EPA

Moderator: Reid Harvey

11-07-14/12:00 p.m. ET

Confirmation # 32300775

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EPA

Moderator: Reid Harvey

November 7, 2014

12:00 p.m. ET

Operator: Good afternoon, my name is (Angie) and I will be your conference operator 

today. At this time, I would like to welcome everyone to the Clean Power 

Plan, Rate to Mass Technical Support Document. 

All lines have been placed on mute to prevent any background noise. After 

the speakers’ remarks, there will be a question and answer session. If you will 

like to ask a question during this time, simply press star then the number one 

on your telephone keypad. To withdraw your question, please press the pound 

key, thank you. 

I would now like to turn the conference over to Reid Harvey, please go ahead. 

Reid Harvey: Thank you. And hello every one, thanks for joining the call. Yesterday, EPA 

posted a technical support document that provides examples of how States, 

Tribes or Territories could translate rate-based goals to mass-based equivalent. 

That’ll be expressed as total funds of Tier 2 emissions in their compliance 

plans. 

So, we wanted to take this opportunity today to walk you through those 

examples and to field any questions you may have. But providing the rates to 

mass TSD, responds to requests we’ve received from you and others and 

provides information to all stakeholders as we worked towards the end of the 

proposed Clean Power Plant coming period on December 1st. 

I hope you’ve had a chance to look over the TSD, and if actually that we 

posted online yesterday afternoon. But, if you haven’t, it’s OK. Because the 
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purpose of the call is to walk through those calculations with you and we tried 

very hard to make those calculations as clear as possible. 

So, before I turn over to Ryan Sims in our office to walk through the 

equations with you, let me give you a little bit more background in the June 

2014 proposal in the October supplemental. EPA gave States, Tribes and 

Territories the option to convert their rate-based goals then to mass equivalent. 

So, that translate – that translation is not based on any new information, it 

does not change the rate-based goals that are outlined in June proposal or the 

recent supplemental proposal. It simply illustrates two possible methods for 

doing that translation. So, our States, Tribes and Territories decide to use a 

mass-based number. That would need to demonstrate that it’s equivalent to 

their rate-based goal. 

We are continuing to seek your ideas and your comments on this rate-to-mass 

conversion. and different options for doing that. As we worked towards, what 

we hope to be a flexible and effective final rule. 

And over the past several months, we’ve received an enormous amount of 

input through hundreds of meetings and conversations in conference calls with 

you and others and I know that the administrator and the acting administrator 

Janet McCabe and all the staff at EPA are very grateful to everyone who’s 

taken the time to review the proposal and all the supporting material to tell us 

what you think. 

We know, we feel for you well that – like we’re overloading you but we 

appreciate your input. So, it’s been incredibly instructive. So, just to wrap 

up, I wanted to thank you for spending time again with us today to thank you 

for your willingness to dive into these issues with us. To lend us your 

expertise and to share your perspectives on this and all the other aspects of the 

Clean Power Plant. 

So, we – we’re listening because, you know, together we know that the Clean 

Power Plant will be better for all this input. So, with that, I’ll turn it over to 

Ryan. 
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Ryan Sims: Thanks Steve. So, I think we’re going to spend the next 15 minutes going 

over the mechanics of the two example methodologies as well as the rationale 

for why we made some of the choices that we did in the methodologies has 

laid out in the TSD. 

For those who have the TSD in front of them, I’ll try to refer to page numbers. 

For those who may not, that’s OK, as we’ve mentioned, we’ve tried to make 

this a very concise TSD. It’s six pages of text. And we’ll make sure to walk 

through each step and I’ll probably pause for questions in between some steps 

as they do build on top of one another. I want to make sure that that we’re all 

understanding where we are and why we are where we are. 

So, first as you all are undoubtedly aware there are two methodologies for 

them (to the) TSD. One that applies mass-based equivalents to existing 

affected possibly fuel choices. And one that calculates mass equivalent for 

existing affected fossil fuel fire sources, as well as new sources. The second 

methodology reflects that we flip through comments, and the (June) proposal 

about the inclusion of new fossil fuel fire sources as a component of state 

plan. 

So, we’re going to start the conceptual overview of both methodologies. 

They’re very similar. And, we’re going to start on page two of the CSD and 

just talk generally about how any mass-based outcome is essentially a product 

(fuel to emission rate) times generation. 

And what we did with both of these methodologies is that for the CO2 

emission rate, we used the proposed rate-based goals from the June proposal 

or from the October supplemental. And then, we needed to define a certain 

generation level that we’d apply to those rate-based goals that would produce 

a mass equivalent. 

And so, since we know the proposed rate-based goals, the majority of the TSD 

is dedicated to qualifying what we’re calling this mass equivalent generation 

level. So, that’s how we’re going to spend the majority of my time here but 

on the Q&A session, we’re certainly open to entertaining a broader range of 

questions. 
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So, to begin, there are several shared concepts that both of these 

methodologies rely on to produce that mass equivalent generation level. 

Those concepts are discussed beginning on page three of the CSD. 

The first concept is that the deployment of the best system of emission 

reduction building blocks will affect total generation from effective fossil fuel 

fire sources. This is an important concept throughout the proposal (to further 

due) proposal, that new resources under building block three and building 

block four will displace generation and therefore emission from affective 

sources. 

Any mass equivalent, we expect will be the result of applying all four building 

blocks and the result of applying those blocks three and four – again, it’s 

important to see the displacement between the new resources deployed under 

those building blocks and the affective source generation. 

The second shared concept is that there is a consistency between the mass 

(and coal) and generation sources – so, the sources that contribute to the mass 

equivalent generation level. And those sources covered by the mass 

equivalent. And so, this essentially is how we get to two methodologies. 

The first methodology, again, just applies to existing affected sources and 

therefore does not include consideration of generation of new sources. 

Whereas the second methodology does include new sources, and therefore it 

was important for us to quantify some level of future generation so that we 

can add that the mass equivalent generation level to arrive at an appropriate 

mass equivalent. 

The third concept, and we’re on page four now for those signing on – is that 

we took a historically based approach with both these methodologies. The 

preamble staked out a rather broad ground when it comes to how effective 

jurisdiction may choose to translate their rate-based goals to mass equivalent. 

And in the (red packed cells), we posed one option that is based on a 

projection base forward looking model based approach. And, we lay out – we 

fully articulate this vision of how this translation could occur in a TSD. And 

so, during the common period, we heard a lot of feedback on this approach but 
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also requests for further illustration as to how this translation could occur in 

other contexts. 

And so, this context – instead of a model-based forward looking projection 

based approach, is simply a calculation based approach in which we rely on 

historical data. So, both approaches again apply the (BSC) or building blocks 

to 2012 historical data, which is very similar to the rate-based goals setting 

methodology in which we rely on 2012 data from affected sources. And we 

apply each of the four building blocks to arrive at the rate-based goal. 

So, those are the three concepts that’s bring in our approach to how we 

calculate the mass prevention ration level. And then, starting on page four, we 

begin to walk through the mechanics of how we get from historical data to a 

mass equivalent generation level. 

So, beginning on page five, the first step is quantifying what the historical 

affective possible generation level is. And what you’ll find in this TSD, is it 

has the equation and then it ties those equations to an example stake. The 

stake given as Ohio, which is stemming sample state as the goal computation 

TSD provides in the June proposal. 

And so, the first step again is quantifying this historical affective fossil 

generation level. And then from that generation level, when we deploy the 

BSCR building blocks, we expect that the new resources under building 

blocks three and four will display emission and generation from that historical 

level. 

And so, that is the equation provided at the bottom of page five. And that’s a 

generation level that we refer to in the (TST) as the adjusted, affective fossil 

generation level. So, again, we’re taking historical and we’re removing the 

new resources under building block three. So, that’s (RE) and under 

construction nuclear. As well, as the (EE) under building block four. 

The next step on page 6 is the massive function generation level – is to add in 

the total resources under building blocks three and four. So, we started with 

the historical fossil. We took away the new resources and now we’re adding 
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all the resources under building blocks three and four. Because at building 

block three, also contains existing (RE) as well. And (at risk) nuclear. 

So, I think I’ll provide a little commentary on that. In that the rates that we’re 

applying to the massive (clone) generation level, again it’s a proposed ratebased goal. And in forming that proposed rate-based goal is the full suite of 

affected entities. 

So, it includes fossil, it includes (RE), it includes nuclear, it includes (avoided)

generation from (EE). So in defining a massive (clone) generation, we wanted 

consistency between the proposed rate-based goal and the sources that were 

contributing to the mass equivalent generation level. 

So, that informs the decision to add in the total resources from building blocks 

three and four. 

So, we’ve arrived at the mass prevention generation level for existing affected 

sources. The methodology for mass prevention level for existing, affected and 

new sources pick off where just on this generation level and simply add the 

generation anticipated to satisfy future demand. 

And so, what we did for quantifying this level of generation, is we looked at 

demand projections from AEO 2013. And the reason we feel like the demand 

projections from AEO 2013 is that it’s the same demand projection that are 

part of not only our compliance modeling, but part of how we specify building 

blocks for generation when we look forward in deploying energy efficient 

resources against a future level of demand. 

So, there’s consistency again between the June proposal and the 

methodologies outlined in the TSC. And so, for each state, we can quantify 

an average annual growth rate from 2012, through, in this case – 2029. And, 

again, that growth rate is taken directly from the AEO projection. And each 

state we can observe what the 2012 historical sales data is for that state. And 

then, we can apply the average annual growth rate to 2012 and we can specify 

what – our reason like expectation of sales, going forward, from each year 

from 2012 on. 
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Then, to convert from a sales level to a generation level, we gross up by 

transmission boxes – 7.5, 1 percent – this is the same as June transmission 

(boxes) that we used to calculate the rate-based goals. 

And then, we have a level of generation required to meet this new demand. 

And then, we can just take the increment from 2012 to any future year. So, 

then we have the difference in generation required to meet demands from 

some future year to 2012 – that is increment that can used and added into the 

mass and generation level to accommodate the inclusion of new sources. 

We can see that final equation, so on page six, is where we lay out the 

equation for how we are arriving at projected sales. Then on page seven, we 

convert those sales into a generation number. 

And then, finally, we (rethink) what the mass-prevention generation level is 

that incorporates new resources which is the adjust-affected fossil generation 

level plus total resources under building blocks three and four plus this new 

increment that we can assign to new sources. 

So, now that we’ve established a massive prevention generation level for both 

existing sources and in existing in new sources, we can finally apply the 

proposed (emissionary) goal and to arrive at the mass equivalent for each 

affected jurisdiction. 

And so, what you’ll see in the appendix is each of these components for each 

affected jurisdiction for the proposed goals. So, in the June proposal for 

States, that would be the option one goals. In the supplemental, it would be 

the option one A goal. As part of this release, we also posted a data file that 

contains mass equivalent, (staunchly) associated with the proposed goals or 

option one but the alternative for option two goals as well. 

For the inter-mass equivalent – inter-mass equivalent similar to how we arrive 

with interim rate-based goal is the simple average of 2020 through 2029 for 

option one. And then, the final mass equivalent is the 2029 value. And that 

applies to 2030, and also to the nearest. 
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So, I think perhaps that is a good overview of the methodologies. And I think 

we can now turn it over to questions. 

Operator: If you would like to ask a question, please press star one on your telephone 

keypad. Again, that’s star one to ask an audio question. Please hold for your 

first question. 

Again, if you would like to ask an audio question please press star one. 

Your first question comes from the line of Ben Cohen with NYISO. 

Peter Corning: Hi, this is Peter Corning from New York Independent System Operator. And 

when we take a quick look at the data that you posted yesterday, we know that 

the emission reduction on the (connage) basis in New York would be 71 

percent from our 2005 reference level, 66 percent for the (Reggie) states and 

45 percent on a national level. 

Those numbers seem to be quite at odds with the announced goal of a 30 

percent reduction. Perhaps, you could clarify the situation? 

Jeb Stenhouse: Yes, hi Peter, this is Jeb Stenhouse at EPA. I think it is a good opportunity to 

clarify as we’ve been reminding folks since the June proposal went out that 

while we did some illustrative system wide modeling to look at, you know, 

what we thought some potential impacts might be from states putting plans 

together to achieve the state goals. That that 30 percent below 2005 at the 

national level was, you know, an analytic observation as a result of that 

illustrative modeling. 

And so, it’s useful to remind folks that that – that in it of itself is not a goal, if 

you will. 

Operator: Your next question comes from the line of Floyd Gilzow of MPUA. 

Floyd Gilzow: Good morning this is Floyd Gilzow with Missouri Public Utility and Lines. 

In the earlier discussion describing the difference between option two – or 

option one and option two, you referenced the fact that option two also 
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included new sources. Could you clarify what you intended with the term 

new sources? 

Male: Sure, the intent was to mirror the proposal. Now the proposal took comment 

on the inclusion of new fossil fuel fire sources as a component of the state 

plan. So, to preserve that flexibility that the proposal afforded states and 

effects of jurisdiction. We proposed two options. One that was inclusive of 

new sources and one that was just existing effective buyer. Because it is a 

mass equivalent – those new sources would be fossil fuel fire sources of 

course. 

Floyd Gilzow: Thank you. 

Operator: Your next question comes from the line of Scott Weaver with AEP. 

Scott Weaver: Good morning guys. Thanks for taking the time to sit down and walk us 

through this proposal. Two questions. First question is related to this 

proposed methodology. 

You can (see assume) that, now that you have a – I guess – one option laid out 

in terms of the mass-based equivalent that if States were to – assuming the 

rule goes forward in some similar fashion. Assuming States would take these 

(CAP) numbers, would it be as simple as writing these (CAP) numbers into 

their SIP for approval? 

And is this kind of a, I guess, pre-determination of this being an acceptable 

approach? 

That’s my first question. My second question relates to the actual generation 

calculation. It appears that you’re adding in and then subtracting out the a –

or actually – subtracting out then adding in the renewable energy and energy

efficiency components? 

Based on my simple math, it looks like the affective generation used to 

calculate the mass – it’s simply historical generation plus under construction 

natural gas combined cycle plus existing renewable energy when you get to 

that final megawatt hour number. But, I just wanted to verify that. 
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Reid Harvey: Hi, Scott, this is Reid. We’ll sort of (divide) this up. 

I’ll take the first question and then Ryan will take your second question. I 

think, you know, the intent here is simply to put out a different way of 

calculating these estimates. But, they’re based on the June proposal. We’re 

seeking feedback on all aspects of the June proposal including some of the 

topics that we erased in the NODA. And so, this is not in any way intended to 

focus on the outcomes of the numbers as if they were binding. 

Obviously, to the extent that the June proposal changes with respect to the –

the way that the building blocks are handled or other features. Then the 

conversion from a rate to a mass-based equivalent which I need. 

So, I think – I would strongly encourage folks to view this simply as yet 

another way to convert the rate that we proposed. But, remember that the 

rates, you know, to the extent that the final rule as different from the proposed 

rule – what else could be different as well. So, Ryan you’re going to take the 

second one? 

Ryan Sims: Sure, on the question the equation – that – in astute observation and true for 

most States. I think the intent of the methodology and the breaking up those 

steps and that we are subtracting new resources and then in the next step 

adding them back in, is just to be really clear about how we’re thinking about 

how BSCR applies in this case as we’re thinking about demonstrating 

equivalency with the rate-based goal. 

So, the methodology could be simplified for many states, but we thought I 

was important to show the interim steps just so that our thinking was clear on 

what the equation means not just the quickest way to get to the end point of 

the mass equivalent generation. 

Scott Weaver: Thank you very much. 

Operator: Your nest question comes from the line of Andy Kellen with WPPI Energy. 
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Andy Kellen: Thanks guys. I think this kind of follows on to the previous question. But, as 

I understand it, if this method is intended to be consistent with the proposal in 

that – the – that the number that you multiply, the emission rate goal by –

would be the generation by affected EGUs in kind of a business as usual or 

reference case scenario? 

That – that in that case, that would be what this mass equivalent generation 

level is intended to represent. And – in as I – probably (Steven) point out, that 

if you look at the equation for the vast majority of states it breaks down to 

simply be 2012 generation by affected EGUs plus at risk nuclear plus existing 

renewables which is, you know, a number that’s flat throughout the year. I 

guess, I’m having trouble figuring out how that can be a (property) for a 

generation by affected EGUs. 

You know, I would expect for example, in a reference case scenario, where 

you’re not adding renewables or efficiencies that the generation by affected 

EGUs would be a little higher each year as those you’d intend to ramp up to 

serve low growth. In this case, your numbers are flat every year under the 

option one scenario. So, I guess, I’m just a little confused there. 

Ryan Sims: Sure, I think the number of (common) to (Neginar) is our one is that this is a 

historically based approach. Two, is that we’re talking about effective EGUs. 

Is that I think the intent is to encompass affected entities. Which is a broader 

universe of sources and affected EGUs which we think as particularly as the 

fossil fuel fire sources, existing fossil fuel fire sources. 

As far as the generation level being flat, that’s correct. But, it’s being applied 

again, the rate-based goal, which continues to decline over time which 

produces a declining cap. I think I can stop there unless there’s a specific 

follow-up. 

Jeb Stenhouse: Hey, I would just add this is Jeb Stenhouse, EPA, I would add that I think that 

the length of the question and the details that hit are a great example of the 

kind of thinking we hope that (GSG) will help facilitate. Where folks can 

think across all of the different options, the proposal in June put on the table 

for public comment about how rates and mass translation might be done. 
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And how that states relate to the particular illustrate of approaches of we’ve 

laid out here. 

Ryan Sims: Yes, I think that’s a good point. Just to ride on Jeb’s comment is I think one 

of the benefits of this approach is that it’s simple enough and concise enough. 

That it allows people to explore the implications of various ways to conceive 

of what is equivalent to the rate-based goal. And it brings clarity to a lot of 

issues that we supposedly did comment on in regards to (BSGR), rates versus 

goals (seeking) methodology et cetera. 

So, it’s our hope that the (SCT), serves more a function of furthering the 

ability – the public to comment on the proposal and less thinking about what 

the specific implications of these numbers are. 

Andy Kellen: Thanks. 

Operator: Your next question comes from the line of (Beth Tenorspiel) of Massachusetts 

Department of Environment. 

(Beth Tenorspiel): Hello, I have a question building on the previous couple. So both on the 

NODA, and the rates to mass TSD is discussed that the potential offsetting of 

existing fossil generation with new renewable energy, nuclear energy

efficiency generation from building blocks three and four. 

Could we calculate it in and if the state were to use the rate to mass 

calculation described in the TSD, my question is, would both the proposed 

emission goal and the mass equivalent generation level be adjusted by 

subtracting the building blocks between four and generation from the existing 

fossil generation? Or would that adjustment be made only once? On – it 

looks like from note 9 that the implication is – it would be only made once. 

And if that is the case, if rate-based stay – if you say you take a rate-based 

approach and that goal were not adjusted to account for this displacement. 

Whereas another state were to take a mass-based approach, and that were to 

be adjusted according to the TSC. How would the equivalence stringency

being maintained between those two approaches? 
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Jeb Stenhouse: Yes, this is Jeb again. I think that what I hear you describing are some really

useful to observations crossing the space of what we proposed in the June rule 

that how state goals were calculated. 

What we recently released in the NODA, about different ideas, we’ve already

heard that from stakeholders on the way that the building blocks and their 

generation are reflected in the copy, you know the calculations behind those 

state goals per rate based as well as the information in this illustrative 

approach for translation of rate to mass. And the proposal certainly posted a 

comment on the way all of this might play out as states take different paths in 

their state plans. 

And so, I’m hearing some really rich thinking there that we certainly hope to 

get, you know, both in your comments as well as others who are thinking 

about these things. 

Operator: Your next question comes from the line of James Boylan with the Georgia 

Department of Natural Resources. 

James Boylan:: Hi, my question is under the mass based goal approach, the assumption is that 

all new generation from renewable and under construction nuclear will replace 

existing fossil generation. While under the rate-based goal approach, the 

assumption is that all new generation from renewable energy and under 

construction nuclear will be added on top of the existing fossil generation. 

So, to me that seems like an inconsistency across the two approaches. 

Jeb Stenhouse: Yes, James, this is Jeb. I think that that linked nicely with – that’s a question 

a minute ago as well. I think what I would say is that in the June proposal as 

we laid out the BSCR element and created a rate goal, I’m not sure we really 

at that point adopted an explicit assumption about the relationship of 

generation between these blocks. 

And at that’s partly why the NODA was reflecting some of the exchanges 

we’ve been having with folks who’ve been looking at the June proposal and 

thinking about what that ultimately means. And how that affects the 

calculation of the state goal. And so, I think you put your finger on an issue 
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we need to think about carefully on state goal computations going into the 

final rule. 

(Is there a reason?)

Operator: Your next question comes from the line of Robert Kappelmann with FMEA. 

Robert Kappelmann: Yes, thanks for having this explanation of the TSD. I guess I’m following 

up on the same question that’s coming up. I noticed in the NODA some of the 

stakeholders pointed out the fact that building block three and four don’t 

displace existing generation. But, we had sort of a understanding or in 

reading this initial proposal in June – that that could accommodate some 

growth on some of the existing generating units. 

In the state of Florida, a lot of your existing units have sufficient reserve 

capacity. That’s one of the reasons, I guess in your proposal you had so much 

generation shifting from coal to combined cycle gas. So, now in the NODA, 

it looked like EPA was entertaining some suggestions from stakeholders, 

asking for comment. But, it looks like you’ve already gone ahead and made 

up your mind based on what I’m seeing in the mass base. Which you’ve used 

that assumption in your mass base. 

Am I incorrect that you’re leaning towards additional stringency in the June 

proposal? 

Jeb Stenhouse: Yes, yes. This is Jeb. You know, I think that – and I appreciate you laying 

that out so that we have a chance to be very clear in this message here. in 

laying out in this TSD, a (lot sure) of ways of crossing from a rate based goal 

to a mass based equivalent – it necessitates addressing that question and 

coming out with some representation. We’ve shown you in these approaches 

one way of making that translation and obviously, that’s in the zone of what 

we need to get feedback on. 

That does not in any way address the root issues about how you calculate state

goals which are already in front of the commenters through the proposal we 

started in June. And then, enriched by the NODA discussion of the exchanges 

we’ve been having that you were just reflecting as well. 
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And so, I think you’re indulging in some tea leaves there that are very much 

not part of what were focusing folks on with this illustrative demonstration of 

how you might be rate to mass translation. 

Robert Kappelmann: Thank you. 

Operator: Your next question comes from the line of Peter Ashcroft of UT Office of 

Energy. 

Peter Ashcroft: Oh, yes other people have asked exactly my questions so I’ll pass. 

Operator: Your next question comes from the line of Darrell Preble, with the Space 

Phila Power. 

Darrell Preble: Yes, thank you for having this opportunity for discussion and looking at the 

four blocks that you’ve got the building blocks, in my opinion, there are folks 

keen on things which are not adequate to address the carbon lowering goals 

which I understand the EPA is attempting to embrace. And, looking at the 

history of the $2 trillion which has been spent on working on (RPS) and (REs) 

the results have – worldwide. Then, a increase of four and a half faster carbon 

dioxide growth in the world. 

The opportunities that utilities have to address these carbon dioxide lowering 

goal in inadequate to accomplish the goals which has been laid out – which 

are admirable goals. 

And, I would question the opportunities which are being provided to the 

utilities which are inadequate in my opinion address these. Looking at the –

the last ten or twenty years or more of history, of how the goals have been set 

and approached. 

Not only in this country but in Europe and in others. The results – well in the 

U.S. has been a 42 percent increase in electricity cost. While during the last...

Male: Can I – can I interrupt you? 

Darrell Preble: Yes. 
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Male: I’ve got other people who are...

Darrell Preble: Yes. 

Male: Who are in the queue, I just want to say thank you for that comment...

Darrell Preble: Yes. 

Male: We, you know, we set the rate goals for states based on an evaluation of the 

best system of emission reduction. 

Darrell Preble: I understand. 

Male: But we certainly encourage you to submit that comment to us before 

December 1st, thank you. 

Darrell Preble: That’s great ...

Female: Yes, and I think we’re ready for the next question. 

Operator: Certainly if you would like to ask a question, please press star one. Your next 

question comes from the line of Lois New, from New York State Department 

of Environmental Conservation. 

Lois New: Hello, thank you for the opportunity to review this and ask questions. I would 

like to know more about how the expected increase in deployment of electric 

vehicle is factored into the growth rate. 

Jeb Stenhouse: Yes, this is (Jeb Steinhaus). We, as I think the TSD describes and cites – we 

use the same electricity demand projection that we had already used in parts 

of the June proposal. Here, in order to quantify that factor, and so that means 

that how the energy information administration is anticipating that as one 

ingredient and all the ingredients they consider better electricity demands 

trend kind of flows through and into this process. 

Operator: Your next question comes from the line of Matt Roussy with State Corporate 

Commissioner. 
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Matt Roussy: The additions and subtractions for building blocks three and four appear to be 

based on the levels on 2029 in the interim mass equivalent seems to be based 

on 2029. Why wouldn’t it be more appropriate to base that on the average of 

20 – 20 through 2029? 

Male: That is how the (interim) is calculated, it’s just a simple average for all the 

years, 2023 to 2029 and then the final is the 2029 value it applied to 2030 and 

all subsequent years. And there is some limited space in the TSD but the data 

file shows that clearly and give (a phrase) to that. 

Matt Roussy: No, the megawatt hours are consistent from year to year in the megawatt 

hours. 

Male: Sir, you’re (got) the megawatt hours as the mass equivalent generation level. 

Matt Roussy: Right, applied to the interim – like with the (gladta) for the interim level. And 

then you average that with megawatt hours themselves. For each year, we 

changed based on whether you used 2020 or 2029 or an average. 

Male: And so, I’m not a 100 percent sure that I was getting the question. But I can 

assure you that the – say – 2024 values are a function of the building block 

three and four generation that we project in 2024 and the emission rate based 

goal that we see in 2024 from Appendix 1. So, those values all come together 

to produce some 2024 value which has no meaning in it of itself because of 

the interim goal – it’s simply the simple average of 2020 through 2029. But, I

guess I’ll leave it there and maybe this could be something that we could 

follow up on. 

Matt Roussy: Well, if you look at your – your spreadsheet – in which you calculate the mass 

equivalent? The megawatt hour figure is consistent in 2020 through 2029. 

And the megawatt hour figure could change based on the way you said the 

additions and subtractions for building blocks three or four. And I’m 

confused by that. The rate did change. The rate does change from year to 

year but the megawatt hours do not. 

Male: Right, and so the reason it’s a mass equivalent generation this was back a few 

questions in the queue. Is that as new resources under building block three 
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and four deploy, what they’re doing is that they’re displacing generation from 

existing affected sources from the historical level. 

So, that the composition of the generation is changing to reflect how building 

blocks three and dour deploy over time. But, the overall mass equivalent 

generation level may be static for that entire period. 

But, that doesn’t imply that it’s all 2029 values or all 2020 values. So, I think 

that’s a – that’s a good observation and is something that I’m glad got brought 

up. 

Matt Roussy: It’s – you know I’ll just make one last point. It change sthe waiting from year 

to year the way you’ve done it. And I – if you do it differently for each year, 

you get a far different result. 

Female: OK. Let’s move on to the next question. We want to give everyone a chance 

and you can use – could we have the next question please? 

Operator: Certainly, your next question comes from the line of Dave Coup with 

NYSERDA. 

Dave Coup: Hello, I wanted this all up on an earlier question about low growth, the 

previous question was about whether (EZ) was included or not. I have a more 

general question as I’m looking at what you had for an assumption of annual 

average growth rate at least for New York. It appeared to be 0.25 percent. 

If I look at our (ISOs), the kind of metric low growth, which seems to be the 

right thing to compare to look at. Because it’s devoid of efficiency and real 

planners’ ease – it’s just kind of status quo low growth. The error rate is more 

like . 8 to . 83. So, I’m just trying to see if you can help me to better 

understand why the values are so different? 

Male: Sure, the values are so different is because those are regional growth rates. 

So, when we take demand projections from (AL) 2013, we’re looking at 

(NEM), that we’re looking at the electricity market module from (NEM). 
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And the regions in (NEM) are not as granular as those that are on the state 

level and so what we can do is we can only work with the regions that we 

have. And so, a state maybe a single (NEM) region. It can encompass several 

states and therefore it would be the average demand projection in each of 

those states. 

Dave Coup: OK. I don’t know if you can answer this question, but would – are you open 

to considering alternative growth rates if it – you know – if an individual state 

just really isn’t seeming to match with what the regional value is? 

Jeb Stenhouse: Yes, this I, Jeb. I think that’s a great example of exactly why we wanted –

you know, the kind of thoughtful input that (we’ve) could use in response to 

just the illustrative way and the data sets we have and what we’ve shown here. 

You know, the – this is a good example of a different data that may be – that 

may sit well into this approach. So, we’re very open to that type of input. 

Dave Coup: OK, and thanks again for holding this session. 

Operator: Your next question comes from the line of Thomas Wells, with the Southern 

Company. 

Thomas Wells: Yes, thank you. In your June proposal, you referenced a – kind of a forward 

looking approach to do a rate to mass conversion. Is this TSD foreclosed that 

type of option? 

Jeb Stenhouse: Yes, this is Jeb, I’m glad you asked it so we can tell everyone on the call that 

it very much does not. This TSD is giving a couple of additional illustrative 

approaches here but the June proposal, the scope of what we invited (Cod) and 

(Todd) in that proposal – which includes forward looking approaches – is not 

at all changed, right? Like sharing this additional TSD. 

Dave Coup: Thank you. 

Operator: We have time for one final question. That question comes from the line of 

Cassandra Jobe with Kentucky Division For Air Quality. 
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Sean Alteri: Yes, this is Sean Alteri, thank you for this illustrative example for the mass 

conversion. My question is will EPA publish these mass equivalent state 

goals? In Table 1 of sub part UUU? 

Jeb Stenhouse: This is Jeb, hi Sean – I think the answer to that is no for a couple of reasons. 

One, being you know that what we’re trying to illustrate here is a 

methodology or different methodologies and approaches by which both can 

take the state goals which are expressed in in a rate based form. And seek to 

quantify themselves a mass-based equivalent. If, you know, the state in 

question of a mass-based equivalent. If, you know, the state in question of the 

authority in question is interested in that type of implementation. 

So, I think that that means that – that’s why we released it in the TSD just so 

to so we’re showcase that and get feedback on those approaches. 

Dave Coup: Thank you. 

Operator: Your next question comes from the line of Ben Cohen with NYISO. 

Ben Cohen: Hey, thanks. I had a call on – a question on the last call and it was deferred to 

this one. So, I’ll ask it now. It’s a little bit, slightly different topic. For a 

state that choose to convert to mass-based goal. Do they still have to do 

energy efficiency, EM&V? Or do they, can improve compliance by just 

measuring CO2 stack emissions? 

Male: Yes, I mean I think it’s a – something that is being handled in your state or in 

the (Reggie) regions are ready through compliance just with stack emissions. 

There’s not a separate – as I understand it -- a separate EM&V process on the 

(EE) side. 

Ben Cohen: So, as – so I’m trying to understand the state would not be obligated to do 

EM&V if they did decide to go with the mass-based goal? 

Male: Yes, we noted in the proposal that that is one of the advantages for states to 

choose to adopt a mass based approach is that there’s less effort needed on the 

EM&D side for (EE). 
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Operator: Your next question comes from the line of Lois New with New York State 

Department of Environmental Conservation. 

Jared Synder: Hi, this is actually Jared Synder with New York DEC. Just following up on a 

question a few minutes ago about the growth rate. Does the growth rate that is 

used – the EAI growth rate, does that include the effect of state energy

efficiency program? 

Because it – if it does we’re a little bit concerned that that is – that that 

reduction is being counted twice. Both in reducing the growth rate and then it 

comes in again in multiplying the – you know by the assigned rate. So, can 

someone answer that question? 

Jeb Stenhouse: Yes, hi Jared this is Jeb. I think that’s an excellent question and part of, you 

know, in June – when we proposed the rule and talked about building block 

four and the quantification of the electricity savings in each state that was –

that was the (SAR) potential. 

Part of what we were inviting comment response on was – you know – how 

that was quantified and the relationship between that and future electricity

demand from which you would be making these savings. 

And so, I think your question kind of goes back to that root question we could 

use some helpful input on. And we can only note that in the course of 

illustrating these approaches, here it was most convenient to use the publicly 

available projected demand as Ryan was describing earlier from the annual 

energy outlook. 

Jared Synder: And well, does that project the demand, consider the impact of state energy 

efficiency program. 

Jeb Stenhouse: Well, to our understanding when we’ve worked with (CEIA) on this question 

in the past, the answer is, you know, that’s not a black and white issue. 

Because that’s the – obviously a dynamic thing over time. 
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And (DIA) at any point when they make projections, can only reflect what 

they know at the point they make the projection. So I think that’s a – I think 

the answer again there is a bit too nuanced to get into here. 

I would note that I think we feel we’ve maintained internal consistency in 

what we’ve just shown you in the TSD and the June proposal. Because we 

use the same demand projection both1 in quantifying building blocks for 

potential. So, you know, departing from those projections as well as 

accounting for electricity demand that could be faulted into the trait to mass 

translation. 

So, that struck as of the useful synchronicity here. But, this is a rich area that 

we look forward to your feedback on. 

Jared Synder: OK, well thank you very much. 

Operator: At this time, there are no further questions, Mr. Reid? Do you have any

closing remark? 

Reid Harvey: Thank you and thanks again to everyone for participating in this call. We 

hope this was a useful discussion for you and that this document is responsive 

to your request for some additional ideas on how to conduct a translation from 

the rate-based approach to massive equivalents. 

And, as always we appreciate your time and energy that you’re putting into 

this and look forward to hearing from you soon. 

Thank you. 

Operator: Thank you for participating in today’s conference call. You may now 

disconnect your lines at this time. 

END