– TECHNICAL SUPPORT DOCUMENT –

1 To: Docket EPA-HQ-OAR-2013-0495 Date: July 31, 2015 Subject: Geographic Availability

1 Introduction

Geologic sequestration (GS) is technically feasible in different types of geologic formations including deep saline formations (format ions with high salinity formation fluids) or in oil and gas formations, such as where injected c arbon dioxide (CO 2 ) increases oil production efficiency through a process referred to as enhance d oil recovery (EOR). CO 2 may also be used for other types of enhanced recovery, such as for n atural gas production. Both deep saline and oil and gas formation types are widely available in the United States, although there are some specific geographic exceptions. Additionally, forma tions such as unmineable coal seams also offer the potential for geologic storage. 1

Figure 1 depicts the geographic extent of potential CO 2 sequestration in deep saline formations, oil and gas reservoirs, and unmineable coal seams, as identified by the Department of Energy, National Energy Technology Laboratory (N ETL), Carbon Utilization and Storage Atlas, Fourth Edition (2012). An explanation of the Atlas and NETL methodology is provided in Section 2. Figure 1 also shows the locations of counties wh ere active CO 2 EOR operations are occurring, based on data reported to the EPA Greenhouse Gas Re porting Program (subpart UU -Injection of Carbon Dioxide). Also shown is the area within 1 00 kilometers from potential GS formations. 2 Existing CO 2 pipelines are shown on the map, along with the loc ations of planned pipelines, or pipeline projects that are currently being consider ed. As shown in Figure 1, there are 39 states for which potential onshore and offshore deep salin e formation storage resources have been identified. EOR operations are currently being cond ucted in 12 states. An additional 17 states have geology that may be amenable to EOR operations . There are 18 states within 100
kilometers of an active EOR location and 13 states have operating CO 2 pipelines.

A few states do not have geologic conditions suitab le for GS, or may not be located in proximity to these areas. However, in some cases, d emand in those states can be served by coal-fired power plants located in areas suitable f or GS, and in other cases, coal-fired power plants are unlikely to be built in those areas for other reasons, such as the lack of available coal or state law restrictions against coal-fired power plants. If an area does not have a suitable GS site, EGUs can either transport CO 2 to GS sites via CO 2 pipelines or they may choose to locate their units closer to GS sites and provide electric power to customers through transmission lines. Figure 2 shows the location of high voltage electrical transmission lines (greater than 230 Kilovolts) within the continental United States, an d illustrates the extensive network of power transmission lines available to electric generating facilities.

1 Other types of opportunities include organic shale s and basalt.

2 The distance of 100 kilometers reflects assumption s in DOE-NETL cost estimates which the EPA used for cost estimation purposes. See “Carbon Dioxide a nd Transport and Storage Costs in NETL Studies”, DOE/NETL-2014/1653 (May 2014).– TECHNICAL SUPPORT DOCUMENT –

2 Figure 1 – Geologic Sequestration in the Continenta l United States– TECHNICAL SUPPORT DOCUMENT –

3 Figure 2 – Electrical Transmission Lines Across the Continental United States 3

2 Geologic Sequestration

3 Ventyx Velocity Suite Online. April 2015.– TECHNICAL SUPPORT DOCUMENT –

4 The DOE and the United States Geological Survey (US GS) have independently conducted preliminary analyses of the availability and potent ial GS capacity in the United States.

National Carbon Sequestration Database and Geograph ic Information System (NATCARB) and National Energy Technology Laboratory (NETL) Atlas Storage Resource Estimates

DOE estimates are compiled by the DOE’s National Ca rbon Sequestration Database and Geographic Information System (NATCARB) using volum etric models and published in a Carbon Utilization and Storage Atlas. The resource estimates in the Atlas were developed to provide an
assessment of CO 2 geologic storage potential across the United State s. The latest version of the Atlas, published in November 2012, includes the mos t current and best available estimates of potential GS capacity determined by a methodology a pplied consistently across all seven of the DOE Regional Carbon Sequestration Partnerships (RCS Ps). 4 The methodology defines a CO 2 storage resource estimate as the fraction of pore v olume of porous and permeable sedimentary
rocks available for CO 2 storage and accessible to injected CO 2 via wellbores.

The RCSPs have evaluated CO 2 storage resources in most states. However, the RCS Ps are voluntary organizations and storage potential was n ot assessed in particular states due to a variety of factors: some states did not participate because they do not have adequate storage resources; other states did not assess storage as l ittle oil and gas development has been done in the state due to low resource availability; othe r states did not submit storage assessments as they did not have the expertise nor the data to par ticipate. For example, the deep saline storage potential (including offshore areas) for Al aska, Connecticut, Hawaii, Maine, Massachusetts, Minnesota, Nevada, New Hampshire, Rh ode Island, and Vermont has not been assessed. Similarly, the storage potential of oil a nd gas reservoirs in Alaska, Connecticut, Delaware, Hawaii, Idaho, Iowa, Maine, Massachusetts , Minnesota, Missouri, Nevada, New Hampshire, North Carolina, Oregon, Rhode Island, So uth Carolina, Vermont, and Washington has not been assessed; and unmineable coal seam sto rage potentials in California, Connecticut, Delaware, Hawaii, Idaho, Maine, Massachusetts, Minn esota, Nevada, New Hampshire, New York, North Carolina, Oregon, Rhode Island, South C arolina, South Dakota, and Vermont have not been assessed. Several of these states have a p otential storage resource, but the amount is not currently reflected in the NETL estimates. New Jersey and Wisconsin were assessed and had little to no storage capacity.

The NETL methodology for estimating storage resourc es uses a volumetric approach. The method requires information on the area of each potential saline formation or horizon within a geologic basin along with the formation’s thickness and porosity (pore space). Additionally, other specific parameters unique to o il and gas fields and coal seams are needed to compute the estimated CO 2 storage resource. A storage coefficient (referred to as the efficiency factor) is applied to the theoretical ma ximum volume in an effort to determine what fraction of the pore space can effectively store CO 2 . Each potential storage resource must meet basic criteria including (1) adequate pressure and temperature conditions in the formation to

4 http://www.netl.doe.gov/research/coal/carbon-stora ge/carbon-storage-infrastructure/rcsp– TECHNICAL SUPPORT DOCUMENT –

5 keep the CO 2 liquid or supercritical; (2) presence of a suitabl e seal system, such as a caprock, to
limit vertical flow of the CO 2 to the surface; and (3) a combination of hydrogeol ogic conditions
to isolate the CO 2 within the saline formation. Other factors includi ng isolation (depth) from shallow potable groundwater, the maximum allowed in jection pressure imposed by regulatory agencies to avoid fracturing the formation at the i njection well (reservoir pressure), and caprock or seal capillary entry pressure are also c onsidered. Carbon dioxide storage resource estimates consider only physical trapping of CO 2 (structural trapping, hydrodynamic trapping, and residual trapping). Chemical trapping mechanism s (dissolution and mineralization were not considered in the methodology. A minimum and maximu m storage volume was estimated for each saline resource by applying a low formation ef ficiency factor (only 0.51 percent of the pore space is available for CO 2 storage) and a high efficiency factor (5.5 percent of the available pore space is available for CO 2 storage). A full description of the NETL methodolo gy is presented in “Summary of the Methodology for Development of G eologic Storage Estimates for Carbon Dioxide,” and is available at: http://www.netl.doe. gov/File%20Library/Research/Coal/carbonstorage/natcarb/geologic-storage-estimates-for-carb on-dioxide.pdf.

NATCARB provides access to publically available dat a presented in Atlas. 5 Maps and data files depicting the location and extent of potentia l saline storage areas, oil and gas producing areas, and unmineable coal seams can be downloaded and used for advanced geographic analysis of the data.

The Atlas shows storage potential of approximately 2,296 billion metric tons to more than 20,092 billion metric tons of CO 2 in the United States from deep saline formations, oil and gas reservoirs, and unmineable coal seams. This est imate includes estimates for onshore storage and offshore storage in federal waters. Dee p saline formations offer the largest GS potential; DOE estimates that areas of the United S tates with appropriate geology have a sequestration potential of at least 2,035 billion m etric tons of CO 2 in deep saline formations.
Table 2.1 shows total CO 2 storage resource by state based on analysis by NETL

.

5 http://www.netl.doe.gov/research/coal/carbon-stora ge/natcarb-atlas– TECHNICAL SUPPORT DOCUMENT –

6 Table 1 – Total CO 2 Storage Resource (DOE-NETL) 6

Million Metric Tons*

State Low Estimate High Estimate

ALABAMA 122,490 694,380

ALASKA 8,640 19,750

ARIZONA 130 1,170

ARKANSAS 6,180 63,670

CALIFORNIA 33,890 420,630

COLORADO 37,610 357,190

CONNECTICUT not assessed by DOE-NETL not assessed by DOE-NETL

DELAWARE 40 40

DISTRICT OF COLUMBIA not assessed by DOE-NETL not assessed by DOE-NETL

FLORIDA 102,740 555,010

GEORGIA 145,340 159,050

HAWAII not assessed by DOE-NETL not assessed by DOE-NETL

IDAHO 40 390

ILLINOIS 10,020 116,820

INDIANA 32,020 68,210

IOWA 10 50

KANSAS 10,880 86,340

KENTUCKY 2,920 7,650

LOUISIANA 169,500 2,103,980

MAINE not assessed by DOE-NETL not assessed by DOE-NETL

MARYLAND 1,860 1,930

MASSACHUSETTS not assessed by DOE-NETL not assessed by DOE-NETL

6 The United States 2012 Carbon Utilization and Stor age Atlas, Fourth Edition, U.S Department of Energy

, Office of Fossil Energy, National Energy Technology Laboratory (NETL).– TECHNICAL SUPPORT DOCUMENT –

7 Table 1 – Total CO 2 Storage Resource (DOE-NETL), cont.

Million Metric Tons*

State Low Estimate High Estimate

MICHIGAN 19,050 47,210

MINNESOTA not assessed by DOE-NETL not assessed by DOE-NETL

MISSISSIPPI 145,010 1,185,030

MISSOURI 10 170

MONTANA 84,580 912,720

NEBRASKA 23,770 113,240

NEVADA not assessed by DOE-NETL not assessed by DOE-NETL

NEW HAMPSHIRE not assessed by DOE-NETL not assessed by DOE-NETL

NEW JERSEY 0 0

NEW MEXICO 42,760 359,090

NEW YORK 4,640 4,640

NORTH CAROLINA 1,340 18,390

NORTH DAKOTA 67,090 147,480 Offshore Federal Only 489,840 6,440,090

OHIO 13,460 13,460

OKLAHOMA 56,950 244,550

OREGON 6,810 93,700

PENNSYLVANIA 22,100 22,100

RHODE ISLAND not assessed by DOE-NETL not assessed by DOE-NETL

SOUTH CAROLINA 30,100 34,180

SOUTH DAKOTA 8,760 24,030

TENNESSEE 430 3,860

TEXAS 443,800 4,329,930

UTAH 25,470 240,910

VERMONT not assessed by DOE-NETL not assessed by DOE-NETL

VIRGINIA 440 2,910

WASHINGTON 36,620 496,730

WEST VIRGINIA 16,650 16,650

WISCONSIN 0 0

WYOMING 72,690 684,850
U.S. Total 2,296,680 20,092,180

* States with a “zero” value represent estimates of minimal CO 2 storage resource. States that have not
yet been assessed by DOE-NETL have been identified.– TECHNICAL SUPPORT DOCUMENT –

8 USGS Storage Resource Estimates

In 2013, the USGS completed its evaluation of the t echnically accessible GS resources for

CO 2 in U.S. onshore areas and state waters using proba bilistic assessment. The USGS methodology defines technically accessible storage as the mass of CO 2 that can be stored in the pore volume of the storage formation taking into ac count present-day geologic knowledge and engineering practice and experience. The assessment used a geology-based examination of all sedimentary basins in the onshore and State waters area of the United States that contain potential storage formations that meet specific cri teria including depth (3,000 feet to 13,000 feet deep), thick regional seals, and saline format ion water (total dissolved solids greater than 10,000 milligrams per liter). The storage estimates were divided into buoyant trapping, where

CO 2 can be trapped in structural or stratigraphic clos ures, and residual trapping, where CO 2 can be held in place by capillary pore pressures in are as outside of buoyant traps. Probability percentiles were calculated representing the 5-, 50 -, and 95-percent probabilities, respectively, that the true storage resource is less than the val ue presented. A mean value of storage for each storage type was also calculated. Storage in o il and gas formations was considered in the assessment, however, only the amount of CO 2 at that could replace the volume of known hydrocarbon production was assessed and quantified. This represents a conservative estimate
because it does not include assessment of GS associ ated with enhanced oil recovery (EOR).

Like the NETL methodology, the USGS storage estimat es did not include chemical trapping (mineralization or dissolution) or potenti al storage in shales or basalt. Several basins, including areas of California, Washington, Oregon a nd Idaho were not assessed. The methodology differs from the NETL methodology in th at it does not include an estimate of the

CO 2 storage potential in “unmineable coal seams”, or o ffshore federal waters, and does not consider EOR. Storage estimates were reduced to acc ount for potential USDWs that may be present. A summary of the methodology and results o f the USGS assessment can be found at http://pubs.usgs.gov/circ/1386/.

USGS estimates a mean of 3,000 billion metric tons of subsurface CO 2 sequestration potential from buoyant and residual trapping and 11 billion metric tons from known oil and gas recovery replacement. Storage resources are dominat ed by medium permeability residual trapping resources which accounts for 89 percent of the total resources. The Coastal Plains Region of the United States contains the largest st orage resource of any region. Within the Coastal Plains Region, the resources from the U.S. Gulf Coast area represent 59 percent of the
national CO 2 storage capacity.

Summary of Findings

The DOE and USGS analyses of the availability and p otential CO 2 sequestration capacity in the United States show that the potential for ge ologic sequestration of CO 2 in the United States is large and the resource is widely availabl e throughout the country. These resource– TECHNICAL SUPPORT DOCUMENT –

9 estimates represent the technical maximum potential , although other considerations such as pore space availability and ownership, economics, a nd legal constraints will factor in to which fields are developed within each geographic basin.

Geologic storage in deep saline formations has been identified in onshore and offshore areas of the US in both the NETL and USGS storage a ssessments.

Oil and gas reservoirs are potential CO 2 storage resources because they have held hydrocarbons for thousands to millions of years and hence have properties potentially suitable
for CO 2 storage. The reservoir characteristics of older fi elds are well known as a result of exploration and many years of hydrocarbon productio n and in many areas infrastructure already exists for CO 2 transportation and storage. The NETL and USGS CO 2 storage resource studies include estimates of CO 2 storage in depleted oil and gas fields, and storag e as part of ongoing EOR activities.

In 2011, DOE sponsored a study 7 to analyze the geographic availability of applying EOR in 11 major oil producing regions of the United Sta tes, including several areas that are not currently applying EOR. The study developed a natio nal EOR resource assessment from
reservoir simulations of CO 2 floods of 1,800 onshore reservoirs and over 4,000 off shore sands and found that there is an opportunity to significa ntly increase the application of EOR to areas outside of current operations. The study found that one of the limitations to expanding CO 2 use in EOR is the lack of availability of CO 2 in areas where oil and gas reservoirs are most ame nable

to CO 2 flooding. The EPA analyzed the state-by-state resu lts of the study and identified 17 additional states where oil and gas fields are amen able to EOR.

Many states have coal resources that are uneconomic al to mine or cannot be extracted due to technological barriers. Coal preferentially adsorbs CO 2 over methane, which is naturally found in coal seams and can become trapped, forming the basis for CO 2 storage in coal seams. Enhanced coalbed methane recovery is similar to EOR because it provides an economic benefit from the recovery and sale of the methane gas, whic h helps to offset the cost of CO 2 storage. DOE’s RCSPs have documented the location of approxi mately 56 to 114 billion metric tons of potential CO 2 storage resource in unmineable coal seams in 21 st ates. 8

7 “Improving Domestic Energy Security and Lowering C O2 Emissions with “Next Generation” CO2- Enhanced Oil Recovery”, Advanced Resources Internat ional, Inc. (ARI), 2011. Available at: http://www.netl.doe.gov/research/energy-analysis/pu blications/details?pub=df02ffba-6b4b-4721-a7b4-

04a505a19185.

8 The United States 2012 Carbon Utilization and Stor age Atlas, Fourth Edition, U.S. Department of Energy, Office of Fossil Energy, National Energy Te chnology Laboratory (NETL).– TECHNICAL SUPPORT DOCUMENT –

10 3 CO 2 Pipelines

CO 2 pipelines are the most economical and efficient me thod of transporting large quantities of CO 2

. 9 CO 2 has been transported via pipelines in the United S tates for nearly 40 years. Over this time, the design, construction, op eration, and safety requirements for CO 2 pipelines have been proven, and the U.S. CO 2 pipeline network has been safely used and expanded. Many miles of pipelines are currently und er construction or planned, further expanding the network in the United States.

Existing Pipelines

The Pipeline and Hazardous Materials Safety Admini stration (PHMSA) reported that in 2013 there were 5,195 miles of CO 2 pipelines operating in the United States. This rep resents a 7 percent increase in CO 2 pipeline miles over the previous year and a 38 per cent increase in CO 2 pipeline miles since 2004. Twenty-eight companies c urrently operate CO 2 pipelines in 13 states, to support transportation of natural and anthropoge nic CO 2 from source areas to CO 2 EOR locations. The Cortez pipeline is the longest CO 2 pipeline and begins at the McElmo Dome CO 2 field in southwest Colorado and traverses 502 miles through New Mexico ending at the Denver City Texas CO 2 Hub, where it connect with several other CO 2 pipelines. The Cortez pipeline was constructed in 1982. Other large pipelines connect natural CO 2 sources in south central Colorado, northeast New Mexico, and Mississippi to oil fields in Texas, Oklahoma, New Mexico,
Utah and Louisiana.

Anthropogenic CO 2 from natural gas processing plants, fertilizer pla nts and ethanol facilities is also transported to oil and gas field s through a series of pipelines that are generally shorter than pipelines from natural CO 2 source areas. Large pipelines in Wyoming, Texas an d Louisiana carry anthropogenic gas from gas plants a nd refineries to the EOR projects. Many smaller pipelines carry gas from anthropogenic sour ces to central distribution facilities or to EOR projects, including the examples below:

• Four gas processing plants in the southern part of the Permian Basin in Texas, referred to as the “Val Verde Plants” supply CO 2 for EOR projects in the Permian Basin through an 82 mile pipeline.

• A fertilizer plant in Coffeyville Kansas supplies C O 2 via a 68 mile dedicated pipeline to
the North Burbank Unit in northeast Oklahoma.

• Two separate CO 2 facilities, a fertilizer plant in Borger, TX and a n ethanol plant in Liberal, KS supply CO 2 to several EOR projects in Oklahoma and Texas via 173 miles of dedicated pipelines.

• A fertilizer plant in Velma Oklahoma supplies CO 2 for EOR projects in southern Oklahoma via a 145 mile pipeline.

9 Report of the Interagency Task Force on Carbon Cap ture and Storage (August 2010), page 36.– TECHNICAL SUPPORT DOCUMENT –

11 Planned Pipelines

The increased demand for CO 2 to support EOR projects, and availability of new anthropogenic sources of CO 2 has provided new opportunities for CO 2 transport companies to expand the CO 2 infrastructure. Several companies have recently pr oposed several hundred
miles of dedicated CO 2 pipeline in Colorado, Louisiana, Montana, New Mexi co, Texas, and Wyoming. Some projects are already under constructi on, some are in the permitting and planning stage and some are still in the evaluation and study phase. Examples are identified
below.

Kinder Morgan has reported several proposed pipeli ne projects including the proposed expansion of the existing Cortez CO 2 pipeline, crossing Colorado, New Mexico, and Texas , to
increase the CO 2 transport capacity from 1.35 billion cubic feet pe r day (Bcf/d) to 1.7 Bcf/d, to support the expansion of CO 2 production capacity at the McElmo Dome production facility in
Colorado. The Cortez pipeline expansion is expected to be placed into service in 2015. 10

Denbury reported that the company utilized approxi mately 70 million cubic feet per day (Mcf/d) of anthropogenic CO 2 in 2013 and that an additional approximately 115 M cf/d of anthropogenic CO 2 may be utilized in the future from currently plann ed or future construction of facilities and associated pipelines in the Gulf Coast region. 11 Denbury also initiated transport
of CO 2 from a Wyoming natural gas processing plant in 201 3 and reported transporting approximately 22 Mcf/d of CO 2 in 2013 from that plant alone. 12

Denbury completed the final section of the 325-mil e Green Pipeline for transporting CO 2 from Donaldsonville, Louisiana, to EOR oil fields i n Texas. 13 Denbury completed construction and commenced operation of the 232-mile Greencore P ipeline in 2013; the Greencore pipeline transports CO 2 to EOR fields in Wyoming and Montana. 14 A project being constructed by NRG and JX Nippon Oil & Gas Exploration (Petra Nova) wo uld capture CO 2 from a power plant in Fort

10 “Form 10-K: Annual Report Pursuant to Section 13 or 15(d) of the Security and Exchange Act of 1934, For the Fiscal Year Ended December 31, 2014”, Kinde r Morgan, February 2015. Available at: http://ir.kindermorgan.com/sites/kindermorgan.inves torhq.businesswire.com/files/report/additional/K MI-2014-10K_Final.pdf.

11 “2013 Annual Report”, Denbury, April 2014. Availab le at http://www.denbury.com/files/doc_financials/2013/De nbury_Final_040814.pdf.

12 “CO 2 Sources”, Denbury, 2014. Available at: http://www. denbury.com/operations/rocky-mountainregion/co2-sources-and-pipelines/default.aspx.

13 http://www.denbury.com/operations/gulf-coast-regio n/Pipelines/default.aspx.

14 “CO 2 Pipelines”, Denbury, 2014. Available at: http://ww w.denbury.com/operations/rocky-mountainregion/COsub2-sub-Pipelines/default.aspx.– TECHNICAL SUPPORT DOCUMENT –

12 Bend County, Texas for transport to EOR sites in Ja ckson County, Texas through an 82-mile CO 2 pipeline. 15 The project is anticipated to commence operation i n 2016. 16

4 Coal-by-Wire

As discussed in the proposal, electricity demand in states that may not have geologic sequestration sites may be served by coal-fired ele ctricity generation built in nearby areas with geologic sequestration, and this electricity can be delivered through transmission lines. This method, known as “coal-by-wire,” has long been used in the electricity sector because siting a coal-fired power plant near the coal mine and trans mitting the generation long distances to the load area is generally less expensive than siting t he plant near the load area and shipping the coal long distances.

For example, we noted in the proposal: “There are m any examples where coal-fired power generated in one state is used to supply elec tricity in other states. For instance, historically, nearly 40 percent of the power for th e City of Los Angeles was provided from two coal-fired power plants located in Arizona and Utah . In another example, Idaho Power, which serves customers in Idaho and Eastern Oregon, meets its demand in part from coal-fired power plants located in Wyoming and Nevada.” 79 FR at 147 8.

In this section, we explore in greater detail the issue of coal-by-wire and the ability of demand in areas without geologic sequestration to b e served by coal generation located in areas that have access to geologic sequestration. F igure 1 of this TSD depicts areas of the country with: (1) existing CO 2 pipeline; (2) probable, planned, or under study CO 2 pipeline; (3)
counties with active CO 2 -EOR operations; (4) oil and natural gas reservoirs ; (5) deep saline formations; (6) unmineable coal seams; and (7) area s 100 kilometers from geologic sequestration. As demonstrated by Figure 1, the vas t majority of the country has existing or planned CO 2 pipeline, active CO 2 -EOR operations, the necessary geology for CO 2 storage, or is within 100 kilometers of areas with geologic seques tration. A review of Figure 1 indicates limited areas that do not fall into these categorie s.

As an initial matter, we note that the data include d in Figure 1 is a conservative outlook of potential areas available for the development of CO 2 storage in that we include only areas
that have been assessed to date. Portions of the Un ited States – such as oil and gas storage potential in Alaska - have not yet been assessed an d thus are depicted as not having geological

15 “The West Ranch CO 2 -EOR Project, NRG Fact Sheet”, NRG, 2014. Available at: http://www.nrg.com/documents/business/pla-2014-west -ranch-fact-sheet.pdf.

16 “WA Parish Carbon Capture Project”, NRG, 2015. Ava ilable at: http://www.nrg.com/sustainability/strategy/enhance- generation/carbon-capture/wa-parish-ccsproject/.– TECHNICAL SUPPORT DOCUMENT –

13 formations suitable for CO 2 storage, even though assessment could in fact revea l additional
formations. 17

As one considers the areas in Figure 1 that fall ou tside of the above enumerated categories, in many instances, we find areas with l ow population density, areas that are already served by transmission lines that could deliver coa l-by-wire, and/or areas that have made policy or other decisions not to pursue a resource mix tha t includes coal. In many of these areas, utilities, electric cooperatives, municipalities, a nd other load-serving entities have a history of joint ownership of coal-fired generation outside th e region or contracting with coal and other generation in other areas to meet their demand. Som e of the relevant areas are in RTOs 18 which engage in planning across the RTO, balancing supply and demand in real time throughout the RTO. Accordingly, generating resources in one p art of the RTO such as a coal generator can serve load in other parts of the RTO, as well as lo ad outside of the RTO. As we consider each of these geographic areas here, we make key points as to why this final rule does not negatively impact the ability of these regions to access new c oal generation to the extent that coal is needed to supply demand and/or those regions seek t o include new coal-fired generation in
their resource mix.

Upper Northwest

This region includes a large portion of Idaho, wit h smaller areas in Washington, Oregon, and Montana. The specific areas identified in this region tend to have a lower population density, which would indicate a lower demand for el ectricity and therefore a likely low demand for new coal generation. To the extent that it is n eeded to supply electricity demand, new coal generation can be constructed in areas with geologi c sequestration available and delivered to this region via the highly interconnected western g rid. Washington’s only coal-fired generator –

17 The data in Figure 1 is based on estimates compile d by the DOE’s National Carbon Sequestration Database and Geographic Information S ystem (NATCARB) and published in the United States 2012 Carbon Utilization and Storage A tlas, Fourth Edition. As discussed in the TSD, deep saline formation potential was not assess ed for Alaska, Connecticut, Hawaii, Maine, Massachusetts, Minnesota, Nevada, New Hampshire, Rh ode Island, and Vermont. Oil and gas storage potential was not assessed for Alaska, Connecticut, Delaware, Hawaii, Idaho, Iowa, Maine, Massachusetts, Minnesota, Missouri, Nevada, New Hampshire, North Carolina, Oregon, Rhode Island, South Carolina, Vermont, and Washingt on. Unmineable coal seams were not
assessed for California, Connecticut, Delaware, Hawaii, Idaho, M aine, Massachusetts, Minnesota, Nevada, New Hampshire, New York, North C arolina, Oregon, Rhode Island, South Carolina, South Dakota, and Vermont. We are assumin g for purposes of our analysis here that they do not have storage potential in those formati ons.

18 In this discussion, we use the term RTO to indicat e both ISOs and RTOs.– TECHNICAL SUPPORT DOCUMENT –

14 Centralia - is located in western Washington and bo th of its generating units are scheduled to shut down in the next 10 years. 19

We note that a large portion of this area is served by the Idaho Power, Avista, and Rocky Mountain Power, as well and multiple cooperatives a nd municipalities. Idaho Power and Avista provide good examples of both joint-ownership of co al generation as well as coal-by-wire. Idaho Power is served by three coal plants located in Wyoming, Oregon, and Nevada. 20 Avista’s service territory includes parts of eastern Washing ton and northern Idaho. According to Avista, nine percent of its generation is supplied by coal. 21 Avista owns 15 percent of two of the Colstrip Steam Electric Station units in Colstrip, Montana. 22

Small Areas in Nevada and Utah

This region includes small areas in Nevada and Utah , which have low population density and therefore less electricity demand than other mo re populous areas in the country. Rocky Mountain Power, which is a subsidiary of Berkshire Hathaway Energy, serves much of Utah. Berkshire Hathaway Energy and its subsidiaries and affiliates own coal-fired power plants that generate electricity to serve load. Nevada is serve d by multiple entities including electric cooperatives and municipalities as well as NV Energ y. This region is part of the highly interconnected western grid with transmission lines crossing it, making coal-by-wire readily available. For example, Intermountain Power Agency owns the Intermountain Power Project in western Utah which largely serves Utah and Southern California. 23 Another example is Deseret Power, a regional generation and transmission coope rative, which supplies electricity to its members and other bulk energy customers in Arizona, Colorado, Nevada, Utah, and Wyoming.

19 **Bills in Washington State Seek to End Use of Coal** , N.Y. Times, Feb. 14, 2015, **available at** http://www.nytimes.com/2015/02/15/us/politics/bills -in-washington-state-seek-to-end-use-ofcoal.html?_r=0.

20 Idaho Power, **Coal-Fired Plants**

, **available at** https://www.idahopower.com/AboutUs/EnergySources/Co al/coal.cfm (last visited July 22, 2015). Idaho Power owns shares of the Jim Bridger c oal plant in Wyoming, the Boardman coal plant in Oregon, and the North Valmy coal plant in Nevada. **Id.**

21 Avista, **Avista’s Diverse Energy Mix**

, **available at** https://www.avistautilities.com/inside/resources/en ergymix/Pages/default.aspx (last viewed July 22, 2015).

22 Avista, **Reliable, Lower-Cost Coal**

, **available at** https://www.avistautilities.com/inside/resources/en ergymix/Documents/Reliable,%20LowerCost%20Coal.FS%2011.6.14.pdf (last viewed July 22, 2015).

23 Multiple entities in Utah, including cooperatives, Utah Power & Light Company (PacifiCorp), and numerous municipalities purchase coal-fired gen eration from this facility. Intermountain Power Agency, **Generation Entitlement Shares**

, **available at** http://www.ipautah.com/participants/.– TECHNICAL SUPPORT DOCUMENT –

15 Deseret owns interests in coal generation, as well as its own facility, that it uses to supply this electricity. 24

Southwest

The southwestern region of Figure 1 includes a sect ion of Arizona as well as a small part of New Mexico. As can be seen in Figure 2, this are a has extensive transmission infrastructure, enabling the area to be served by outside coal plan ts. Most of the load in Arizona - including Phoenix, the most populous part of this area - is s erved by the Arizona Public Service (APS) or the Salt River Project, each of which owns shares o f coal plants in other areas with geologic sequestration available. Specifically, Arizona Publ ic Service owns shares of coal plants in Arizona and New Mexico, 25 and Salt River Project owns shares of coal plants in Arizona, New Mexico,
and Colorado. 26 Other entities such as Tucson Electric Power, Tric o Electric Cooperative, UNS Electric, Sulphur Springs Valley Electric Co-op als o have service territories in this area. 27 Mexico has instate coal generation with the majority of th e state having geologic sequestration
available.

Upper Midwest

This region includes Minnesota, most of Wisconsin, the Upper Peninsula of Michigan, and parts of North Dakota, South Dakota, Nebraska, and Iowa. Most of the areas of this region shown in Figure 1 are located in an RTO 28 or are in the process of joining an RTO, 29 which provides open access to transmission service and a large set of resources within the RTO to

24 Deseret Power Electric Cooperative, **Power to Succeed, Now and in the Future**

, **available at** http://www.deseretgt.com/profile/profile.php.

25 APS jointly owns the Four Corners Power Plant on t he Navajo Indian Reservation west of Farmington, New Mexico. APS also owns part of the C holla Power plant in northeastern Arizona and the Navajo Power Plant in northern Arizona. APS

, **Coal-Fueled Power Plants**

, **available at** https://www.aps.com/en/ourcompany/generationtransmi ssion/generation/Pages/home.aspx (last visited July 22, 2015).

26 Salt River Project, **Facts about SRP**

, **available at** http://www.srpnet.com/about/Facts.aspx.

27 Arizona Corporation Commission, **State of Arizona-Electric Map**

, **available at** http://www.azcc.gov/divisions/utilities/electric/ma p-elect.pdf (last visited July 22, 2015).

28 In this discussion, we use the term RTO to indicat e both ISOs and RTOs.

29 FERC, **MISO Electric Market: Overview and Focal** Points, **available at http://www.ferc.gov/market-oversight/mkt-electric/m**  **idwest/elec-mw-reg-des.** pdf ; FERC,
**Southwest Power Pool Electric Market: Overview and Focal Points** 

, **available at** http://www.ferc.gov/market-oversight/mkt-electric/s pp/elec-spp-reg-des.pdf; SPP, **FERC Approves Integrated System Joining SPP**  (Nov. 12, 2014), **available at** http://www.spp.org/publications/FERC%20approves%20I S%20membership.pdf (noting FERC’s approval of the Integrated System, made up of the W estern Area Power Administration-Upper Great Plains, Basin Electric Power Cooperative, and Heartland Consumers Power, joining SPP).– TECHNICAL SUPPORT DOCUMENT –

16 serve load. The two RTOs in this area are MISO and SPP, both of which engage in planning across the RTO, balancing supply and demand in real time throughout the RTO. Accordingly, generating resources in one part of the RTO such as a coal plant often serve load in other parts of the RTO, as well as load outside of the RTO. Bot h MISO and SPP have a number of coal-fired power plants in areas with access to geologic seque stration. If a new coal unit is built in an area with geologic sequestration, this supply can serve load both inside and outside areas with available sequestration. Just as current coal facil ities in SPP and MISO can inject electricity onto the grid and that electricity can serve load in are as without coal facilities, new coal plants built in RTO areas with geologic sequestration available can serve load in areas without sequestration available. For example, Wisconsin is in MISO with the southern part of the state as well as many surrounding areas having geologic s equestration available. Further, this area
has extensive transmission infrastructure that incl udes coal-fired power plants outside of this area (e.g., lignite plants in North Dakota). 30

Central

This area includes small parts of Missouri, Arkansa s, and Tennessee. Parts of this area are in MISO, providing the opportunity to serve loa d through a diverse set of resources including coal-fired electricity, as discussed abov e. The eastern part of this central area is served at wholesale by the Tennessee Valley Authori ty, which is a large federal entity that functions like an RTO with numerous generation asse ts and whose transmission network includes areas with geologic sequestration availabl e. Moreover, this area is crossed by transmission lines and ringed by coal fired power p lants at or near its border.

Southeast

Figure 1 also indicates areas in the southeast that do not have geologic sequestration, including parts of Alabama, Georgia (including Atla nta), South Carolina, and North Carolina. As Figure 2 indicates, this area is served by an exten sive network of transmission infrastructure that can deliver electricity from a diverse resourc e mix. Additionally, most of this area is served by Alabama Power, Georgia Power, Duke Energy Progre ss, and South Carolina Electric and Gas, each of which are large companies with numerous gen erating assets, including coal-fired assets and allowing diverse resources throughout the balan cing authority to serve load.

Mid-Atlantic

Figure 1 indicates that parts of Virginia, Maryland , Pennsylvania, and New Jersey are lacking geologic sequestration. Again, as noted pre viously, Figure 2 indicates that there is
extensive transmission infrastructure in this area that delivers electricity throughout the region. This area is served by PJM, a large RTO. Currently, existing coal-fired units in West Virginia,

30 For example, Basin Electric owns the Antelope Vall ey Station, a 900 MW lignite-based electric generating facility near Beulah, ND. Lignite Energy Council, **Antelope Valley Station**

, **available at** https://www.lignite.com/mines-plants/power-plants/a ntelope-valley-station/.– TECHNICAL SUPPORT DOCUMENT –

17 Kentucky, Pennsylvania, and Ohio provide electricit y onto the electric grid to serve electricity load in PJM. Additionally, generators in the wester n parts of PJM, which has geological sequestration available, historically have provided a large amount of generation in the RTO. Similarly, new coal generation could be sited in ar eas with geologic sequestration while allowing this new generation to serve other areas w ithout geologic sequestration through the
extensive transmission infrastructure.

New York

Figure 1 indicates that the eastern part of New Yor k does not have available geologic sequestration. This area is part of NYISO, which, s imilar to other RTOs, has a diverse resource mix to meet system demand. New York’s resources inc lude a very small amount of coal-fired generation. 31 Additionally, this area, like many others on the g rid, imports electricity from surrounding areas. 32 Portions of New York, as well as surrounding areas such as Pennsylvania, have access to potential geologic sequestration. Th erefore new coal generation could be built in those areas and serve load in the eastern part of N ew York.

Moreover, New York is a member of the Regional Gree nhouse Gas Initiative (RGGI), which is a market-based regulatory program to reduc e greenhouse gas emissions, which indicates that the state is moving away from genera tion facilities that have high CO 2 emissions. Further, New York has adopted CO 2 limits on new coal-fired power plants, which essent ially can be met only through the installation of CCS. 33

New England

This area includes Connecticut, Rhode Island, Massa chusetts, Vermont, New Hampshire, and Maine. All of these states are members of RGGI, which is the first market-based regulatory program in the U.S. to reduce greenhouse gas emissi ons, giving a clear indication that New England is moving away from electric generation tha t has high CO 2 emissions.

Coal-fired power plants may have more unfavorable e conomics in this area than in some other areas of the country. For example, this area does not have coal supplies, so that coal must be transported into this area from Appalachia or el sewhere. Additionally, some existing coalfired power plants with recently added pollution co ntrols such as SO 2 scrubbers are still choosing to close for economic reasons: Brayton Poi nt Power Station (Somerset, Massachusetts) is scheduled to close in May, 2017 a nd Mt. Tom (western Massachusetts)

31 EIA, **New York: State Profile and Energy Estimates – Prof ile Analysis**  (July 16, 2015), **available**

**at** http://www.eia.gov/state/analysis.cfm?sid=NY.

32 EIA notes that more half of New York’s energy is s upplied by other states and Canada. **Id.**

33 Scott DiSavino and Jim Marshall, **NY adopts CO 2**  **rules that limit new coal power plants**

, Reuters, June 28, 2012, **available at** http://www.reuters.com/article/2012/06/28/us-utili tiesnewyork-carbon-coal-idUSBRE85R1GF20120628.– TECHNICAL SUPPORT DOCUMENT –

18 recently closed. According to ISO New England’s 201 5 Regional Electricity Outlook, “Rising costs associated with oil and coal and the advanced age o f many of the power plants that use these fuels make it difficult for these resources to comp ete against newer, more efficient generators - primarily natural gas units. For this reason, coal and oil units are now run mainly to meet peak demand, when natural gas plants are unavailable, or when natural gas price spikes surpass oil prices. The region’s coal- and oil-fired generators represent about 28% of capacity in the region, but only produced about 6% of its electricity in 20 14 - and very few coal units are left.” 34 Moreover, ISO New England stated, “The natural gas price spikes in recent winters have led to oil- and coal-fired units being more economical and thus selected in the energy market to run more frequently in winter. (See page 29.) This reve nue stream could delay retirements for some resources; however, it’s unclear how long the trend will continue or whether it will be enough to counter other economic and regulatory pressures. For example, once oil resources run more than 9% of the time, expensive capital investments may be required in order to meet air quality regulations. In some cases, state regulations restr ict the number of hours that dual-fuel units can burn oil. And over time, the Regional Greenhous e Gas Initiative’s cap and trade program for
carbon dioxide emissions could make oil and coal le ss economic fuels.” 35

EIA has also noted the trend towards natural gas an d Canadian hydroelectric generation in New England over the last decade. 36 This region is seeing older, less efficient, tradi tional resources such as coal retire. New England states h ave several reasons to further limit their use of electricity generated from fossil fuels. “Constr aints on some of the pipelines delivering natural gas into New England have contributed to hi gher natural gas prices and made electricity relatively more expensive. Also, all New England st ates have renewable portfolio standards (or in Vermont, a nonbinding goal) requiring that a cer tain percentage of their electricity comes
from renewable sources.” 37 Additionally, entities are also proposing to build transmission
between the United States and Canada to increase ac cess to Canadian hydropower. For example, Champlain VT, LLC (doing business as TDI-N ew England) applied in 2014 for a Presidential Permit to build the New England Clean Power Link which it stated would bring “clean, affordable hydropower to Vermont and the Ne w England marketplace.” 38 To the extent that ISO-NE wanted to utilize coal-fired generation , we note that it is interconnected to PJM which has both currently-existing coal generation a vailable, as well as geologic sequestration.

34 ISO New England, **2015 Regional Electricity Outlook** , at 19 (Jan. 2015), **available at** http://www.iso-ne.com/static-assets/documents/2015/ 02/2015_reo.pdf.

35 **Id.** at 20.

36 Energy Information Administration

**, New England relying more on natural gas along with**  **hydroelectric imports from Canada** (Aug. 22, 2014), **available at** http://www.eia.gov/todayinenergy/detail.cfm?id=1767 1.

37 **Id.**

38 Champlain VT, LLC Application for Presidential Per mit (May 20, 2014), **available at** http://energy.gov/sites/prod/files/2014/07/f17/PP-4 00%20TDINew%20England%20Application%20with%20Appendices_0.p df.