### MEMORANDUM

**DATE:** 11/21 /14 **FROM:** Ken Mitchell/EPA Region 4 **TO:** Clean Power Plan for Existing Power Plants; Docket Id: OAR
–2013
- 0602 **SUBJECT:** Discussion of the Clean Power Plan with the Georgia Environmental Protection Division
**SUMMARY :**  Region 4 provided information on the Clean Power Plan to the Georgia Environmental Protection Division on August 1 3 , 2014 . The Clea n Power Plan for Existing Power Plants was p roposed on June 2, 2014. **ATTENDEES :**  **EPA** Beverly Banister/EPA R4 Carol Kemker/EPA R4 Jeaneanne Gettle/EPA R4 Ken Mitchell/EPA R4 David McNeal/EPA R4 David Solomon/EPA OAQPS Lisa Conner/EPA OAQPS Elineth Torres/EPA OAQPS Julia Miller/EPA OAP Erika Wilson/EPA OAP Erich Eichmann/EPA OAP Matt Clouse/EPA OAP Other EPA Staff **External Stakeholders** Albert Pierce/GA EPD Karen Hays/GA EPD Mary Walker/GA EPD Keith Bentley/GA EPD Jud Turner/GA EPD **ATTACHMENT Advance Questions for Discussion of the Clean Power Plan wit**  **h the G**  **eorgia Envi ronmental Protect**  **ion**

**Divis i**  **on on 8 /**  **1 3** **/14 Subject**  **Question Dispatch to Natural**  **Gas CC** Dispatch is currently performed based on economics. What regulatory

mechanism does EPA anticipate states using to require utilities to give priority to CO2 emissions over cost? Implementation of a minimum dispatch requirement for NGCC would have significant impacts on our publically
- owned utilities and their customers (Oglethorpe Power and MEAG Power). **Renewable generation**  **– basis**  **for SE target of 10 %** The SE target of 10% was set based on the NC standard, which covers

both RE and EE generation as opposed to RE only. Is the basis for the 10 % assignment technically correct? **Renewable generation**  **– credit**  **to generator or purchaser**  Who gets credit for r enewable power purchased out
- of
- state? The

state purchasing or the state with the generation? Has EPA changed their position on the answer previously given (which was the state purchasing the power gets the credit)? How are wind and solar quantified for calculation of emissions performance? Are there enforceable compliance mechanisms other than an RPS or EERS? **Modeling** Can EPA’s modelers work with our modelers so that we can evaluate

the modeling runs that EPA did? We would like to see the output fi les in an understandable format and be walked through the modeled compliance scenario. **Mass -**  **based goal** SE states have requested a webinar from EPA Region 4. The current

discussion of methodology in TSD is inadequate. Does EPA plan to calculate an equiv alent mass goal for each state and when might we expect to see it? If EPA is not doing the conversion calculation, when will EPA provide detailed guidance? Is switching from rate
- based goal to mass
- based goal allowed? How and when and how often? Would you have to submit a plan revision every time you switched? **Plan flexibility** Many aspects of the energy infrastructure and technology will

undoubtedly chan ge between now and 2030. States will need some mechanism to adapt our plan to accommodate those changes relatively quickly (i.e. not a 2 year review process). How does EPA envision this working? **Emissions** Rule 60.5770(a)(3): (a)(3) The conversion must represent the tons of**Performance Level**

**(60.5740)** CO2 emissions that are projected to be emitted, in the absence of

emissions standards contained in the plan, if the affected EGUs were to perform at an average lb CO2 /MWh rate equal to the rate

- based goal fo r the state identified in Table 1 of this Subpart.

- Georgia’s rate
- based goal is 834 while our coal emissions rate (after HR improvement) and NGCC emissions rate are 2157 and 841 lbs/MWh, respectively. Even if we dropped coal generation to 0, we would be left with an equivalent emissions rate of 841. This would fail the equivalency test in paragraph (a)(3). No state that operates coal
- fired EGUs and has a goal below 900 lbs/MWh would be able to meet the requirement as stated. Please clarify. **Other questions:**  1. How can a state account for or adjust in the event that a zero emission IPP either shuts down or does not reach expected capacity say in 2025? 2. Does EPA have a planned approach for dealing with some type major disruption in the energy markets th at may occur in the future? Same question for an unexpected shutdown of an existing nuclear plant? 3. What does a federal state plan look like? 4. If two or more states request the two year extension to develop a multistate program and despite good faith efforts , the plan is not completed, how will EPA react and what will the path forward be for the states involved? 5. A state plan will be based on achieving certain levels of HRI, natural gas dispatch, RE, EE, assumed capacity factors for various fuel types and othe r methods that reduce carbon. Will the state be held accountable to meet each component of the plan or simply to meet the final goal? 6. Why did EPA include an interim goal, and why is it so close the final goal? Can states propose an alternative interim goal as long as the final goal is reached in 2030? 7. Can a new source be included as an affected unit for 111(d)?