State of Idaho EPA Proposed Rules for Section 111(d) of the Clean Air Act

Technical Anal ys t Questions to the EPA **Technical Questions** 1. Why is the sales figure measured at generation of 25,492,620 MWh (see column AP in 20140602tsd

- state
- gaol

- data

- computation

- 1.xls) when converted to sales at customer meter of 23,711,859 MWh (25,492,620 MWh / 1.0751) used to determine the yearl y energy efficiency

potential different than the figure used to derive the 2012 BAU Sales figure (23,731,655 MWh) for calculating the Energy Efficiency

baseline for Idaho? The difference appears to be due to an inconsistent exclusion of adjustments to Bonneville Power Administration sales in the tab labeled F861_2012_file2 in the TSD_GHG_Abatement_measures excel file. Jeremy Mark /Joe Bry son 2. What was the amount of in

- state generation and sales used to calculate the net import adjustment factor for Idaho? What was the source of data used? Jeremy Mark [link with #6 and hand

- off to Joe/Roby n] 3. Id aho has no coal plants and has onl y two NGCC plants as affected units. The only way Id aho can meet its goal using EPA's calculation method is to run its NGCC plants at or below 2012 baseline capacity factors, even though the utilities that operate those p lants have coal plants in other states. This will ultimately limit the utility 's ability to offset coal in other states contributing to higher CO2 emissions, nationally , while at the same time impose operational constraints that artificiall y increase cus tomer rates. How much more Energy Efficiency

and Renewable Energy

would Idaho need to implement in order to offset emissions from its affected NGCC units running at EPA prescribed 70% capacity factors (See Building Block 2) when compared to the increment al amounts needed to comply with EPA’s proposed 2030 goal. Jeremy Mark/ **Chris Sherry** 4. How did the EPA incorporate existing h ydropower into the state renewable energy targets in chapter 4 of the GHG Abatement Measures TSD? Was it done in the same way that e xisting wind, solar, or other forms of renewable energy were incorporated into the goals? **James Critchfield**5. There appears to be an inconsistency in load growth assumptions between the reliability /resource adequacy

assessment and the energy efficiency

(EE) target calculations for building block 4. The EE target calculations shows that loads will be higher in 2020 even with a reduction in load due to policy driven EE, while the reliability /resource adequacy

study states that overall loads in 2020 will be low er . Specificall y, EPA concludes in 2020, the policy case results in no impact to reliability or resource adequacy

from a 3.5% reduction in summertime peakload capacity due to a nationwide 3% reduction in load from EE as a result of the policy (See Technic al Support Document: Resource Adequacy and Reliability Analysis , p. 4, (June 2, 2014). However, EPA’s energy

efficiency

target calculation from an overall U.S. perspective (as illustrated in worksheet “Sorted_b y_State” in the Excell spreadsheet “20140602tsd

- ghg

- abatement

measures - scenario1.xlm”) shows an increase in total nationwide sales after EE has been applied as a result of the policy with 3,678,577 GWh in 2012 and 3,813,590 GWh in 2020. Please explain the discrepancy in the two sets of assumptions. Joe Bry son/Roby n DeYoung/Bill Meroney
**Methodology/Policy Qu estions**  6. What is the net import adjustment factor and what was the rati onale for applyingit to adjust Energy

Efficiency

targets in the goal calculation? Joe Bry son/Roby n deYoung 7. Did EPA factor in Regional Haze (RH) emission controls and efficiency losses due to parasitic loads in the baseline? I f not, are there specific provisions that will ensure RH emission controls are exempted from the definition of modification under current NSPS regulations (40 CFR 60.14.) Jeremy Mark/Juan Santiago 8. One of Idaho's a ffected units (L angley Gulch) included in the 2012 baseline was a new facility which did not come on line until halfway through 2012. This is reflected in the number of megawatt

- hours and in the baseline emission rates. How would EPA suggest we adjust for this as an anomaly in Idaho's goal? Jeremy

Mark9. Why did EPA use all generation in the state of Idaho, including existing Hydropower, to calculate the renewable energy cap while at the same time excluding existing Hydropower from the 2012 existing rene wable baseline amount? James Critchfield 10. In a state with significant hydro and wind resources, if the compliance measurement period is during a period of extended severe drought or other significant natural event, would EPA provide some sort of adjustment factor to normalize the measured result based on weather? Chris Sherry 11. In what circumstances can new NGCC units be used for compliance to 111(d) rules? Because the calculation of BSER does not include new NGCC, how would it be treated? Would it be added in as an affected unit and then energy re - dispatched to it from coal

- t o gas thus affecting both the numerator and the denominator? Would the facility be subject to both 111(d) and 111(b) rules? Chris Sherry /Colin/Juan (OAQPS) 12. EPA has stated in its proposed rules that it recognize and take advantage of the progress alread y made by

existing programs. In light of this statement, how will states get credit for early efforts to implement Energy Efficiency

prior to 2012 and after 2012 prior to measuring for compliance ? Joe Bry son/ Chris Sherry 13. How will the EPA handle unaffected EGU's (e.g. , a simple cy cle plant) that are operated past the affected unit threshold? Will the EPA designate them as affected EGU's after the fact? Juan 14. It is not clear how EPA will ensure accountability for merchant fossil fuel generation that is not used to meet a state’s native load. How would the EPA hold the States accountable that use the generation? Juan/Chris Sherry 15. How would a state calculate the contribution of fuel

- switching from electricity to natural gas end uses (i.e. space and water heating) in the calculation of compliance to the goal? Chris Sherry