Deleted: og 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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4 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 t echnology 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 an d 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 peri od, the benefits of an expanded baseline period

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

“hypothetical” year. Consequently, the EPA decide d 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. Deleted:

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Deleted:

Deleted: currently on the ground

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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5  State level NGCC emission rate

 State level NGCC capacity

 “Other” generation

 “ O ther” emissions 2

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 emi ssions 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, in cluding, 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 al lows 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 u ltimate 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 Deleted: o

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

capacity factor greater than 33% are not part of th e 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 a s 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 covere d under the 111(d) applicability language, but not

subjected to BSER technologies

, is accounted for in an “other” category. Th e 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 form s 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). NEED S includes basic geographic, operating, capacity,

and other data on existing or under construc tion 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 Docume ntation, Chapter 4: Generating Resources. 6 In

addition to those under construction NG CC 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/powersectormod eling/BaseCasev513.html#needs Deleted: technology

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,

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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.

Deleted: is

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Deleted:

Deleted: existing 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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7 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 inab ility 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. Deleted: EGUINTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.83.Example of State Goal Calculation and DiscussionEPA’s methodology for calculating state goals is described in thesteps below. The implementation of each step is illustrated in the table below itsdescription, using the state of Ohio as an example.The mathematical calculations are fundamental to translating the building blocks into aquantifiable state goal.Step 1:Calculation of unadjusted 2012 state fossil emission rate for covered sourcesAs noted above, the EPA begins the state goal emission rate calculation by starting with actual historic data at the state level.Plant-level dataaresummed to state-level values describing: coal generation, coalemission rate, NGCC generation, NGCC emission rate, OG steam generation, OGsteam emission rate, “other” emissions, “other” generation, andNGCC capacity. These categories are identified as they represent the historicalgeneration that is subject to building block application and/or would likely be subject to the state goal. For combined heat and power (CHP) unitsthat are covered under the rule, theemissions and energy output associated with the useful thermal output not used for electricity production areincluded in the state goal and would be reported under the 111(d)reporting guidelines if the unit meets the 111(d) applicability criteria. Theemissions and energy output associated with the useful thermal output are captured in the “Other” category. The emission rates shown reflecttotal emissions divided by total net energy output (e.g. net electricity generation + useful thermal output).7However, only the electricitygeneration portion of CHP is available for redispatch purposes,and therefore only this portion of the cogeneration operation is reflected in thegeneration totalsfor each technology category. There are four coal facilities that co-fired biomass in 2012 that did not report emissions under Part75, in these cases an emission rate factor is used to estimate stack CO2emissions attributable to the type of biomass reported.8,9These technologyspecific values become the basis for calculating the state’s emission rate. All emission rates provided in the state goal determination are on a netbasis.7A separate state goal rate is calculated for IPM power sector modeling that reflects total emissions from CHP units, but justtheir net electricity generation in thedenominator. This was necessary as IPMis a dispatch model that optimizes around net electricity demand, so itreflects total emissions associated withcogeneration operation, but only the generation associated with meeting net electricity demand.These corresponding modeling goals expressed in lb/net MWhof electricity generation can be found in the docket file titled “State Goals on a lb/MWh of Electricity Generation Basis”.8http://www.theclimateregistry.org/downloads/2013/04/2013-Climate-Registry-Default-Emissions-Factors.pdf9PleaseseesectionVIIIofthepreambleformoreinformationonbiomassinthecontextofthisrulemaking.Deleted:Emission Rate CalculationComment [A11]:Youmightwanttoaddasectionbeforethisbeingexplicitregardingthefundamentalimportanceofthemathematicalformulatothesecalculations.[EPAResponse]:Thankyou,addedsomelanguagetoemphasize.Deleted:UnitDeleted:isDeleted:Deleted:entire emissions and generationDeleted:output notDeleted:Deleted:. (including that associated with usefulthermal output not for electricity generation)steambased) from the facility are counted whendetermining emission ratesbecause such facilities’entire emissions and generation would be consideredwhen determining compliance with ruleComment [A12]:Thisapproachseemslikeitmightconflictwiththeapproachdiscussedinthepreambleonpages103‐104,inthediscussionofBuildingBlock1,whichindicatesthatimprovementtousefulthermalenergywouldalsobecredited:“HeatrateimprovementsarechangesthatincreasetheefficiencywithwhichanEGUconvertsfuelenergytoelectricenergy(andusefulthermalenergyinthecaseofunitsthatcogeneratesteamforprocessuseaswellaselectricity),therebyreducingtheamountoffuelneededtoproducethesameamountofelectricityandloweringtheamountofCO2producedasabyproductoffuelcombustion.”&“TheheatrateofanEGUistheamountoffuel... [7]Comment [A13]:Forpurposesofcalculatingstategoals,co‐firedbiomassunitsarepresumedto... [8]Deleted:Therefore, they will appear slightlyhigher than the emission rates viewed on a gross... [9]Deleted:the electricity provided to grid portion oftheir generationDeleted:INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.92012 Rate (lbs/MWh)2012 mass(lbs)2012 Generation (MWh)2012CapacityStartingCoveredFossil Rate(lbs/MWh)ABCDEFGHIJCoal RateOGSteamRateNGCCRateOtherEmissionsCoal GenOGSteamGenNGCCGenOtherGenNGCCMWOhio2,1261,332963284,732,50686,473,075321,60220,907,183214,1784,3431,897Note, when the values in the above cells shaded green and blue are applied to the equation below, the state’s 2012 “unadjustedfossil” emissionrate (or historical fossil rate) for likely covered sourcesequals1,897lb/MWh.ൌ ݁ݐܽݎ	݊݋݅ݏݏ݁݉݅	݈݅ݏݏ݋݂	݁݀ݐݏݑ݆݊ܽ݀ݑ	݈݅ܿܽݎ݋ݐݏ݅ܪሻܱ2ܥ	݈ܾሺ	ݏ݊݋݅ݏݏ݁݉݅	݈݅ݏݏ݋݂	݈ܽݐ݋ݐሻܹ݄ܯሺ	݊݋݅ݐܽݎ݃݁݊݁	ݕ݃ݎ݁݊݁	݈݅ݏݏ݋݂	݈ܽݐ݋ݐThis can be rewritten asHistoricalfossilemission rate = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissionsCoal gen. + OG gen. + NGCC gen. + “Other” gen.Step 2: BSER BlockOne- Calculation of state fossil emissionrate goal for covered sources resultingfrom 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 elementof BSER. The EPA assumes that a 6% heat rate improvement atthe facility will directly translate to a 6% reduction in the netCO2emission rate.Therefore, in conjunction with determining state goals undertheProposed state goalsin this proposal, the EPA adjusts the state-level coalDeleted:is equalDeleted:946Formatted:Centered, Space Before: 0 pt,After: 0 ptDeleted:݄:Deletedݕݐ݅ܿ݅ݎݐ݈݁݁ܿ ݈݅ݏݏ݋݂Formatted:Space Before: 0 pt, After: 0 ptFormatted:Font: 10 pt, Underline, ComplexScript Font: 10 ptDeleted:oDeleted:option 1INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.10emission rate (column A) downwards by 6% to reflect the 6% heatrate improvement. In the case of Ohio, this results in a dropfrom 2,126lb/MWh to1,999lb/MWh. This completes the building block 1 treatment forthe Proposed state goals.10Emission Rate (lbs/MWh)Emissions(lbs)Generation (MWh)2012CapacityState GoalPost Block 1(lbs/MWh)ABCDEFGHIJCoal RateOGSteamRateNGCCRateOtherEmissionsCoal GenOGSteamGenNGCCGenOtherGenNGCCMWOhio1,9991,332963284,732,50686,473,075321,60220,907,183214,1784,3431,795Note that when the total emission rate is recalculated with heat rate improvement reflected in the adjustment to the state’s coal emission rate, thestate emission rate drops from 1,897lb/MWh to 1,795lbs/MWh. This is not the final state emission rate goal rate, rather an emission ratereflecting building block 1 application before moving onto the remaining blocks. The bold areas in the equation below reflectthe values that areadjusted from their historical level at this step.State Emission Rate Post Block 1= (coal gen.xcoal emission rate)+ (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” EmissionsCoal 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 toexisting NGCCcapacityIn the GHG Abatement Measures TSD, the EPA described how historical 2012 data illustrated that a significant number of NGCCplantshad a netgeneration that was greater than or equal to its nameplate capacity x 8784 *0.7 – in other words a 70% or greaternet capacity factor. It also10EPA makes a similar adjustment forthe Alternative state goals, but uses a 4% HRI improvement assumption when reducing the coal rateDeleted:87Deleted:2,056Deleted:option 1Deleted:... [10]Formatted:Font: (Default) Times NewRoman, 8 pt, Font color: Black, Complex ScriptFont: Times New Roman, 8 ptDeleted:2012Deleted:2012 massDeleted:2012Formatted:Font: (Default) Times NewRoman, 8 pt, Font color: Black, Complex ScriptFont: Times New Roman, 8 ptDeleted:<object>Formatted:Font: (Default) Times NewRoman, 8 pt, Font color: Black, Complex ScriptFont: Times New Roman, 8 ptDeleted:946Deleted:841Deleted:ageDeleted:¶Deleted:unitsDeleted:option 2INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.11provided analysis supporting a 70% capacity factor as cost-effective and historical data that illustrated the ability to increase utilization atNGCCsunder favorable market conditions. That portion of the TSD also describes the engineering analysis that suggests the average availability of aNGCC issignificantlygreater than 70%. Building block 2 was intended to reflect the potential redispatch to the state’s existing NGCC fleet up to a70% capacity factor level.To operationalize the 70% CF ceiling in the state goal setting, the state’s 2012 existing NGCC nameplate capacity is multipliedby 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 sourcessupport such a level.11Therefore, if this ceiling value (MWh) isless thanthe sum of the state’s 2012 coal, OG steam, and NGCC net generation,the historic NGCC generation is increased to this calculatedMWhceiling value representing the NGCC fleet ata 70% capacity factor, and historiccoal and OG steam generation are ramped down by an equivalent amount of generation. If the generation of existing NGCC at a 70% capacityfactor isgreater thanthe sum of the state’s 2012 coal, OG steam, and NGCC net generation, the historical NGCC generation is only adjusted toequal the total of the 2012 net fossil generation from these sources. In summary, adjusted NGCC net generation is equal to thelesser of existingNGCC fleet at 70% capacity factor or 2012 total fossil generationfrom BSER subjected sources. This preserves the historical total covered fossilgeneration 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 andOG steam generation in proportion to the state’s historic generation. Forexample, if coal historically accounted for 90% of the total coal and OG steam generation in the state, then its historic generation would bereduced by 90% of the amount that NGCC generation increases. Likewise, the OG steam generation would be reduced by 10% of theamount bywhich NGCC generation is increased.Emission Rate (lbs/MWh)Emissions(lbs)Generation (MWh)2012CapacityState GoalPost Block2.1(lbs/MWh)ABCDEFGHIJCoal RateOGSteamRateNGCCRateOtherEmissionsCoal GenOGSteamGenNGCCGenOtherGenNGCCMWOhio1,9991,332963284,732,50680,700,563300,13326,701,164214,1784,342.51,73911Fossil sources here refers to those units subject to BSER redispatch building block treatment (i.e., coal, o/g steam, and NGCC)Deleted:combined cycle unitsComment [A14]:Asnotedabove,wewouldbeinterestedindiscussingtheprosandconsofacoal“floor”thatmightbebasedonhistoricalempiricaldataregardinglowlevelsofcoaldispatchandidling.[EPAResponse]:EPAparticipatedinthisdiscussion.EPA’spowersectormodelingofillustrativecompliancescenariosforthisrule(presentedintheRIA)takeintoaccountreal‐worldlimitationssuchasturndownconstraintsoncoal‐firedunitoperation.Comment [A15]:Thismightnotcapturefullpotentialofredispatch–ifregionalscenarios/modelingisdone,existingNGCCinthesestatescouldpotentiallyincreaseto70%capacityfactorbyexportingtheadditionalgas/re‐dispatchingcoalinothercoal‐heavystates.IsitpossibleforEPAtoprovideitsregionalmodelingofpotentialredispatchforBSER?[EPAResponse]:ThisTSDisfocusedonthecomputationofstategoals;thisbuildingblockspecificissueisaddressedintheGHGabatementmeasuresTSD,Chapter3Deleted:netDeleted:... [11]Formatted:Font: (Default) Times NewRoman, Font color: Black, Complex Script Font:Times New RomanFormatted:Font: (Default) Calibri, Font color:Black, Complex Script Font: Times New RomanDeleted:2012Deleted:2012 massDeleted:2012Formatted:Font: (Default) Times NewRoman, 8 pt, Font color: Black, Complex ScriptFont: Times New Roman, 8 ptDeleted:3INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.12Note – in the above example, the total covered fossil generationhas not increased in the state from the historic totals shownin step 1. It has onlybeen reapportioned assuming a 70% capacity factor for NGCC.NGCC generation is adjusted upwards by approximately 6,000,000 MWh, andcoal and O/G are adjusted downward by the same amount. This increase in NGCC generation reflects the existing fleet increasingfrom ahistorical level of approximately 55% CF up to the ceiling of 70% CF. When these updated generation values are folded into thestate goalcalculation, the emission rate drops from 1,795lb/MWh in Step 2 to 1,739lb/MWh. The values in bold below reflect the historic data points thathave been adjusted to reflect building block implementation at this point in the process.1213State Emission Rate Post Block 2.1= (coal gen. xcoal emission rate)+ (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissionsCoal 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 existingandunder constructionNGCC capacityStep 3ais repeated for “under construction” NGCC capacity that would also be considered anexisting covered fossil source. For this step, “underconstruction” is defined as anything that came online in 2013 or that wasunder construction, site prep, or testing by January 8, 2014. The EPAlooked 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.14Therefore, the EPA assumed that a 55% capacityfactor would be a reasonable representation forthe expected generation of “under construction” NGCCs capacity under a business as usual scenario. The EPA conservatively designated thegeneration 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”12While 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 thislevel in EPA’s projected compliance scenarios.13Inthe Alternativestate 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 above14http://ampd.epa.gov/ampd/4,342.5MWx8784hoursx70%CF=26,701,164Deleted:841Deleted:81Deleted:This completes building block twoapplication.Formatted:Font: Not BoldDeleted:Step 4:Formatted:Font: BoldDeleted:Deleted:“en route”Deleted:en routeDeleted:en routeComment [A16]:Isthisdifferentfrom“existing”underthelegaldefinitionforhowweseparate“new”from“existing”undertheNSPS?Asnotedabove,keepingtheterminologysimpleandconsistentisimportant,unlesstherearesomefundamentaltimingissuesthatweneedtoaddressbetweenthevarioussourcesofMWhrsandhowtheyarecomingonlinearoundtheJan8,2014period.[EPAResponse]:Thedateprovidedhereisindeedthedaterelevanttothelegaldistinctionof“existing”and“new”unitsundertheNSPS;however,inthisdocumentwemustfurtherdistinguishbetween“existing”unitsthatwereoperatingin2012and“existing”unitsthathadnotyetcommencedoperationsin2012,thelatterofwhichwerefertohereas“enroute”capacity.Thissectionexplainstheassumptionswehavetomakeregardinggenerationfrom“enroute”capacitygiventheirlackof2012operationaldata.Deleted:under a business as usual scenarioDeleted:en routeDeleted:en routeFormatted:Font: (Default) Times New RomanDeleted:option 2Formatted:Font: (Default) Times New RomanDeleted:3INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.13NGCCs. Because these sources are nevertheless covered under thestate 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 at55% capacity factor under a business as usual scenario, the average availability for these units is greater than 55%, and theytoo could ramp up to70% 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 coaland OG steamgeneration in the same manner as in step 3a.The portion of the “under construction” NGCC unit’s generation that is not consideredavailable for redispatch(i.e., the first 55%) is captured inthe “other” category. The generation and emissions from these sources are still included in the emission rate quantified as the state goal byaveraging in their unadjusted emissions and generation. For “under construction” NGCC units that have no 2012 historical data, the generationassociated with the 55% baseline capacity factor is obtained by using the“under construction” capacityand historical average emission rate forNGCCs in the state.15The emissions total for these units iscalculated bymultiplying the generation at a 55% CF by the average emission rate forexisting NGCCs in the state.2012 Rate (lbs/MWh)2012 mass(lbs)2012 Generation (MWh)2012Capacity"En Route"NGCCState GoalPost Block2.2(lbs/MWh)ABCDEFGHIJKCoal RateOGSteamRateNGCCRateOtherEmissionsCoal GenOG Steam GenNGCC GenOther GenNGCCMWNGCCMWOhio1,9991,3329632,791,474,08479,993,008297,50227,411,3502,818,1954,3435391,71515Note, both Wyoming and Kentucky had “en route” NGCC capacity, but did not have existing covered NGCC in the state from which aproxy emission ratecould be derived for the “en route” capacity. Therefore, the nationwide average NGCC emissions rate of 907lb/MWh became the assumed emission rate for the“under construction” NGCC in these two states.4,343MWx8784hoursx70%CF=26,701,164539x8784x15%CF=710,186TotalNGCC=27,411,350539x8784x55%CF=2,604,017Total“other”=2,604,017+214,178=2,818,195Deleted:en routeDeleted:subject to BSER abatement measuresDeleted:en routeDeleted:emissions andDeleted:“en route capacity”Deleted:based onDeleted:¶¶¶¶... [12]Formatted:Font: (Default) Times NewRoman, 10 pt, Bold, Complex Script Font:Times New Roman, 10 ptFormatted:Font: (Default) Times NewRoman, 10 pt, Bold, Complex Script Font:Times New Roman, 10 ptFormatted TableFormatted:Font: (Default) Times NewRoman, 8 pt, Font color: Black, Complex ScriptFont: Times New Roman, 8 ptFormatted:Font: (Default) Times NewRoman, 10 pt, Bold, Complex Script Font:Times New Roman, 10 ptFormatted:Font: (Default) Times New RomanDeleted:19Formatted:Font: (Default) Times New RomanDeleted:(net basis)Deleted:en routeFormatted:Font: (Default) Times New RomanMoved (insertion) [1]Moved up [1]:Total=27,411,350¶INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.14Note that when the total emission rate is recalculated to reflect the “under construction”NGCC capacity, the state’s emission rate at this step dropsfrom 1,739lb/MWh to 1,715lbs/MWh. This is not the final state emission rate goal rate, rather an interim rate reflecting building blocks one andtwo application before moving onto the remaining blocks. The bold areas in the equation below reflect the values that are adjusted from theirhistorical level at this stage.Note the “Other” category is bolded here as it reflects the addition of the 55% utilization of under constructionNGCC.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” emissionsCoal gen. + OG gen. + NGCC gen. + “Other” gen.Step4a: BSER Block Three -Calculation of state fossil emission rate goal resultingfrom heat rate improvement, redispatch to existing andunderconstructionNGCC capacity, andunder constructionandat risknuclearIn Step4a, the total under construction nuclear capacity is determined.16Additionally, an amount ofthenuclear capacity that is “at risk” of beingretired is identified as approximately5.8% of the nuclear fleet (see GHG Abatement Measures TSD for further discussion on how the percentassumption was derived). Thisunder constructionandat risknuclear 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 theresulting 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 duebothits low variable operating cost relative tofossil sourcesand technical limitations regarding start-up and shut-down time. The differing dispatch economicsbetweenNGCC and nuclearleads to a different treatment in the goal setting. Existing nuclear is not assumed to increase generation in the same manneras the NGCC fleet isassumed capable of in the above steps. Instead of redispatchingfrom coal to nuclear in the same fashion as the previous steps, the expectedgeneration forunder construction and “at risk”nuclear is simply added to the state goal denominator – resulting in alowerstate goal emission rate.However, it is important to note that this “under constructionand preserved” nuclear capacity is also part of the inventory that the state can counttowards compliance with its state goal (i.e., zero emitting generation that can be averaged with that of the covered fossil sources in order to obtaina rate that is equal to or less than the state emission rate goal).16Watts Bar in TN, Vogtle in GA, and Summer in SCDeleted:en route”Deleted:81Deleted:54Formatted:Font: Not BoldComment [A17]:Forthisstep‐by‐stepequationdiscussion,Iwouldsuggestboldingonlythosetermsthatareaddedinthestepthatisbeingpresented.Thatwillhighlightthestepmoreclearly.... [13]Deleted:5Deleted:en routeDeleted:newDeleted:preservedDeleted:preservedDeleted:5Deleted:existingDeleted:currentDeleted:newComment [A18]:Terminologyissue–isthis... [14]Deleted:preservedComment [A19]:Theapproachforpreserved... [15]Deleted:toDeleted:forDeleted:slightlyDeleted:new and preservedDeleted:vDeleted:loverDeleted:newComment [A20]:?... [16]Comment [A21]:Alittlemisleading,asthe“new... [17]Deleted:theDeleted:inDeleted:Therefore, the fossil sources do not... [18]INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.15Emission Rate (lbs/MWh)Emission(lbs)Generation (MWh)2012Capacity"UnderConstruction" NGCCUnderConstructionand “at risk”nuclearState GoalPost Block3.1(lbs/MWh)ABCDEFGHIJKLCoal RateOGSteamRateNGCCRateOtherEmissionsCoal GenOG SteamGenNGCC GenOther GenNGCCMWNGCC MWMWhOhio1,9991,3329632,791,474,08479,993,008297,50227,411,3502,818,1954,343539993,0771,699Ohio has 0 MW of under construction nuclear and 125.617MW of “at risk” nuclear capacity share asdescribed in the “GHG Abatement MeasuresTSD”referred to as Nuclearuc+arin the equation below. This results in an expected nuclear generation amount of933,077MWh that is incorporatedinto the state goal calculation (based on 90% capacity factor). When this value is added into the state goal calculation, thestate’s emission ratedrops from 1,715lb/MWh to 1,699lb/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” emissionsCoal gen. + OG gen. + NGCC gen. + “Other” gen. + NuclearUC+ARgen.Step4b: BSER Block Three, cont. -Calculation of state fossil emission rate goal resulting from heat rate improvement, redispatch to existingandunder constructionNGCC capacity,under construction and at risknuclear, and Renewable (RE)Deleted:... [19]Formatted... [20]Comment [A22]:Shouldthisnumberbe1,351,858?(171MW*0.9*8784)?Pleasecheck.[EPAResponse]:Hadactuallyused171.39MW*.9*8760.Butthe8,760shouldbeupdatedto... [21]Formatted... [22]Deleted:2012Deleted:2012 massDeleted:2012Deleted:En RouteDeleted:New and Preserved NuclearDeleted:<object>Formatted... [23]Deleted:271Deleted:1,351,239Deleted:54Deleted:733Formatted:Font: Not BoldDeleted:)+Formatted:Font: Not BoldFormatted:Font: Not BoldFormatted:Font: Not BoldFormatted:Font: Not BoldDeleted:N&PFormatted:SubscriptComment [A23]:Thisvalueisnotwhatwe... [24]Deleted:6Comment [A24]:It’snotimmediatelyclear... [25]Deleted:en routeDeleted:new and preservedINTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.16The GHG Abatement Measures TSD describes how the RE generation total for each state was derived from a combination of existingrenewablegeneration in the state and target RE levels informed by existing Renewable Portfolio Standards (RPS) in the region. Althoughthe amount ofassumed RE generation varies by state to reflect the different existing portfolios of renewable resources and the amount of renewable fuelsavailable in different regions of the country, the nationwide average assumed underthe Proposed state goalsis approximately 13% RE by the endof 2029.17A potential RE generation value is calculated for each state annually for all years between 2020-2029 to reflect the annualgrowth asstates move toward a particular regional RE benchmark. The state-specific RE generation values that relate to this goal nationwide average areavailable in the Excel attachment to this TSD and the GHG Abatement Measures TSD. These RE MWh totals include both existing renewableresources in the state and new renewable generation.Emission Rate (lbs/MWh)Emissions(lbs)Generation (MWh)2012Capacity"Underconstruction" NGCCUnderConstructionand at riskNuclearExistingand NewREStateGoal PostBlock 3.2(lbs/MWh)ABCDEFGHIJKLMCoal RateOG SteamRateNGCCRateOtherEmissionsCoal GenOG SteamGenNGCC GenOther GenNGCCMWNGCC MWMWhMWhOhio1,9991,3329632,791,474,08479,993,008297,50227,411,3502,818,1954,343539993,07713,775,5941,512Ohio 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 beadded into the state goal by adding it in the denominator. The RE value and resulting state goal shown above reflect the 2029year. When this isadded into the state goal calculation, the state’s emission rate drops from 1,699lb/MWh to 1,512lb/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” emissions17See “GHG Abatement Measures TSD”18http://www.eia.gov/electricity/data/state/Deleted:Existing and new renewable generation is... [26]Comment [A25]:ThisistheapparentlogicalinconsistencybetweennuclearandRE.Itwouldlikelybemathematicallydistortingtoaddallexistingnuclearunderthedenominator.Theconversedoesnotovertlyappeartobeproblematic,i.e.,toremovethesmallamountsofexistingnon‐hydroREfromthedenominator,anda)subtractthisexistingREfromtheultimatestategoalandb)givethestatekudosinthetext/tableforhavingthislevelofexistingnon‐hydroRE.Thebenefitofsubtractingexistingnon‐hydroREfromthespreadsheetgoalswouldbetomaintainlogicalconsistencywiththewaywearetreating“new”andatrisknuclear,ascomparedtohowwearetreatingexistingnuclear.... [27]Comment [A26]:Yes–welookedatthis... [28]Comment [A27]:Thisismoreacommentforthe... [29]Deleted:Option 1...T...e Proposed state goals is... [30]Deleted:... [31]Formatted... [32]Formatted... [33]Deleted:2012Deleted:2012 massDeleted:2012Deleted:En RouteDeleted:New and PreservedDeleted:Non-HydroDeleted:<object>Formatted... [34]Deleted:non-hydroComment [A28]:ThisTSDdoesnotexplain... [35]Deleted:non-hydro ...E generation would be... [36]Formatted:Font: Not BoldDeleted:)+Formatted... [37]INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.17Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclearuc+argen. + RE gen.Step5: BSER Block 4 -Calculation of state fossil emission rate goal resulting from heat rate improvement, redispatch to existing NGCC, “underconstruction”NGCC, under construction andat risknuclear, RE, anddemand-side EEA state-specific percent value is determined for each state reflecting the amount of total MWh sales that could potentially beavoided throughdemand-side energy efficiency measures (see GHG Abatement MeasuresTSD). Annual percentage savings rates for MWh sales are derived foreach state for all years between 2020 and 2029 in the Proposed state goals. A different set of annual percent savings are derived for 2020-2024forthe Alternative state goals. Because of the temporal nature of demand-side energy efficiency, this building block, along with RE portion ofbuilding block three, are the only BSER components that increaseeach year. The GHG Abatement Measures TSD explains the rationale andderivation of these annual savings rates. Once these state-specific percent savings rates for sales are derived, they are multiplied by the state’s2012 historical retail sales and scaled by a factor of 1.0751 to obtain an avoided generation value in MWhs.19The 7.51% scaling factoreffectivelyconvertsthe 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) theavoided net generation value multiplied by the state’s generationshare of its sales isthen applied to the denominator. This last step helps assurethat building block four reductions for net importer states are linked to theirowninstate generation.This step further reduces the state goal. However, the statemay also count EE measures towards compliance with its state goal. Therefore, if astate achieves the assumed avoided generation based on EE, it does nothave to further lower its emission rate from covered fossil-fuel firedgenerators determined in the previous steps. Instead, adding the avoided generation to the denominator (i.e., averaging in theavoided generationat a 0 lbs/MWh emission rate) will lower the state’s emission rate used for compliance with the state goal.19http://www.eia.gov/electricity/data/state/“Retail Sales of Electricity by State and Sector”20The 7.51% scaler represents the historical difference betweentotal net generation of electricity (4,036 TWh) and retail salesof electricity (3,754 TWh).http://www.eia.gov/electricity/state/pdf/sep2010.pdfFormatted:Font: Not BoldFormatted:Font: Not BoldDeleted:7Deleted:en routeDeleted:preservedDeleted:Deleted:Option 1Deleted:underDeleted:Option 2Deleted:TDeleted:MWhDeleted:covertsDeleted:sComment [A29]:T&Dlossesvaryregionally.Itmaybehelpfultoincorporatethisvariation.[EPAResponse]:EPAdoesnotbelievesuchvariationissignificantenoughtowarrantaddingsuchcomplexityintothestategoalcomputationapproachhere.Comment [A30]:Theremaybeotheroptionstoconsiderthatwouldbemoreappropriate.Commenterslookforwardtodiscussingthis.[EPAResponse]:EPAparticipatedinthisdiscussion.Deleted:anyDeleted:futureDeleted:... [38]Formatted:Font: (Default) Times NewRoman, Font color: Black, Complex Script Font:Times New RomanFormatted:Font: (Default) Times New RomanFormatted:Default Paragraph Font, Font:(Default) Times New RomanFormatted:Font: (Default) Times New RomanINTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.18Emission Rate (lbs/MWh)Emission (lbs)Generation (MWh)2012Capacity"UnderConstruction" NGCCUnderConstructionand at riskNuclearExistingand NewREAvoidedSales viademandside EEPostBlock 4(lbs/MWh)ABCDEFGHIJKLMNCoalRateOGSteamRateNGCCRateOtherEmissionsCoal GenOGSteamGenNGCC GenOtherGenNGCCMWNGCC MWMWhMWhMWhOhio1,9991,3329632,791,474,08479,993,008297,50227,411,3502,818,1954,343539993,07713,775,59416,284,5841,338As described in thedemand-side energy efficiency section of theGHG Abatement Measures TSD, the 2029 percent of generation savings due toenergy efficiency iscalculatedto be 11.557% in Ohio.21This value is then multiplied by the retail electricity sales in the state (152,456,864MWh)22and multiplied by 1.0751 to reflect the net generation commensuratewith these sales (i.e., inclusive of transmission and distributionlosses). This results in 18,942,382 MWh of avoided generation. This value is then multiplied by85.97% (Ohio’s share of sales coming from instate power generation) to reflect the amount of avoided in-stategeneration that results from the energy efficiency investments. This finaladjustment results in16,284,584MWh of avoided generation for Ohio that is assumed for 2029. This avoided generation value is added into thedenominator and results in the state goal being decreased from 1,512lbs/MWh to 1,338lbs/MWh. This concludes the application of all fourbuilding blocks for the year 2029, and the 1,338lb/MWh rate reflects Ohio’sadjustedemission 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” emissionsCoal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen.uc+ar+ RE gen. + EE gen.Steps 6 & 7: Interim and Final State GoalsThe completion of the previousfivesteps results in a 2029 emission rate for the state. However, as noted above, the RE and EE assumptionschange for each year from 2020 through 2029. Thus this procedure is repeated for each of those years using the corresponding RE and EE2111.557% reflects rounded value. See Appendix 1 for actual calculated value of 11.55683...% used to arrive at MWh shown above.Most values shownthroughout this example are rounded for visual purposes. See Appendix for unrounded number.22http://www.eia.gov/electricity/data/state/Deleted:2012Deleted:2012 massDeleted:2012Deleted:En RouteDeleted:New and PreservedDeleted:Non-HydroDeleted:<object>Formatted:Font: (Default) Times NewRoman, Font color: Black, Complex Script Font:Times New RomanFormatted... [39]Deleted:DDeleted:DemandDeleted:assumedDeleted:6Deleted:92.43Deleted:17,507,556Deleted:40Deleted:49Deleted:49Deleted:AdjustedFormatted:Font: Not BoldDeleted:)+Formatted:Font: Not BoldFormatted:Font: Not BoldFormatted:Font: Not BoldFormatted:Font: Not BoldFormatted:Font: Not BoldDeleted:8Deleted:sevenFormatted... [40]INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.19assumption for that year. This results in a set of annual adjusted emission rates for the years 2020-2029. However, this rulemaking only issuestwo state goals – an interimand final state goal. Thus,goals are derived by averaging,or taken directly from and the annual adjusted emission ratevalues.ForThe Proposed state goals:Interim State Goal – Average of the adjusted yearly emission rates for the period 2020-2029Final State Goal – The 2029 emission rate (as calculated above) becomes the state goal for 2030 and each year thereafterForThe Alternative state goals:Interim State Goal – Average of the adjusted yearly rates for the period 2020-2024Final State Goal – The 2024 emission rate becomes the state goal for 2025and each year thereafterThe EPA recognizes that the emission rate goals calculated hereinclude measures that may yield reductions in mass emissions but may not yieldemission rate reductions in practice when observing monitored and reported emission and generation data from affected units. As such, it is notfully informative to compare the state goals calculated here toobservable emission rates across affected units either historically or in futureyears. For more discussion about how states can demonstrate compliance with these emission rate goals, please see the “State PlansConsiderations TSD”.For more discussion on emission reductions, please see the Regulatory Impact Analysis.Finally, the assumptions used to arriveat each state’s goal are not prescriptive ofnecessary actions that a state must take.As described in thepreamble, these values are used only forcalculating a state goal. A state may choose to comply with that state goal through any combination ofabatement 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)Deleted:erimDeleted:Option 1Deleted:Option 2Deleted:9Deleted:(as calculated above)Deleted:30Formatted:Font: (Default) Times New RomanComment [A31]:Andviceversa–maybethiswouldbeagoodspottomentiontheIPMmodelingintheRIA,whichprovidesanoverallestimateoftheactualcumulativeCO2reductionsnationwideby2030.[EPAResponse]:Thankyou.Formatted:Font: (Default) Times New RomanFormatted:Font: (Default) Times New RomanDeleted:¶Formatted:Font: (Default) Times New RomanFormatted:Font: (Default) Times New RomanDeleted:OptioDeleted:– ((2,056 x 78,249,041) + (2,196 x317,354) + (963 x 27,411,350) + 2,506,741,578)= 1,349 lb/MWh¶((78,249,041 + 317,354 + 27,411,350 +2,604,017 + 1,351,239 + 13,755,594 + 17,507,556)Deleted:INTERAGENCYWORKINGCOMMENTSONDRAFTLANGUAGEUNDEREO12866INTERAGENCYREVIEW.SUBJECTTOFURTHERPOLICYREVIEW.20See the accompanying Excel Workbook for all state level data, calculations, and final state level emission rate goals used to calculate theInterimand Final State Goals for Options 1 and 2. This workbook shows all the calculations used to transform the historicalcovered fossilemission rateto the Interim and Final State Goal (columns BA and BB) forthe Proposed state goals, and (columns AL and AM) forthe Alternative state goals.Deleted:oDeleted:option 1Deleted:option 2I NTERAGENCY W ORKING C OMMENTS ON D RAFT L ANGUAGE UNDER EO12866 I NTERAGENCY R EVIEW

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21 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: O p tion 1

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22 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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23 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:

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24 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 Formatted: Font: Not Bold

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25 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: 

### ¶

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26 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 an d 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 Applic ation for Proposed Final State Goal (2030)

A B C D E F G

State 2012 Fossil

Rate

(lbs/MWh) 2012 Fossil,

RE,

Nuclear UC+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 1,763I NTERAGENCY W ORKING C OMMENTS ON D RAFT L ANGUAGE UNDER EO12866 I NTERAGENCY R EVIEW

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27 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

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28 Appendix 6 - De scription 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 emissi ons 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: CO 2 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 CO 2 emissions were used. These

emissions are either determined from continuous emissions monitors that measure CO 2 concentration and

stack gas volumetric flow or, for units that combust ce rtain 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, CO 2 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 ha s 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:

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29

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 , Kemper 23

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/publ ications/proceedings/11/co2capture/presentations/4

‐ Thursday/25Aug11

‐

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‐ Kemper

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30 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”

Formatted: Normal, Indent: Before: 0"

Formatted: Font: BoldPage 2: [1] Formatted Author



## Indent: Before: 0.69", Hanging: 0.19"

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 refl ect existing hydr o 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 goalsPage 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 CO 2 

## 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 view ed on a gross generation basis.

Page 10: [10] Deleted Author

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

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 M W

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

Page 11: [11] Deleted Author2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 2012 Capaci t

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 M W

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 M W

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 = 26,701,164Page 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 Ne w

Pre s

N u

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 gene ration 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 “d ispatchable”. 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.

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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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## Option 1

Page 16: [31] Deleted Author2012 Rate (lbs/MWh) 2012 mass

(lbs) 2012 Generation (MWh) 2012

Capacity "En

Route"

NGCC New and

Preserved

Nuclear Ex i

N e

H y

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 n

New

Hyd r

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 M W

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 13,7 7

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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.

Page 22: [42] Deleted Author



### 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

Page 25: [66] Deleted Author



## 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