Statement of Abengoa at EPA hearing on proposed 111d regulations 

Denver, CO 

July 30, 2014 

My name is Ryan Shininger. I am the Director of Engineering for Abengoa Solar. Our US headquarters 

are in Lakewood, Colorado. Abengoa applies innovative technology solutions for sustainability in the 

energy and environment sectors, generating electricity from renewable resources, converting biomass 

into biofuels and producing drinking water from sea water. Abengoa's solar business unit develops and 

applies technologies to generate electricity from the sun using mostly solar thermal electric technologies, 

also known as Concentrating Solar Power or "CSP." 

Abengoa supports the Environmental Protection Agency's use of Section 111(d) of the Clean Air Act to 

reduce carbon dioxide emissions from the power sector and EPA's approach that provides states with the 

flexibility to take advantage of solar as part of a diverse compliance portfolio. We also support including 

solar in the definition of the Best System of Emission Reduction (BSER), as solar is a suite of proven 

technologies that can play a significant role in helping states reach compliance. 

In particular, Concentrating Solar Power (CSP) can be a significant part of Western states' compliance 

plans. CSP uses mirrors to concentrate the radiation from the sun to generate steam to turn a 

conventional steam turbine. This thermal energy can also be stored to produce electricity when it is 

needed, night or day. 

A CSP plant with thermal energy storage offers all of the services provided by fossil-fueled plants —

without carbon and other emissions. CSP plants with thermal energy storage can provide operational 

attributes and other grid services that can assist utilities and grid operators in maintaining grid reliability. 

CSP can be combined with conventional power plants to form hybrid plants. Hybridization lowers 

dependency on conventional fuel and cuts CO2 emissions from fossil plants. CSP also diversifies the 

energy mix and hedges against the volatility of natural gas. 

This technology is commercially available today. Abengoa's Solana is a 280-MW CSP plant with 6 hours 

of thermal energy storage, providing dispatchable energy after sunset or when cloudy. Solana delivers 

enough electricity to supply approximately 70,000 Arizona households and will prevent the emission of 

more than 475,000 tons of CO2 into the atmosphere every year. For example, if a power plant like 

Solana were to displace a coal plant it would prevent the emission of more than 1 million tons of CO2 

every year. 

In addition to clean energy, CSP creates jobs and economic growth throughout the US. Over 70 percent 

of the construction components, products, and services for our Solana and Mojave CSP plants were 

sourced from companies here in the US, involving 300 companies from 31 states. 

For Abengoa, sustainability is the cornerstone of company strategy and we are convinced that CSP with 

thermal energy storage can contribute significantly to strong and diverse 111(d) compliance plans. 

Thank you 

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