State of Idaho

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

Technical Analyst 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 yearly 

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 Bryson

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/Robyn]

3. Idaho has no coal plants and has only two NGCC plants as affected units. The only way 

Idaho 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 plants 

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 artificially increase customer 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 incremental amounts needed to 

comply with EPA’s proposed 2030 goal. Jeremy Mark/Chris Sherry

4. How did the EPA incorporate existing hydropower into the state renewable energy targets 

in chapter 4 of the GHG Abatement Measures TSD? Was it done in the same way that 

existing 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 lower. 

Specifically, 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 Technical 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_by_State” in the Excell spreadsheet “20140602tsd-ghg-abatementmeasures-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 Bryson/Robyn 

DeYoung/Bill Meroney

Methodology/Policy Questions

6. What is the net import adjustment factor and what was the rationale for applying it to 

adjust Energy Efficiency targets in the goal calculation? Joe Bryson/Robyn deYoung

7. Did EPA factor in Regional Haze (RH) emission controls and efficiency losses due to 

parasitic loads in the baseline? If 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 affected units (Langley 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 Mark
9. 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 renewable 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-togas 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 

already 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 Bryson/Chris Sherry

13. How will the EPA handle unaffected EGU's (e.g. , a simple cycle 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