MEMORANDUM 

Date: August 1, 2015 

Subject: Projections for New, Modified, and Reconstructed Electric Utility 

Generating Units for the Carbon Dioxide New Source Performance 

Standards in Alaska, Hawaii, and the United States Territories 

From: Shelly Johnson, RTI International 

To: Christian Fellner 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

I. Introduction 

Under section 111(b) of the Clean Air Act (CAA), the U.S. Environmental Protection 

Agency (EPA) is required to establish new source performance standards (NSPS) for the fossilfuel-fired electric steam generating units and the combustion turbines source categories. The 

U.S. Supreme Court ruled that GHGs meet the definition of “air pollutant” in the CAA and 

premised that the CAA displaced any federal common law right to compel reductions in carbon 

dioxide (CO2) emissions from fossil fuel-fired power plants. The EPA is finalizing NSPS under 

CAA section 111(b) that, for the first time, will establish standards for emissions of CO2 for 

newly constructed, modified, and reconstructed affected fossil fuel-fired electric utility 

generating units (EGUs). The action establishes separate standards of performance for fossil 

fuel-fired electric utility steam generating units and fossil fuel-fired stationary combustion 

turbines. To be considered an EGU, the unit must: (1) be capable of combusting more than 250 

MMBtu/h (260 GJ/h) heat input of fossil fuel; and (2) serve a generator capable of supplying 

more than 25 megawatts (MW) net to a utility distribution system (i.e., for sale to the grid). 

The purpose of this memorandum is to present the information reviewed and 

methodology used to project the number of new, modified, and reconstructed emission units that 

may trigger NSPS in the 3-year period following the applicability date for the NSPS review in 

Alaska, Hawaii and the U.S. territories. The electric generating units NSPS is scheduled to be 

signed by August 3, 2015. The proposal date for new sources under this rule was January 8, 

2014, and the proposal date for modified and reconstructed units was June 18, 2014. The dates of 

proposal represent the applicability dates for NSPS, such that new sources or sources that are 

modified or reconstructed following the applicability date would be subject to the NSPS. 

Economic impact analyses consider the impacts of an NSPS over the 3 years following 

applicability of the NSPS. Therefore it is necessary to project the number of new, modified, or 

reconstructed emission units that would become subject to the revised NSPS in the 3-year time 

period from 2014 to 2017. Subpart TTTT of 40 CFR part 60 defines terminology that relates to 

when new sources commence construction, modification, or reconstruction. 
Projections for New, Modified, and Reconstructed EGUs for the CO2 NSPS in Alaska, Hawaii, and U.S. Territories 

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II. Alaska and Hawaii 

The U.S. Energy Information Administration (EIA) collects detailed data on the electric 

utility industry for the 50 states and the District of Columbia. Form EIA-860 collects generatorlevel specific information about existing and planned generators and associated environmental 

equipment at electric power plants with 1 MW or greater of combined nameplate capacity. 

Reporting in this form must be all existing plants and proposed (10-year plans) plants that: (1) 

have a total generator nameplate capacity (sum for generators at a single site) of 1 MW or 

greater; and (2) where the generator(s), or the facility in which the generator(s) resides, is 

connected to the local or regional electric power grid and has the ability to draw power from the 

grid or deliver power to the grid. In the case of generators located in Alaska and Hawaii which 

are not a part of the North American interconnected grid (U.S. EIA, 2014a and U.S. EIA, 

2014b), generators that are connected to a “public grid,” meaning a local or regional transmission 

or distribution system that supplies power to the public, must be reported on Form EIA-860 (U.S. 

EIA, 2015a). 

The latest Form EIA-860 is from 2013. In this form, utilities entered any planned 

upgrades or changes to existing generators and any proposed generators. Alaska and Hawaii 

reported planned electric utility power plants with expected years of starting operation that range 

from 2014 to 2018. The reported planned generation from these states did not include EGUs 

subject to the NSPS. Table 1 displays the proposed generation per prime mover type for Alaska 

and Hawaii. Combustion (gas) turbines and steam turbines are the only prime mover types that 

would be subject to this rule if they meet the remaining applicability criteria. The proposed 50 

MW of combustion turbine generation in Alaska was for Homer Electric Association's Soldotna 

plant in Kenai Peninsula County. The plant had begun construction before this rule was proposed 

and began commercial operation in March 2014, so it is an existing source. There are no other 

EGUs proposed that are capable of supplying more than 25 MW. Neither Alaska nor Hawaii 

reported any upgrades or repowering projects to units that would be affected by this rule 

indicating there are no planned modifications or reconstructions. 

Table 1: Proposed Generating Capacity for Alaska and Hawaii by Prime Mover Type.

Prime Mover Description Alaska

(MW)

Hawaii

(MW)

Energy Storage, Concentrated Solar Power 0 6

Combustion (Gas) Turbine 50 0

Hydroelectric Turbine 26 0

Internal Combustion Engine 178 11

Photovoltaic 0 74

Steam Turbine, including nuclear, geothermal and solar steam 17 9.3

Wind Turbine, Onshore 0 25

Total Generation (MW) 271 125

 Source: Based on U.S.EIA, 2015a 
Projections for New, Modified, and Reconstructed EGUs for the CO2 NSPS in Alaska, Hawaii, and U.S. Territories 

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III. U.S. Territories 

The inhabited U.S. territories that were reviewed to determine unit projections for new, 

modified or reconstructed EGUs were Puerto Rico, American Samoa, Guam, Northern Mariana 

Islands, and the U.S. Virgin Islands. The U.S. territories do not report utility sector data to Form 

EIA-860, so determination was derived from EIA Energy Profiles, territory-specific power 

reports and media articles. The applicability criteria states that EGUs not covered by the 

standards include stationary combustion turbines that are not physically capable of combusting 

natural gas (e.g., not connected to a natural gas pipeline). As none of the territories have access 

to a natural gas pipeline, they will not have any units that could be applicable to the standards for 

combustion turbine units. Only new, modified or reconstructed fossil fuel-fired electric utility 

steam generating units would be subject to this rule. 

Each of the territories relies heavily on petroleum products for electricity production. 

Each of these islands is very isolated and import all fossil fuels used at the electric power plants. 

Distillate fuel oil is the primary fuel source for these plants, but liquefied natural gas, jet fuel, 

kerosene, residual fuel oil and other petroleum products may also be imported for use as fuel. 

Due to the locations and resources available at each of the territories, there is a large focus for 

increasing the use of renewable fuel sources. Table 2 displays the population for each of the 

territories and their action plan goals for incorporation of renewable resources. American Samoa 

did not have a renewables action plan reported. 

Table 2: Population and Renewable Fuel Goals for Territory Action Plans

State or Territory Name Population Percent of Net Electricity  Sales

to Come From Renewables

Date for

Renewables Action

Puerto Ricoa     4,000,000   20% 2035

American Samoab           55,000        

Guamc         175,000   25% 2035

Northern Mariana Islandsd           54,000   80% 2015

U.S. Virgin Islandse         106,000   60% 2025

a U.S. EIA, 2015b, b U.S. EIA, 2015c, c

 U.S. EIA, 2015f, d U.S. EIA, 2015d, e U.S. EIA, 2015e 

Puerto Rico has the largest population of all of the islands and has one coal-fired EGU 

(U.S. EIA, 2015b). All electricity is supplied by Puerto Rico Electric Power Authority (PREPA), 

a government agency that owns the electric distribution system. PREPA has large debts and 50 

percent more capacity than is currently needed. The island has one coal plant that is not expected 

to modify or reconstruct. (Allen, 2015) It is not expected any EGUs will be newly constructed, 

modified or reconstructed in the near future. 

 American Samoa is a string of smaller islands with a generating capacity of 40 MW (U.S. 

EIA, 2015c) produced by four power plants. The largest power plant is 23 MW (FEMA, 2011); 

the rest of the plants are much smaller than this. A tsunami in 2009 crippled the island's power 

supply creating a need to build a 24.5 MW replacement plant (U.S. EIA, 2015c). No additional 

EGU capacity is needed for this territory. 
Projections for New, Modified, and Reconstructed EGUs for the CO2 NSPS in Alaska, Hawaii, and U.S. Territories 

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 Guam is the second largest territory by population. There are reports of Guam planning to 

build a 180 MW combined cycle unit that will have the capability to fire both liquefied natural 

gas (LNG) and distillate fuel oil (Pacific Islands Development Program, 2015). This unit would 

not be subject to this rule, as it does not meet the combustion turbine applicability criteria 

requiring access to the pipeline. With the planned construction of this unit and additional solar 

and wind projects, no additional need for more MW capacity from an EGU is expected. 

 Northern Mariana Islands has a total generation capacity less than 100 MW and a large 

focus on increasing generation from renewable resources to 80% of net electric sales by 2015. 

Their renewable plans include generation from waste gasification, geothermal, solar, and wind 

(U.S. EIA, 2015d). 

 The U.S. Virgin Islands have a total generation capacity of about 320 MW and average 

loads are less than half the capacity. They have recently constructed two solar facilities that add 

9 MW of generation. Between their goal of 60% net electricity sales from renewable resources 

by 2025 (U.S. EIA, 2015e) and the available generation in their fossil fuel-fired fleet, it is not 

expected there will be any newly constructed, modified or reconstruction EGUs that will be 

subject to this NSPS. 

   

IV. Conclusion 

From the available information and research conducted, we are projecting that no new fossil-fuel 

fired EGUs applicable to this standard will be built in Alaska, Hawaii, or the US territories 

between 2014 and 2017. 

V. References 

Allen, G. and Peñaloza M. 2015. Power Problems: Puerto Rico's Electric Utility Faces 

Crippling Debt. National Public Radio. Available at 

http://www.npr.org/2015/05/07/403291009/power-problems-puerto-ricos-electric-utility-facescrippling-debt 

FEMA. 2011. Critical Infrastructure Restoration: The Three-Phased Power Restoration Plan 

After the American Samoa Tsunami. Available at 

https://www.llis.dhs.gov/sites/default/files/GS_American_Samoa_Power_Restoration_Plan.pdf 

Pacific Islands Development Program, 2015. Guam Power Authority Approves New Power Plan 

Construction. Available at http://pidp.eastwestcenter.org/pireport/2015/January/01-28-14.htm 

U.S. EIA (U.S. Energy Information Administration). 2014a. Alaska. State Profile and Energy 

Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=AK 

U.S. EIA (U.S. Energy Information Administration). 2014b. Hawaii. State Profile and Energy 

Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=HI

U.S. EIA (U.S. Energy Information Administration). 2015a. Electricity. Form EIA-860 detailed 

data. Available at http://www.eia.gov/electricity/data/eia860/

U.S. EIA (U.S. Energy Information Administration). 2015b. Puerto Rico. Territory Profile and 

Energy Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=RQ
Projections for New, Modified, and Reconstructed EGUs for the CO2 NSPS in Alaska, Hawaii, and U.S. Territories 

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U.S. EIA (U.S. Energy Information Administration). 2015c. American Samoa. Territory Profile 

and Energy Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=AQ

U.S. EIA (U.S. Energy Information Administration). 2015d. Northern Mariana Island. Territory 

Profile and Energy Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=CQ

U.S. EIA (U.S. Energy Information Administration). 2015e. U.S. Virgin Islands. Territory 

Profile and Energy Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=VQ

U.S. EIA (U.S. Energy Information Administration). 2015f. Guam. Territory Profile and Energy 

Estimates. Available at http://www.eia.gov/state/analysis.cfm?sid=GQ