August 21, 2014 

New Hampshire’s List of Questions (due 8/21) for 8/26 10:00 call with EPA on 111(d)

1. Building block #1 calls for a 6% reduction in the CO2 emission rate from coal plants. Is this 

achievable, given that Merrimack Station already did a heat rate improvement project?

2. Building block #2 calls for total redispatch from 2012 generation (1,281,341 MWh from coal, 

6,946,869 MWh from natural gas combined cycle (a 53% capacity factor based on nameplate 

capacity), and 72,614 MWh from oil) to 8,300,824 MWh from natural gas only (a 63% CF). Last 

winter when demand for natural gas increased for home heating purposes, coal plants had to 

come back on line to meet electricity demand. Does this assume that a natural gas pipeline 

project will be completed? What timeframe? If so, given that electricity generation is regional 

in nature, why did EPA limit redispatch to just in-state generation? Why didn’t EPA allow the 

maximum 70% CF? Plants in other New England States have already announced intended 

shutdowns, and that power generation will have to be replaced, possibly by increased 

generation from NH NGCC plants. 

3. Building block #3: The “Alternative Renewable Energy Approach” based upon technical and 

economic potential as described in EPA’s Technical Support Document posted on EPA’s website

seems to be more reasonable for NH. In 2012, NH’s non-hydro renewable generation was 

primarily from wood. One new 70 MW biomass plant has come on line, but additional biomass 

plants are not anticipated, because the forests may not be capable of additional sustainably 

harvested supply. Also, significant amounts of new wind capacity are not anticipated, because 

siting new wind farms has been a very difficult process recently in NH. Also, NH DES 

understands that EPA intends to prevent double counting of RE in the final guidelines by 

stipulating that whichever state’s RPS requires a given REC to be retired will get credit for that 

RE, regardless of which state the RE was generated in. New England REC markets are such that 

RECs go first to MA (highest REC price), then CT, then NH (lowest REC price). This is yet another 

reason why NH projects that future RE will be significantly less than that in EPA’s proposed 

approach. In EPA’s proposed approach, EPA looked at an average of the New England States’ 

RPS aspirational targets. ME’s 40% (including hydro) skewed that average (25%), and ME is 

already close to meeting their target, but other states don’t have that same potential. Can EPA

confirm that the recalculated the individual NH state goals (558 lb/MWh with hydro and 619 

lb/MWh without hydro) using the alternative approach as shown on the attached spreadsheet 

are correct? Which one is appropriate? Is EPA leaning toward going with the Alternative RE 

Approach for the final guidelines?

4. Building block #4: ISO-NE forecasts near-term future EE. As an alternative to EPA’s projected EE 

estimates, could NH extend the ISO-NE forecast based on a multi-year average of the latest 

years and use that?

5. EPA included updated RGGI in the base case, awarding no credit for reducing from 91 million ton 

2014 cap to 78.2 million 2020 cap, in addition to no credit for 40+% reduction from 2005 to 

2012. For mass-based programs, can equivalency be demonstrated based on a percent 

reduction from 2005 greater than 30%, rather than a “conversion” of the 486 lbs/MWh ratebased goal? If no, what amount of RE (and nuclear) and EE can NH include in its projection? 

Only 2012 levels? Why can’t NH include all of the RE and EE that EPA included in its calculation 
August 21, 2014 

of the rate-based goal? EPA’s building block #2 for NH assumes that all coal-fired generation is 

re-dispatched to gas, resulting in projected NH 2020-2030 annual emissions of 3,644,062 tons, 

providing an incentive for increased operation of existing lower-emitting (878 lb/MWh) NGCC 

plants. Would EPA agree that NH’s mass-based goal should be at least 3,644,062 tons? 

6. Has EPA been asked by NGOs to provide EPA’s presumptive translation of the rate-based goal to 

the mass-based goal, for all 49 States? If so, is EPA leaning toward doing so? When?

7. The RGGI States are planning to do modeling. Can EPA review the assumptions made by each 

state prior to the modeling runs? Did EPA recently have a call with NY? While NH is much 

smaller than NY, NH shares many of the same issues. Is there anything that was discussed on 

the call with NY that NH is forgetting to raise here?