**Alaska Questions for EPA Region 10 Call August 7, 2014** 

1. To help assure our understanding is correct , can EPA walk us through the specific goal calculations for Alaska identifying the specific data and assumptions used , particularly where any assumptions were based on data or situations from outside of Alaska ? Jeremy Mark/ Brian Fisher

2. How may the utilities and the state quantify and capture renewable energy projects and energy efficiencies achieved since 2005? Are there any particular GHG m easures or alternative power sources (e.g. new hydroelectric) that may not be used to meet the proposed state goals or that would be treated differently than other measures or sources used to meet the state goals ? Matt Clouse/James Critchfield; Joe Bryson /Robyn deYoung

3. What sort of legal obligations or compliance monitoring arise under an EPA

- approved state plan? What are the consequences if a state fails to timely meet the goals in the plan? May a
state quantify, capture and utilize reductions in CO2 emissions from electric generation
sources in the state that are not among the listed power plants in its plan? If so, with what limitations? What is the legal basis for these limitations? Chris Sherry

4. The deadlines in the proposed rule may not line up well with reasonable timelines for scoping, permitting, financing, constructing and commissioning of new power and transmission infrastructure. What flexibility is there to extend the deadline for reaching the goal to match reality? Fur ther, if reaching the GHG reduction goal is the priority, how will this affect other federal decisions under NEPA, ESA and other federal statutes? Particularly given the processes involved under these statutes can extend the time needed to get projects permitted? Is EPA prepared to actively support development of renewable, zero emission sources of power as proposed projects proceed through federal licensing and permitting processes? Jim K

- C

5. The proposed rule appears to be based on the presumption that eac h state produces power from large plants connected to a grid where power switching can be used to minimize the production of power from higher GHG emission sources. What accommodations are there in the proposed rule for states like Alaska where this presu mption doesn’t hold true? Can GHG reduction measures undertaken in the power generation sector in Alaska, but which don’t reduce GHG emissions “from the grid,” still be counted in meeting the state’s goal? Is there any mechanism that Alaska might explore for doing this, either that is in the current law, proposed rule, or a new provision that might be added to the draft rule? Misha

6. Alaska has power plants that may convert from liquid fuels to natural gas in the relatively near future. These plants are n ot currently included in establishing Alaska’s target goals and the natural gas emissions would be less than the liquid fuel emissions. How would the state handle such a conversion? Could Alaska quantify and capture the emission improvement and apply it toward achieving the target rate under the new 111(d) rule ? Would the new section 111(b) rule also apply? Christian Fellner/Misha

7. Did EPA conduct any Alaska

- specific economic analysis as part of the RIA? What Alaska data or assumptions were used by EPA in looking at regulatory impacts? Misha8. Could Alaska choose to participate, in some degree, in a regional cap and trade approach

with other states even though all of the electricity used in Alaska is produced in Alaska and no power is currently exported f rom Alaska ? Chris Sherry

9. Did EPA perform any calculations on the associated cost and timing of electric transmission upgrades that would be required in Alaska for the state to take full advantage of proposed BSER blocks 2 and 3? Misha/James Critchfield

10. The primary objective of the proposed 111(d) rule is to reduce GHG emissions from public power plants, primarily through the states’ development and implementation of plans that strongly favor lower

- carbon emitting plants and user efficiency measures. Thi s objective, draft rule and state plans may come into conflict with other sets of goals and requirements set by public utility commissions and other bodies that approve other plans and rate structures for public electric utilities. How are state agencies, who are required to develop and implement the plans required under the proposed 111(d) rule, expected to deal with these conflicts, particularly if they might cause a state not to timel y reach one of its goals under rule 111(d)? Colin Boswell