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List of technical questions from Nevada for EPA:

1. Assumptions re goal calculation and potential compliance scenarios:

a. Some states have said that 2012 was an anomalous year because natural gas prices 

were so low. Has EPA considered averaging emissions from a longer range to use as 

the basis for its goal computation?

b. The national average of 70% NGCC capacity is unrealistic for many states. In 

Nevada, we face a unique situation where electricity consumption continues 

throughout the night and NGCC plants are used as peakers, not baseload capacity. 

Currently evaluating whether 50% is realistic. Did EPA do any such analysis, or just 

look at national average?

c. Building block 3 (RE) is calculated based on 2012 electricity demand but does not 

account for load growth. If load were to grow, we would basically need to add more 

renewables than natural gas in order to reach/maintain the goal (because the goal 

of 647 is significantly less than the new source performance standard for new or 

modified NGCC plants). Has EPA considered adding load growth to its equation, and 

if so, what growth percentage does it believe is reasonable?

d. Building block 3 (RE) is calculated based on an average of State RPS standards, for 

those that have them. Yet Nevada’s RPS is inconsistent with EPA’s treatment of 

renewables as described in the TSD. For example, Nevada’s RPS allows small hydropower (<30 MW), some energy recovery from waste heat generation (<15 MW) and 

banking of renewable generation in excess of the standard. Would NV be allowed to 

include any of these aspects in its Plan? Is waste heat recovery an RE measure or an 

EE measure? (NV Energy has a plant (Goodsprings) that recovers waste heat from 

natural gas compressors that is then used to drive an electrical generator; credits 

apply to Nevada’s RPS compliance.)

e. EPA has mentioned that they have done compliance runs for NV that include some 

proportion of coal generation. Can you walk us through this analysis? More 

specifically, we anticipate a realistic scenario where one coal-fired EGU, TS Power, 

would continue to operate in NV past 2030 since it’s a fairly new plant 

commissioned in 2008. We are unable to derive a reasonable scenario that meets 

the 2030 NV goal with this plant still in operation. Does EPA have any suggestions as 

to how NV could reasonably meet the goal with this plant in operation? Our analysis 
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suggests that renewables generation would have to increase by 63% above EPA’s 

goal calculation to compensate for this coal generation, which seems unrealistic and 

exceeds our RPS of 25%.

f. Non-Affected EGUs are not included in the numerator of the rate goal calculation. 

However, they are included in the denominator of the RE calculation. Why is this 

inconsistent approach used when performing the RE calculations vs. the rate 

efficiency calculations?

g. Have the potential effects of long-term drought in the west been factored into the 

rule? Under the proposed rule, if drought conditions persist and reduce hydropower 

generation during the period of compliance, the lost generation would have to be 

quickly made up by one of the building blocks. This may not be possible given the 

long time frames necessary to shift power generation away from fossil fuel intensive 

sources. This unplanned for event could result in non-compliance with either the 

interim or final goals. Has EPA made allowances for unanticipated events or 

conditions effecting power generation that might prevent a state from attaining its 

goal?

h. For determining the energy savings from EE measures, does the expected lifetime of 

each EE measure have to be accounted for, or is some default program lifetime 

assigned to all EE programs? Are EE programs, and their associated electrical 

generation savings rates, expected to be maintained after the final goal year of 

2029?

i. The PUCN is considering NVE’s request to join the CAISO Energy Imbalance 

Market. Participation in this market will improve the efficiency of operation of the 

participating utilities and reduce green house gas emissions. How does a program 

like this contribute to the EE building block?

j. The PUCN is considering a Volt Var Optimization program which will reduce energy 

consumption on affected transmission and distribution circuits. How does a program 

like this contribute to the EE building block?

k. How do solar thermal programs contribute to the EE Building Block?

2. Tribal issues:

a. Where renewables are built on tribal land and purchased by a utility for use beyond 

tribal land, does that count toward RE?
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3. Enforceability:

a. What is a federally enforceable plan for RE or EE measures? For example, is an RPS 

“federally enforceable”, or will EPA require that it be named as a third party 

beneficiary under power purchase agreements in order to enforce them? 

4. Other issues:

a. We have heard that some states are pushing back on the goal calculation for 

renewables. In the proposed rule, if it is generated in your state, you receive 

“credit” for it. But some states believe they should receive credit for out-of-state 

renewable energy generation since they paid for it. If EPA ultimately agrees with the 

latter view, since it is one of the building blocks and will result in a complete 

overhaul of the calculation of states’ goals, shouldn’t that rule be re-proposed rather 

than made final?