EPA Moderator: Reid Harvey 11
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**EPA Moderator**  **: Reid Harvey**  **November 7, 2014 12:00 p.m. E**  **T**
Operator : Good afternoon, m y name is (Angie) and I will be your conference operator

today . At this time, I would like to welcome every one to the Clean Power Plan, Rate to Mass Technical Support Document. All lines have been placed on mute to prevent an y 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 o n your telephone key

pad. To withdraw y our 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. Yes terday , 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. S o, we wanted to take this opportunity today to walk you through those examples and to field any questions y ou may

have. But providing the rates to mass TSD, responds to requests we’ve received from y ou and others and provides information to all stakeholde rs 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 actuall y that we posted online y esterday

afternoon. But, if y ou haven’t, it’s OK. Because theEPA Moderator: Reid Harvey 11
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Page 2 pur pose 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 Ry an Sims in our office to walk through the equations with y ou, let me give you a little b it 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 infor

mation, 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 - bas ed 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 yo u and others and I know that the administrator and the act ing 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 y ou think. We know, we feel for yo u well that

– like we’re overloading you but we appreciate your input. So, it’s been incredibl y instructive. So, just to wrap up, Iwanted to thank y ou for spending time again with us today to thank y ou for your willingness to dive into these issues with us. To lend us your expertise and to s hare yo ur 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 Ry an.EPA Moderator: Reid Harvey 11
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Page 3 Ry an 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 wh y 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 wh y we are where we are. So, first as y ou all are undoubtedly aware there are tw o 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 methodo logy

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 generall y about how an y 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 kn ow 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 m y time here but on the Q&A session, we’re certainl y open to entertaining a broader range of questions.EPA Moderator: Reid Harvey 11
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Page 4 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 deplo ym ent of the best sy stem 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 n ew 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 th ose blocks three and four

– again, it’s important to see the displacement between the new resources deplo yed 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 b y 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 historicall y based approach with both these methodologies. Th e 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 loo king 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 butEPA Moderator: Reid Harvey 11
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Page 5 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 appl y the (BSC) or building blocks to 2012 historical data, which is very similar to the rate
- based goals setting methodology

in which we rel y 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 le vel. 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 deplo y the B SCR 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 leve l 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 addingEPA Moderator: Reid Harvey 11
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Page 6 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, Ithink I’ll provide a little commentary on that. In that the rates that we’re applyin g to the massive (clone) generation level, again it’s a proposed rate
based 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 fro m 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 dir ectl y from the AEO projection. And each state we can observe what the 2012 historical sales data is for that state. And then, we can appl y the average annual growth rate to 2012 and we can specify what

– our reason like expectation of sales, going forwar d, from each ye ar from 2012 on.EPA Moderator: Reid Harvey 11
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Page 7 Then, to convert from a sales level to a generation level, we gross up b y 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 y ear. So, then we have the difference in generation required to meet demands from some future ye ar 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 block s 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) g oal 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, (staunchl y) associated with the proposed goals or option one but the alternative for option two g oals 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 appli es to 2030, and also to the nearest.EPA Moderator: Reid Harvey 11
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Page 8 So, Ithink 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

key pad. 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 Sy stem 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 St enhouse 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 sy stem wide modeling to look at, y ou 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 anal yt ic observation as a result of that illustrative modeling. And so, it’s useful to remind folks that that

– that in i t of itself is not a goal, if yo u will. Operator : Your next question comes from the line of Flo yd Gilzow of MPUA. Floyd Gilzow : Good morning this is Floyd Gilzow with Missouri Public Utility and Lines. In the earlier discussion describing the dif ference between option two

– or option one and option two, y ou referenced the fact that option two alsoEPA Moderator: Reid Harvey 11
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Page 9 included new sources. Could y ou clarify what yo u intended with the term new sources? Male : Sure, the intent was to mirror the proposal. Now the pro posal 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 buy er. 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 A EP. Scott Weaver : Good morning gu ys . 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 y ou have a

– I guess

– one o ption 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 a

pproval? And is this kind of a, Iguess, 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 actuall y
– subtracting out then adding in the renewable energy and energy efficiency components? Based on m y simple math, it looks like the affective generation used to calculate the mass

– it’s simply historical generation plus under constr uction natural gas combined cycle plus existing renewable energy when y ou get to that final megawatt hour number. But, I just wanted to verify that.EPA Moderator: Reid Harvey 11
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Page 10 Reid Harvey : Hi, Scott, this is Reid. We’ll sort of (divide) this up.

I’ll take the first question and then Ry an 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 in cluding 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, Ithink

– I would strongl y encourage folks to view this simply as y et 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 y ou’re going to take the second one? Ry an Sims : Sure, on the question the equation

– that

– in astute observation and true for

most States. Ithink 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 reall y 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 And y Kellen with WPPIEnergy
.EPA Moderator: Reid Harvey 11
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Page 11 Andy K ellen : Thanks gu ys . 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 majorit y 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 ye ar. I guess, I’m having trouble figuring out how that can be a (propert y) for a generation b y affected EGUs. You know, I would expect for example, in a reference case scenario, where yo u’re not adding renewables or efficiencies that the generation by affected EGUs would be a little h igher each ye ar as those you’d intend to ramp up to serve low growth. In this case, your numbers are flat every ye ar under the option one scenario. So, I guess, I’m just a little confused there. Ry an Sims : Sure, I think the number of (common) to (Negi nar) 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 part icularl y 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. Ithink 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 th inking 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.EPA Moderator: Reid Harvey 11
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Page 12 And how that states relate to the p articular illustrate of approaches of we’ve laid out here. Ry an Sims : Yes, I think that’s a good point. Just to ride on Jeb’s comment is Ithink 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 way s to conceive of what is equivalent to the rate
- based goal. And it brings clarit y 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, Ihave 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 b y subtracting the building blocks between four and generation from the existing fossil generation? Or would that adjustment be made onl y 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 t ake 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?EPA Moderator: Reid Harvey 11
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Page 13 Jeb Stenhouse : Yes, this is Jeb again. I think that what Ihear you describing are some r eally

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 buil ding blocks and their generation are reflected in the cop y, 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 reall y rich thinking there that we certainl y 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 Bo yl an 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 rene wable 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 fos sil 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 partl y wh y 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 y ou put y our finger on an issueEPA Moderator: Reid Harvey 11
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Page 14 we need to think a

bout carefull y 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 gue ss 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 i nitial proposal in June

– that that could accommodate some growth on some of the existing generating units. In the state of Florida, a lot of y our existing units have sufficient reserve capacity . That’s one of the reasons, I guess in yo ur 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 y ou’ve used that assumption in your mass base. Am Iincorrect that you’re leaning towards additional stringency in the June proposal? Jeb Stenhouse : Yes, yes. This is Jeb. You know, I think that

– and Iap preciate 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 way s of crossing from a rate based goal to a mass based equivalent

– it necessitates addressing that question and comin g out with some representation. We’ve shown y ou 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 an y wa y address the root issues about how y ou calculate state goals which are alread y i n front of the commenters through the proposal we started in June. And then, enriched b y the NODA discussion of the exchanges we’ve been having that you were just reflecting as well.EPA Moderator: Reid Harvey 11
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Page 15 And so, Ithink y ou’re indulging in some t ea leaves there that are very much not part of what were focusing folks on with this illustrative demonstration of how y ou might be rate to mass translation. Robert Kappelmann : Thank you. Operator : Your next question comes from the line of Peter Ashc roft of UT Office of

Energy
. Peter Ashcroft : Oh, y es other people have asked exactl y m y 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 havi ng 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 emb race. 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 opini on address these. L ooking at the

– the last ten or twent y ye ars 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 electricit y cost. While during the last... Male : Can I

– can I interrupt yo u? Darrell Preble : Yes.EPA Moderator: Reid Harvey 11
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Page 16 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 Prebl e : Yes. Male : We, you know, we set the rate goals for states based on an evaluation of the

best sy stem of emission reduction. Darrell Preble : I understand. Male : But we certainl y 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 L ois New, from New York Stat e 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 deploy ment 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 electricit y demand projection that we had already used in parts of the June proposal. Here, in order to quantify that factor, and so that means th at how the energy

information administration is anticipating that as one ingredient and all the ingredients they consider better electricit y demands trend kind of flows through and into this process. Operator : Your next question comes from the line of M att Roussy with State Corporate Commissioner.EPA Moderator: Reid Harvey 11
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Page 17 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 appr opriate 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

ye ars, 2023 to 2029 and then the final is the 2029 value it applied to 2030 and all subsequent y ears. 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 y ear to y ear in the megawatt

hours. Male : Sir, y ou’re (got) the megawatt hours as the ma ss equivalent generation level. Matt Roussy : Right, applied to the interim

– like with the (gladta) for the interim level. And

then y ou average that with megawatt hours themselves. For each y ear, 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 goa l 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 may be 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 fi gure could change based on the way you said the additions and subtractions for building blocks three or four. And I’m confused b y that. The rate did change. The rate does change from ye ar to ye ar but the megawatt hours do not. Male : Right, and so th e reason it’s a mass equivalent generation this was back a few

questions in the queue. Is that as new resources under building block threeEPA Moderator: Reid Harvey 11
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Page 18 and four deplo y, what they’re doing is that they’re displacing generation from existing affected sources from the hi storical 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, Ithink 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 y ear the way you’ve done it. And I

– if you do it differentl y for each ye ar, yo u 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, Iwanted 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 questio n as I’m looking at what y ou 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 (I SOs), the kind of metric low growth, which seems to be the right thing to compare to look at. B ecause 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 y ou can help me to better understand wh y 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).EPA Moderator: Reid Harvey 11
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Page 19 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 onl y work with the regions that we have. And so, a state may be a single (NEM) region. It can encompass several states and therefore it would be the average demand projection i n 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 v alue is? Jeb Stenhouse : Yes, this I , Jeb. I think that’s a great example of exactly wh y we wanted

– yo u 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 he re. 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 ty

pe of input. Dave Coup : OK, and thanks again for holding this session. Operator : Your next question com es 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 ty pe of option? Jeb Stenhouse : Yes, this is Jeb, I’m glad y ou 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? L ike 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
.EPA Moderator: Reid Harvey 11
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Page 20 Sean Alteri : Yes, this is Sean Alteri, thank y ou for this illustrative example for the mass

conversion. M y 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 b y 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 t ype o f implementation. So, Ithink 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 stil l 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 y our state or in

the (Reggie) regions are read y through compliance jus t 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 go al? 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).EPA Moderator: Reid Harvey 11
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Page 21 Operator : Your next question comes from the line of Lois New with New York State

Department of Environmental Conservation. Jared Sy nder : Hi, this is actually Jared Sy nder 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 mul tiplyingthe

– you know b y 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 blo ck 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 ele ctricity demand from which you would be making these savings. And so, Ithink y our 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 w as most convenient to use the publicly available projected demand as Ry an was describing earlier from the annual energy outlook. Jared Sy nder : And well, does that project the demand, consider the impact of state energy

efficiency program. Jeb Stenhou se : Well, to our understanding when we’ve worked with (CEIA) on this question

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

– obviously a d yn amic thing over time.EPA Moderator: Reid Harvey 11
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Page 22 And (DIA) at an y point when they make pro jections, can onl y reflect what they know at the point they

make the projection. So Ithink 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 sy nchronicit y here. But, this is a rich area that we look forward to your feedback on. Jared Sy nder : 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 alway s we appreciate your time and energy that you’re putting into this and look forward to hearing from you soon. Thank you. Oper ator : Thank you for participating in today ’s conference call. You may now disconnect your lines at this time. END