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 measures 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? Further, 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 each 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 presumption 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 not 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? Misha
8. 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 from 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. This 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 timely reach one of its goals 

under rule 111(d)? Colin Boswell