From: Hackel, Angela 

Sent: Friday, June 5, 2015 10:24 AM 

To: Nathan_J._Frey@omb.eop.gov 

Cc: Culligan, Kevin; Vasu, Amy 

Subject: Slides for Today's Inter-agency Briefing on the Clean Power Plan Final Rule 

Hi Nathan, 

I hope this email finds you doing well! Kevin, asked me to send you the attached. He will be 

walking through these at today’s interagency briefing. 

 

Please let me know if you have any questions. 

 

Thanks and have a great day! 

Angela 

<< CPP_Interagency briefing_June 5 2015.pptx >> 
Clean Power Plan: 

Overview of Draft Final Ru

Kevin Culligan

Associate Division Director, SPPD

U.S. EPA

June 5, 2015
Deliberative – Do Not Cite or Quote 

Overview

► The Best System of Emission Reduction (BSER)► CO2 Emission Performance Rates and State Goa► State Plans► Electric System Reliability Assurance
Deliberative – Do Not Cite or Quote 

The Best System of Emission Reduction (

► BSER is comprised of the first three building blocks (BBs); 

longer included

► Core concept of each BB has been retained, but with refine

reflect new data and to address stakeholder comments

► BB1 – in range of 2.1- 4.3 percent by region (6 percent nation

proposal)

► BB2 – 75 percent net summer capacity (70 nameplate capaci

proposal)

► BB3 – greater use of RE (based on techno-economic approac

updated NREL data), inclusion of new NGCC, and removal of 

► Achievability of all BBs is facilitated by plans’ ability to auth

tradable credits or allowances

► BBs are quantified consistently in terms of ability to produc

incremental emission reductions

► BBs are quantified at regional (interconnection) level to pro

regional emission performance rates by technology categoguidelines use the least stringent regional rates of any regioregions 
Deliberative – Do Not Cite or Quote 

CO2 Emission Performance Rates and Sta

► CO2 Emission Performance Rates

► We are setting emission performance rates for the two sub

affected EGUs

• Fossil fuel-fired electric utility steam generating units: 1290 lb• Stationary combustion turbines: 780 lbs per MWh

► These are uniform and equitable for the sources across th

category, regardless of location

► State Goals

► We are providing mass-based and rate-based state goals► Goals are translated from the subcategory-specific emissio

performance rates

► Interim Rates and Goals

► EPA is providing interim CO2 emission performance rates 

mass- and rate-based goals for:

• The 8-year interim period (2022-2029) and, • For each of three steps, 2022-2024, 2025-2027, and 2028-20
Deliberative – Do Not Cite or Quote 

State Plans► Plan Options

► Emission standards approach► “State measures” approach, based on proposal’s “portfo

• Would include state-enforceable measures that may apply 

EGUs and other entities, with some or no federally enforcstandards for affected EGUs, and a backstop of federally standards on affected EGUs

► State Plan Submittal Timing

► 13 months for initial plan submittal (August 31, 2016)► 3 years for final plan submittal (August 31, 2018)

► Options Beyond BSER Measures

► States may choose from numerous options, including:

• Demand-side EE, including through emissions trading• Transmission upgrades• Nuclear and hydro uprates
Deliberative – Do Not Cite or Quote 

State Plans (cont.)► State Plan Submittal 

► Emission guidelines specify required components of a s► Submittal must include a demonstration that affected EG

meet:

• Interim step CO2 emission performance rates or state CO

interim step goals on average over the 2022-2024, 2025-22028-2029 periods

• Final CO2 emission performance rates or state CO2 emiss

later than 2030

► Timing for Demonstration

► State is required to compare emission levels achieved b

EGUs with emission levels projected in the state plan aresults to the EPA

• Beginning January 1, 2025, and then January 1, 2027, fol

January 1, 2029, and then every two calendar years

• Reporting is required by July 1 of those calendar years
Deliberative – Do Not Cite or Quote 

Electric System Reliability Assurance► Timing

► Start date of 2022 and approach for interim goals gives more tim

consultation and decision making in the formulation of state plans choice of compliance strategies 

► Requirements

► Each state must provide documentation, in its plan submittal, tha

considered reliability issues in developing its plan

► Reliability Safety Valve

► A one-time short-term modification to enforceable requirements p

EGU or EGUs under an approved plan, initiated by the state

• When conflict between rigid state requirements and maintenance of r

unanticipated emergency triggers need for immediate short-term relie

• State must notify EPA with written concurrence from planning authori• States must meet goals

► If problem not resolved at end of period, state must revise its plan► States plans that allow for flexible approaches such as trading an

would not need to use this mechanism

► Memorandum

► EPA, DOE and FERC will document joint understanding of how th

coordinate efforts to help ensure continued reliable electricity gentransmission during implementation of the final rule