MEMORANDUM 

DATE: December 1, 2014 

TO: Clean Power Plan for Existing Power Plants; Docket ID: OAR–2013-0602 

FROM: Melanie King, Office of Air Quality Planning and Standards 

SUBJECT: November 18, 2014 Meeting Regarding Proposed Clean Power Plan for Existing Power 

Plants 

SUMMARY 

A meeting was held between EPA and the attendee(s) listed below on November 18, 2014, to 

discuss the proposed Clean Power Plan Supplemental Proposal for Existing Power Plants in Indian 

Country and U.S. Territories. The Clean Power Plan Supplemental Proposal was issued on October 28, 

2014, and published in the Federal Register on November 4, 2014. Attached are the slides presented by 

EPA during the meeting. 

ATTENDEES 

 April Quinn, Navajo Nation – DOJ 

 Sandy Eto, Bureau of Reclamation, PXAO 

 Shauna White, ITCA 

 Mitchell Weinberg, Calpine 

 Barbara McBride, Calpine 

 Luke Johnson, Fort Mojave Tribe 

 Jill Grant, Jill Grant & Assoc., counsel for Navajo Nation 

 Carlene Tenakhongua, Hopi Tribe 

 Francys Crevier, Hopi Tribe 

 Norman Honie, Hopi Tribe 

 Elaine Wilson, ITCA 

 Eugena Quintana, Navajo Nation EPA, Air Toxics Dept. 

 Robert Miguel, Ak-Chin Indian Community 

 Delbert Altaha, White Mountain Apache Tribe, Environmental Protection Office 

 Robert F. Palmquist, Strickland & Strickland for Ak-Chin Indian Community 

EPA 

 William Niebling, OAR 

 Greg Green, OAR/OAQPS 

 Laura McKelvey, OAR/OAQPS 

 Melanie King, OAR/OAQPS 

 Mary Johnson, OAR/OAQPS (by phone) 

 Amy Zimpfer, Region 9 

 Anita Lee, Region 9 

 Colleen McKaughan, Region 9 

 Laura Farris, Region 8
Clean Power Plan: 

Supplemental Proposal for Power 

in Indian Country and U.S. Territ

November 18, 2014
Agenda

► Clean Power Plan Supplemental Proposal► Why is EPA Proposing the Clean Power Plan?► Affected Power Plants in Indian Country and U.S. Territorie► Determination of the Best System of Emission Reduction a► Implementation Plan Guidelines► Impacts of the Supplemental Proposal► Outreach and Consultations► Public Input
Clean Power Plan Supplemental Propo

► On October 28, 2014, EPA issued the Clean Power Plan su

proposal to address carbon pollution from affected power pIndian country and U.S. territories 

► Published in the Federal Register on November 4

► Supplemental proposal has two main elements: 

► Rate-based goals for carbon dioxide (CO

2) emissions from th

sector specific to each area of Indian country and U.S. territorexisting fossil fuel-fired electric generating units

► Guidelines for these areas to follow in developing plans to ach

area-specific goals

► Supplemental proposal relies on approach used in June 20

Power Plan proposal for states
Why is EPA Proposing the Clean Power P

► CO

2 is a potent greenhouse gas (GHG) that contributes to c

change 

► CO

2 is the primary GHG pollutant, accounting for nearly 75% 

GHG emissions and 82% of GHG emissions across the cou

► GHG pollution is causing potentially rapid, damaging and lo

changes in our climate that can have a range of severe negon human health and the environment

► May 2014 report of the National Climate Assessment conclu

climate change impacts are already manifesting themselves imposing losses and costs; report documents increases in eweather and climate events in recent decades, damage and to infrastructure and agriculture, and projects continued incrimpacts across a wide range of communities, sectors, and e
General Overview of Clean Power Plan

► Proposal sets an interim (2020-2029) and final goal (2030) 

power plants in each area to reduce carbon pollution

► EPA is not prescribing measures these areas need to imple

the goal

► Areas have flexibility to choose what goes into their plan – 

when to get the necessary reductions, provided the goals aestablished timeframe

► Option to translate rate-based goal to mass equivalent► Choose what works best in an area, tailored to its need

objectives

► Opportunity to build on existing energy efficiency and re

energy programs 

► Option to work with other areas through multi-jurisdictio► Fits into existing utility electricity sector planning proces
Affected EGUs in Indian Country and Terr

► Indian Country:

► Four affected power plants:

• South Point Energy Center on Fort Mojave tribal land

Arizona

• Four Corners Power Plant on Navajo tribal lands with

Mexico

• Navajo Generating Station on Navajo tribal lands wit• Bonanza Power Plant on Ute tribal lands within Utah

► U.S. Territories:

► Six affected power plants in Puerto Rico ► Two affected power plants in Guam
Determination of the Best System of Emission R

► To set goals for each area, EPA first determined the Bes

Emission Reduction (BSER)

► Because the power sector is interconnected, EPA determ

set of 4 types of measures, or “building blocks,” together best system to reduce carbon pollution from fossil fuel-fiplants

► BSER is made up of 4 building blocks: 

(1) measures to make coal plants more efficient (e.g., heat ra

improvements)

(2) increased use of high efficiency, natural gas combined cy

units (e.g., redispatch)

(3) generating electricity from low- or zero-emitting facilities(4) demand-side energy efficiency

► After determining the BSER, EPA set the goals based on 

of the BSER to each area
Proposed Goals for Areas of Indian Co

► Notes:

► No adjustments from building block 1 for Fort Mojave la► No adjustments from building block 2 ► Proposing one option for application of building block 3 

comment on alternatives 

► Requesting comment on projected retail electricity sales 

Indian country (used for building block 4)

Proposed Goals (adjusted output-weighted-average lb CO

2/net 

Area of Indian Country Interim Goa

Lands of the Fort Mojave Tribe 856 

Lands of the Navajo Nation 1,991 

Lands of the Ute Tribe of the Uintah and Ouray Reservation 2,000 
Translation of Goals to Mass-Based Equiva

► EPA provided additional information in November 201

potential ways to translate the rate-based CO

2 goals t

based equivalent, including two illustrative approache

► First produces mass-based equivalents that apply to ex

fuel fired sources only

► Second produces mass-based equivalents that are incl

emissions from existing affected and new fossil fuel-fire

Area of Indian Country Existing Affected Sources Only Exis

and 

Lands of the Fort Mojave Tribe 528 

Lands of the Navajo Nation 26,731 

Lands of the Ute Tribe of the Uintah and

Ouray Reservation 2,787 

Final Mass Equivalent (Thousand Metric Tons)
Implementation Plan Guidelines

► Areas of Indian country with affected EGUs:

► Tribes may seek authority to implement 111(d) plans► Pursuant to the Tribal Authority Rule, if tribes do not see

the authority to establish a plan, EPA must promulgate splan provisions as are necessary or appropriate

► EPA is not proposing a determination regarding any tribe

to develop a plan or whether a federal plan is necessary appropriate

► Areas without affected EGUs (e.g., other tribal areas, V

D.C., Canada):

► Taking comment on allowing state or multi-jurisdictional 

include demand side energy efficiency, renewable energunits located in areas without affected EGUs
Impacts of the Clean Power Plan

► No additional costs, emission reductions or benefits fo

Country for the supplemental proposal

► Navajo: if converted to mass-based equivalent, expected to 

without additional actions beyond shutdowns already occurRegional Haze

► Ute and Fort Mojave: costs, reductions and benefits alread

June Clean Power Plan proposal

► Impacts of June Clean Power Plan proposal:

► By 2030, CO

2 emission reductions from the power sector o

30 percent from 2005 levels 

► Reductions of other pollutants including SO

2, NOx, and dire

PM2.5

► Net climate and health benefits of $48 billion to $82 billion 
Outreach and Consultation Prior to Pr

► EPA held a listening session and outreach meeting wi

and participated in NTAA teleconferences and webina

► EPA sent consultation letters to leaders of all federally 

tribes when the June 2014 Clean Power Plan proposaissued

► EPA held consultations with the Ute Tribe, Crow Natio

Nation, Fort Mojave Tribe, and Navajo Nation; concerincluded:

► Impacts of Clean Power Plan on tribes with budgets and 

dependent on coal mines and power plants

► Application of building blocks 3 and 4 for the Navajo Na► Impacts on renewable energy projects on tribal lands► Ability of tribes to control any available carbon credits u

program
Public Input

► Public hearing will be held on November 19, 2014, at 

Convention Center

► Public comments will be accepted through December 

► Comments should be identified by Docket ID No. EPA-H

2013-0602

► EPA intends to take final action on the supplemental p

conjunction with final action on the proposed Clean Pfor states

► For more information:

► http://www.epa.gov/cleanpowerplan