UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

AIR AND RADIATION 

MEMORANDUM 

ubject: 

From: 

To: 

Summary of Stakeholder Meetings 

Carissa Cyran 

Dockets EP /\-HQ-OAR-20 13-0602. EPA-HQ-OAR-20 13-0603. and EPA-HQOAR-20 13-0495 

This memorandum summarizes meetings with stakeholders during the week of .July 20. 2015. 

On .July 21 , Associate Assistant Administrator for Climate and Senior Counsel for Air and 

Radiation Joseph Goffman met with representatives from the National Rural Electric 

Cooperative Association. Sign-in sheet and handout arc attached. 

On Jul y 23. Administrator Gina McCarthy. Acting Assistant Administrator lo r Air and Radiation 

Janet McCabe, and Assoc iate Assistant Administrator for Climate and Senior Counsel for Air 

and Radiation Joseph Goffman met with President Richard Trumka and other representatives 

from the AFL-CIO. 

On July 24. Senior Advisor for Congressional and International Affairs to r Air and Radiation 

William Niebling and Senior Policy Advisor for Air and Radiation Deborah Jo rdan met with 

representatives from Arizona·s Public Service Company. Sign-in sheet attached. 

Internet Address (URL) • nnp //www epa gov 

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Date: July 21, 2015 

Meeting: Rural Utilities 

Rule(s) Discussed: C,PP 

Written Materials@No: 

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CPP Extended Compliance Averaging/Borrowing Plan Option to Avoid Small System 

Stranded Generation Assets 

Problem 

Many smaller systems have tew options to meet CPP compliance because they lack the diverse 

generation sources of larger utilities. 

For these small systems closure of even one coal-fired unit premature closure would depri ve 

them of a very substantial portion if not the bulk ofthe system's generation capacity. 

Premature closure of a unit with an outstanding debt obligation could put a small utility in 

financial stress by forcing it to fund new generation while at the same time servicing the 

outstanding debt for a stranded asset no longer useful as a generation source. In essence the 

system would be paying twice for a significant portion of its total generation requirements. 

Option 

To reduce the risk that smaller systems wi ll not be thrust into financial stress due to CPP 

compliance obligations that force unit premature shutdowns, EPA could incorporate an extended 

compliance averaging plan option into the CPP to allow those select units who choose to take 

advantage of the option to operate long enough to pay off unit debt while at the same time 

ensuring that CPP C02 mitigation goals are ultimately achi eved. Under this voltLntary option: 

• The unit taking advantage of the extended compliance averaging option may not operate 

beyond the year in which the unit's debt obligation is fully met. 

• The extended compliance averaging period cannot extend beyond the unit's projected 

remaining engineering useful life. 

• A unit's shutdown obligation must be enforceable and the averaging plan requirements 

must be included in the unit's operating permit and in the CPP implementation plan. 

• Taking into account the avoided emissions resulting from the retirement of the units 

before their projected remaining engineering useful life, an approvable averaging plan 

would ensure emissions neutrality defined as demonstrating total emission reductions 

over the averaging period eqtLal to or greater than the emjssion reductions the llnit would 

be subject to under the CPP. 
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