# Technical Support Document for

Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian

Country

October 1, 2014TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

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## CONTENTS Acronyms and initialisms ................................ ................................ ................................ ............................... i Introduction ................................ ................................ ................................ ................................ .................. 1 Affected electricity generating units on tribal lands ................................ ................................ .................... 1 Overview ................................ ................................ ................................ ................................ ................... 1 Data ................................ ................................ ................................ ................................ ........................... 2 BSER factors informing tribal lands’ emission rate goals ................................ ................................ .......... 3 Building block 1 – heat rate improvement at coal -fired power plants ................................ ................. 3 Building block 2 – redispatch to lower-emitting NGCC EGUs ................................ ............................... 3 Building block 3 – renewables ................................ ................................ ................................ .............. 3 Building block 4 – energy efficiency ................................ ................................ ................................ ...... 4 Affected electricity generating units in U.S. territories ................................ ................................ ................ 4 Overview ................................ ................................ ................................ ................................ ................... 4 Data ................................ ................................ ................................ ................................ ........................... 7 BSER factors informing territories’ emission rate goals ................................ ................................ ......... 10 Building block 1 – heat rate improvement at coal -fired power plants ................................ ............... 10 Building block 2 – redispatch to lower-emitting NGCC EGUs ................................ ............................. 11 Building block 3 – renewables ................................ ................................ ................................ ............ 11 Building block 4 – energy efficiency ................................ ................................ ................................ .... 11 

## ACRONYMS AND INITIAL ISMS BSER best system of emission reduction CC combined cycle CO 2 carbon dioxide CT combustion turbine EGU e lectric generating unit GHG greenhouse gas GPA Guam Power Authority ICE internal combustion engine LNG liquified natural gas NGCC natural gas combined cycle PREPA Puerto Rico Electric Power Authority ST steam turbine VIWAPA U.S. Virgin Islands Water and Power AuthorityTSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

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## INTRODUCTION In the June 2014 Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (hereafter referred to as “June 2014 proposed rule”), EPA proposed to establish carbon dioxide (CO 2 ) emission guidelines for existing electricity generating units (EGUs) in th e 50 states of the U.S. The Agency also indicated that it would propose a supplemental rule that included CO 2 guidelines for existing EGUs in the territories and areas of Indian country (hereafter referred to as “tribal lands” ) . Based on the June 2014 proposed rule, the Agency identified the best system of emission reduction (BSER) that, taking into account the cost of achieving emission reductions and non -air quality health and environmental impact and energy requirements, the Administrator determines has been adequately demonstrated. Based on its evaluation of adequately-demonstrated greenhouse gas (GHG) abatement measures, the Agency listed four categories, or “building blocks,” that are technically viable and broadly applicable, and can provide cost-effective reductions in CO 2 emissions from existing EGUs. These “building blocks” include: 1. Reducing the CO 2 intensity of generation at individual affected EGUs through heat rate improvements; 2. Reducing emissions from the most CO 2- intensive affected EGUs in the amount that results from substituting generation at those EGUs with generation from less CO 2- intenstive affected EGUs (e.g., natural gas combined cycle (NGCC) EGUs); 3. Reducing emissions from affected EGUs in the amount that results from substituting gen eration at those EGUs with expanded generation at low- or zero-CO 2 EGUs; and, 4. Reducing emissions from affected EGUs in the amount that results from the use of demand -side energy efficiency that reduces the amount of generation required. The Agency believes that for purposes of Clean Air Act section 111(d), as applied to the power sector, the BSER encompasses all four “building blocks.” This Technical Support Document (TSD) describes how the Agency applied the BSER from the June 2014 proposal to affected EGU s on tribal lands and in territories. 

## AFFECTED ELECTRICITY GENERATING UNITS ON TRIBAL LANDS Overview There are four power plants with 12 affected EGUs on tribal lands (see Table 1 ). Three plants combust coal and one plant has two NGCC EGUs . The EGUs on tribal lands operate as part of an integrated electricity grid and supply the majority of their electricity generation to customers outside the tribal lands. The Agency did not find any information about grid -connected renewable energy existing in 2012 on tribal lands with affected EGUs and, therefore, assumed no existing renewable energy sources. **Table 1**  **: Potentially a ffected EGUs on tribal**  **lands Tribe**  **ORIS Plant name**  **Unit Fuel**  **Unit type Capacity**  **(MW) Navajo**  2442 Four Corners 1 coal steam turbine 190TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

2 **Navajo** 2442 Four Corners 2 coal steam turbine 190 **Navajo** 2442 Four Corners 3 coal steam turbine 253 **Navajo** 2442 Four Corners 4 coal steam turbine 818 **Navajo** 2442 Four Corners 5 coal steam turbine 818 **Navajo** 4941 Navajo Generating Station NAV1 coal steam turbine 803 **Navajo** 4941 Navajo Generating Station NAV2 coal steam turbine 803 **Navajo** 4941 Navajo Generating Station NAV3 coal steam turbine 803 **Ute** 7790 Bonanza 1 coal steam turbine 500 **Fort Mojave** 55177 South Point Energy Center A gas NGCC 236 **Fort Mojave** 55177 South Point Energy Center B gas NGCC 236 **Fort Mojave** 55177 South Point Energy Center ST1 gas NGCC 236 

## Data The 2012 CO 2 emissions and electricity generation data for the EGUs listed in Table 1 are taken from the document titled, 2012 Unit-level Data Using the eGRID Methodology. 1 Inform ation about the source of these data and the methodologies used to compile the data set is described in Description of 2012 UnitLevel Data Using the eGRID Methodology. 2 The information available to the Agency indicates there was no generation from utility-scale, grid connected renewable energy in 2012 in the three tribal lands with affected EGUs . This was based on a review of information from EIA, DOE’s Office of Indian Energy, and tribal utility authorities serving tribal lands with affected EGUs. Data required for the calculation of building block 4 goals for tribal lands and their sources are: 1. 2012 electricity sales (MWh): Form EIA-861 3 2. 2012 energy efficiency incremental effects – total (MWh): Form EIA-861 4 3. Projected annual electricity sales by region (2012 -2040): AEO2013 Reference Case 5 These data are inputs to the supporting technical files to this TSD [reference EE spreadsheet files] . Table 2 summarizes data o n 2012 electricity sales for tribal lands by state and utility . None of the tribes reported energy efficiency data on their Form EIA-861 submittals for 2012. P rojected annual electricity sales by region are included in the supporting technical files to th is TSD. **Table 2**  **: 2012 total electricity sales for tribal lands**  **Tribe Utility**  **n umber**  **Utility n**  **ame State**  **Total s** **ales (MWh)**  **Ute** 12866 Moon Lake Electric Assn Inc UT 470,007 **Navajo** 13314 Navajo Tribal Utility Authority AZ 548,934 **Navajo** 13314 Navajo Tribal Utility Authority NM 117,010

1 Available in the docket EPA- HQ-OAR- 2013 -0602 at http://www.regulations.gov/#!documentDetail;D=EPA- HQOAR-2013 -0602-0254 . 2 2 Available in the docket EPA- HQ-OAR-2013 -0602 at http://www.regulations.gov/#!documentDetail;D=EPA- HQOAR-2013 -0602-0257 . 3 Available at http://www.eia.gov/electricity/data/eia861/ (see “retail sales” workbook). 4 Available at http://www.eia.gov/electricity/data/eia861/ (see “dsm” workbook). 5 Available at http://www.eia.gov/forecasts/archive/aeo13/.TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

3 **Navajo** 13314 Navajo Tribal Utility Authority UT 10,070 **Fort Mojave** 58123 Aha Macav Power Service AZ 47,788 

## BSER factors informing tribal lands’ emission rate goals The methodology for calculating tribal lands’ emission rate goals generally applies the same approach to determining BSER as described in the Goal Computation TSD from the June 2014 proposed rule . Information about the BSER measures can be found in the GHG Abatement Measures TSD . 6 The GHG Abatement Measures TSD describes the categories of emission reduction measures (building blocks) used in determining the emission rate goals . 

### Building block 1 – heat rate improvement at coal

-fired power plants Using the data discussed above, the Agency applied a 6% heat rate improvement to the EGUs at the Four Corners, Navajo Generating Station, and Bonanza coal -fired power plants. To calculate the alternative goal, the Agency applied a 4% heat rate improvement to the EGUs . The results from building block 1 are presented in Table 3 . **Table 3**  **: Adjusted**  **average coal**  **CO 2**  **emission rate for coal -** **fired EGUs**  **T ribe**  **6% HRI**

**Coal CO**  **2 rate**  **(lbs/MWh) 4** **% HRI**

**Coal CO**  **2 rate**  **(lbs/MWh) Navajo**  1,993 2,036 **Ute** 2,016 2,059 

### Building block 2 – redispatch to lower

- emitting NGCC EGUs Because none of the tribal lands have both coal -fired EGUs and NGCC EGUs, the analysis does not include redispatch to less CO 2- intenstive affected EGUs . 

### Building block 3 – renewables The analysis of renewable energy for building block 3 used the proposed methodology from the June 2014 proposed rule. Because EPA did not fi nd any information about utility-scale, grid -connected renewable energy net generation on tribal lands with affected EGUs in 2012, the renewables targets are zero, and, therefore, result in no change to the goals for these areas. EPA did not propose renewa ble energy targets for goal calculations based on the co- proposed methodology for the U.S. territories or the alternative approach used in the June 2014 proposed rule as discussed in the preamble. However, EPA considered using the renewable energy technica l potential estimates for tribal lands 7, 8 as well as using the lowest renewable energy percentage target (as derived in the alternative approach upon which EPA solicited comment for states) of any state in which that area of Indian country is located. Beca use these co- proposed methodology and alternative approach are

6 Available in the docket EPA- HQ-OAR- 2013 -0602 at http://www.regulations.gov/#!documentDetail;D=EPA- HQOAR-2013 -0602-0437 . 7 Doris et al (DOE), 2013. Geospatial Analysis of Renewable Energy Technical Potential on Tribal Lands. Available at http://www.nrel.gov/docs/fy13osti/56641.pdf. 8 Lopez et al (NREL), 2012. U.S. Renewable Energy Technical Potentials: A GIS- Based Analysis. Available at http://www.nrel.gov/docs/fy12osti/51946.pdf.TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

4 based on a state or territory’s total net electricity generation and not retail sales (i.e., consumption), applying these methodologies to tribal lands – where sales are only 2% - 16% of generation – yields large renewable energy goals relative to retail sales. 

### Building block 4 – energy efficiency The analysis of energy efficiency for building block 4 used the proposed methodology from the June 2014 proposed rule. 

## AFFECTED ELECTRICITY GENERATIN G UNITS IN U.S. TERR ITORIES Overview The territories of Guam, Puerto Rico, and the US Virgin Islands have coal -, oil -, and/or gas-fired EGUs that may be affected by this proposal . D ata from these EGUs were analyzed to establish territorial goals using the BSER described above. The Guam Power Authority (GPA) owns and manages the territory’s electricity grid. The majority of electricity on Guam is generated from No. 6 heavy fuel oil w ith a small amount from No. 2 distillate oil, both of which are shipped to the territory by tanker. 9 There are nine fossil -fired EGUs in Guam greater than 25 MW nameplate capacity (see Table 4). Excluding Guam’s internal combustion engines (ICEs) and oil -fired combustion turbines (CTs), 10 there are four EGU heavy fuel oil -fired steam turbine (STs) EGUs that may be affected sources under the rule. Guam is also pursuing renewable energy and energy efficiency. In 2008, Guam’s legislature established a renewable energy goal of 8% of net electricity sales by December 31, 2020; 10% of net electricity sales by December 31, 2025; and 15% of net electricity sales by December 31, 20 30 . 11 **Table 4**  **: Guam fossil -** **fired EGUs greater than 25 MW capacity**  **Plant name (location) Unit**  **Fuel Unit type**  **Capacity (MW)**  **Cabras** 1 No. 6 oil ST 60 * **Cabras** 2 No. 6 oil ST 60 * **Cabras** 3 No. 6 oil ICE 38 **Cabras** 4 No. 6 oil ICE 38 **Tanguisson** 1 No. 6 oil ST 25 * **Tanguisson** 2 No. 6 oil ST 25 * **PITI** 7 d istillate oil CT 40 **PITI** 8 No. 6 oil ICE 40 **PITI** 9 No. 6 oil ICE 40 Note: EGUs with asterisks were included in the goal calculation for Guam

9 EIA, 2013. Guam – Territory Energy Profile Analys is. Available at http://www.eia.gov/state/analysis.cfm?sid=gq . 10 The June 2014 proposed rule does not include ICEs as affected sources, and CTs must combust natural gas for more than 90% of the CT’s heat input. Since available data indicate Guam’s CT did not combust natural gas, it has been excluded from the list of potentially affected units for purposes of this goal -setting analysis. 11 NCSU, 2014. Guam – Renewable Energy Portfolio Goal. Available at http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=GU03R&ee=1TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

5 The Puerto Rico Electric Power Authority (PREPA) owns and manages the territory’s electricity grid. In 2012, approximately 65% of the electricity wa s generated from No. 6 heavy fuel oil and No. 2 distillate oil, 18% from liquified natural gas (LNG), 16% from coal, and 1% from hydro. 12 There are several fossil fired EGUs in Puerto Rico greater than 25 MW nameplate capacity (see Table 5 ). Excluding oil -fired CTs and combi ned cycles (CCs), 13 there are 2 coal -fired ST EGUs, 2 NGCC EGUs, and 14 oil -fired ST EGU s that may be affected sources under the rule. Puerto Rico is also pursuing renewable energy and energy efficiency. In 2010, Puerto Rico enacted a renewable energy portfolio standard of 15 % of retail electricity sales in 2020, rising to 20% in 2035 . 14 **Table 5**  **: Puerto Rico fossil** **- fired EGUs greater than 25 MW capacity**  **Plant name (location) Unit**  **Fuel Unit type**  **Capacity (MW)**  **AES (Guayama)** 1 coal ST 227 * **AES (Guayama)** 2 coal ST 227 * **Eco -** **electrica (Penuelas)** CT1 gas NGCC 568 * **Eco -** **electrica (Penuelas)** CT2 gas NGCC 568 * **PREPA Aguirre (Aguirre)** AG1 No. 6 oil ST 450 * **PREPA Aguirre (Aguirre)** AG2 No. 6 oil ST 450 * **PREPA Aguirre (Aguirre)** CC1 distillate oil CC 296 **PREPA Aguirre (Aguirre)** CC2 distillate oil CC 296 **PREPA Aguirre (Aguirre)** T1 - 1 distillate oil CT 30 **PREPA Aguirre (Aguirre)** T1 -2 distillate oil CT 30 **PREPA Cambalache (Arecibo)**  C1 distillate oil CT 83 **PREPA Cambalache**  **(Arecibo)** C2 distillate oil CT 83 **PREPA Cambalache (Arecibo)**  C3 distillate oil CT 83 **PREPA Daguao (Ceiba)**  T1 - 1 distillate oil CT 30 **PREPA Daguao (Ceiba)**  T1 -2 distillate oil CT 30 **PREPA Jobos (Guayama)**  T1 - 1 distillate oil CT 227 **PREPA Jobos (** **Guayama)** T1 -2 distillate oil CT 227 **PREPA Mayaquez**  GT5 distillate oil CT 28 **PREPA Mayaquez**  GT6 distillate oil CT 28 **PREPA Mayaquez**  GT7 distillate oil CT 28 **PREPA Mayaquez**  GT8 distillate oil CT 28 **PREPA Palo Seco (Toa Baja)** PS1 No. 6 oil ST 85 * **PREPA Palo Seco (Toa Baja)** PS2 No. 6 oil ST 85 * **PREPA Palo Seco (Toa Baja)** PS3 No. 6 oil ST 216 * **PREPA Palo Seco (Toa Baja)** PS4 No. 6 oil ST 216 * **PREPA Palo Seco (Toa Baja)** GT1 - 1 distillate oil CT 30

12 EIA, 2014. Puerto Rico Territory Energy Profile. Available at http://www.eia.gov/state/print.cfm?sid=RQ 13 In the June 2014 proposed rule, affected CTs are defined as those that combust natural gas for more than 90% of the CT’s heat input. Since available data indicate Puerto Rico’s CTs did not combust natural gas, those units have been excluded from the list of potentially affected units. 14 NCSU, 2014. Puerto Rico – Renewable Energy Portfolio Standard. Available at http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=PR07R&ee=1TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

6 **PREPA Palo Seco (Toa Baja)** GT1 -2 distillate oil CT 30 **PREPA Palo Seco (Toa Baja)** GT2 - 1 distillate oil CT 30 **PREPA Palo Seco (Toa Baja)** GT2 -2 distillate oil CT 30 **PREPA Palo Seco (Toa Baja)** GT3 - 1 distillate oil CT 30 **PREPA Palo Seco (Toa Baja)** GT3 -2 distillate oil CT 30 **PREPA San Juan (San Juan)**  SJ7 No. 6 oil ST 100 * **PREPA San Juan (San Juan)** SJ8 No. 6 oil ST 100 * **PREPA San Juan (San Juan)** SJ9 No. 6 oil ST 100 * **PREPA San Juan (San Juan)** SJ10 No. 6 oil ST 100 * **PREPA San Juan (San Juan)** CC5 distillate oil CC 232 **PREPA San Juan (San Juan)**  CC6 distillate oil CC 232 **PREPA South Coast (Guiyanilla)** SC3 No. 6 oil ST 85 * **PREPA South Coast (Guiyanilla)** SC4 No. 6 oil ST 85 * **PREPA South Coast (Guiyanilla)** SC5 No. 6 oil ST 410 * **PREPA South Coast (Guiyanilla)** SC6 No. 6 oil ST 410 * **PREPA South Coast (Guiyanilla)** GT1 distillate oil CT 45 **PREPA South Coast (Guiyanilla)** GT2 distillate oil CT 45 **PREPA Vega Baja** GT1 - 1 distillate oil CT 30 **PREPA Vega Baja** GT1 -2 distillate oil CT 30 **PREPA Yabucoa (Humacao)**  GT1 - 1 distillate oil CT 30 **PREPA Yabucoa (Humacao)**  GT1 -2 distillate oil CT 30 Note: EGUs with asterisks were included in the goal calculation for Puerto Rico The U . S . Virgin Islands Water and Power Authority (VIWAPA), an independent government agency, manages the territory’s two separate electricity grids. There are several fossil -fired EGUs in the U . S . Virgin Islands, but most are less than 25 MW nameplate capacity. The Agency found information about 3 fossil -fired EGUs greater than 25 MW (see Table 6 ). Excluding the oil -fired combustion turbine (CT) EGU , 15 there is 1 coal -fired ST EGU that has not operated in more than 20 years and 1 oil -fired ST EGU that has not operated since 2011 . Because there are not 2012 data for the analysis and because there is no indication that VIWAPA will return these units to operation, the analysis does not include a goal calculation for the U . S . Virgin Islands. **Table 6**  **: Virgin Island fossil -** **fired EGUs greater than 25 MW capacity Plant name (location)**  **Unit Fuel**  **Unit type Capacity**  **(MW) Krum Bay**  13 No. 6 oil ST 35 **Krum Bay** 23 Distillate oil CT 39 **St. Croix Renaissance** 10 Coal ST 25

15 In the June 2014 proposed rule, affected CTs are defined as those tha t combust natural gas for more than 90% of the CT’s heat input. Since available data indicate the U.S. Virgin Island’s CT did not combust natural gas, that unit has been excluded from the list of potentially affected units.TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

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## Data Potentially-affected EGUs in the U.S. territories do not report comprehensive information to the Agency or the Energy Information Administration (EIA). Therefore, the Agency compiled data from a variety of sources, including:  EPA’s Greenhouse Gas Reporting Program 16  P uerto Rico Electric Power Authority (PREPA)  U.S. Virgin Islands Power and Water Authority (VIWAPA)  Guam Power Authority (GPA)  EIA’s form EIA-861 The territory goals are described as a CO 2 emission rate (lb of CO 2 per MWh of net electricity generation). However, the Agency did not have comprehensive unit- level data available on both CO 2 emissions and net electricity generation. For Guam, the Agency received unit- level net generat ion and fuel consumption data from GPA. For Puerto Rico, the Agency had unit- level CO 2 emission data reported by the power companies to the EPA’s Greenhouse Gas Reporting Program. Therefore, two different methodologies were used to calculate CO 2 emissions (Guam) and net electricity generation (Puerto Rico). For Guam, GPA provided information about unit- level net generation and fuel consumption . The Agency used the information to calculate unit- level CO 2 emissions using the following formula: 2 = × Where: CO22012 is the 2012 annual CO 2 emissions in metric tons; OIL 2012 is the 2012 annual oil consumption in gallons; and EF is an emission factor of 0.01127 metric tons of CO 2/gallon of No. 6 oil. 17 For Puerto Rico, CO 2 emission data for 2012 were available at the unit level, but information was not available for unit- level net electricity generation in 2012 . The Agency estimated 2012 net electricity generation by multiplying each unit’s ratio of maximum net electricity generation to m aximum CO 2 emissions by the unit’s reported CO 2 emissions in 2012. The calculation is : h = h

2 × 2 Where: MWh 2012 is the annual net electricity output produced by the EGU in MWh ; MWh max is the maximum potential annual net electricity output produced by the EGU in MWh – calculated as nameplate capacity in MW X 8,784 hours 18 X a gross-to- net conversion factor (see Table 7 ) ;

16 Information about EPA’s Greenh ouse Gas Reporting Program is available on the program’s website at http://ghgdata.epa.gov/ghgp . 17 Emission factors from 40CFR Part 98 Subpart C, Table C- 1. Available at http://www.ecfr.gov/cgi - bin/textidx?SID=0769576af3d3e7d0e7c4556a2611dc4c&node=ap40.21.98_138.1&rgn=div9 .TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

8 CO22012 is the 2012 annual CO 2 emissions in metric tons reported to the EPA’s Greenhouse Gas Reporting Program ; and CO2 max is the maximum potential CO 2 emissions in metric tons – calculated as: 2 = × × ×

2205 Where: F

c is a carbon - based F-factor in standard cubic feet (scf) CO 2/mmBtu (see Table 8 ) ; U f is a conversion factor equal to 1/385 scf CO 2/lb- mole at 14.7 psia and 68° F; MW CO2 is the molecular weight of CO 2, 44 lb/lb- mol; and HImax is the maximum potential annual heat input in mmBtu – calculated as:

= × 1 × 8, 784h × Where: C is the nameplate capacity of the unit in MW; η pm is the electricity generating efficiency of the prime mover-fuel combination in percent 19

– calculated as 3.412 mmBtu/MWh 20 ÷ heat rate in mmBtu/MWh for the prime mover-fuel combination (see Table 9 ) 21; and K is a constant equal to 3.412 mmBtu/MWh, the energy value of 1 MWh.

**Table 7**  **: Gross** **- to** **- net**  **electricity generation factor (2012) EGU type**  **Net:gross**

**ratio Coal ST**  .9360 **Oil ST** .9352 **Natural gas CC**  .9728 Source: EIA, Frequently Asked Questions: What is the efficiency of different types of power plants? Available at **Table 8**  **: Carbon** **- based F** **- factors**  **(scf/mmBtu) Fuel type**  **F c**  **Coal (bituminous)** 1800

18 The number of possible operating hours in 2012. 19 For information about calculating power plant efficiency, see EIA, Frequently Asked Questions: What is the efficiency of different types of power plants? Available at http://www.eia.gov/tools/faqs/faq.cfm?id=107&t=3 . 20 One MWh of electricity is equal to 3.412 mmBtu of energy. 21 Heat rates are based on 2012 data from EIA, Elect ric Power Annual, Table 8.2: Average tested heat rates by prime mover and energy source 2007 -2012 . Available at http://www.eia.gov/electricity/annual/html/epa_08_02.html .TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

9 **Oil** 1420 **Natural gas** 1040 Source: 40CFR Part 75 App. G § 2.3 **Table 9**  **: Electric generating efficiency by prime mover type and fuel (2012) EGU type**  **Heat rate**

**(mmBtu/MWh) Coal ST**  10.107 **Oil ST** 10.359 **Natural gas CC**  7.615 Source: EIA, Electric Power Annual, Table 8.2: Average tested heat rates by prime mover and energy source 2007- 2012 . Available at http://www.eia.gov/electricity/annual/html/epa_08_02.html . The unit- level data for Guam and Puerto Rico are in the supporting technical files to this TSD [ reference to goal setting worksheet files]. For renewable energy, t he available information indicate that generation from utility-scale, grid connected renewable energy on Guam and Puerto Rico in 2012 was limited to hydroelectric energy on Puerto Rico (see Table 10) . The total estimated annual technical potential (MWh) for solar PV and wind on Puerto Ri co were developed using datasets for 40 km solar22 and 70m wind 23 and methodologies generally consistent with the NREL report, “U.S. Renewable Energy Technical Potentials: A GIS- Based Analysis.” 24 More specific information related to the methodologies for developing the datasets are available for 40 km solar25 and 70m wind . 26 Other data sources include: 1. Net generation by utility : Form EIA-861 27 2. Existing generation: EIA territorial profiles 28 **Table 10**  **: Renewable energy net generation (MWh) Territory**  **Renewables 2011**  **(MWh) 2012** 

**(MWh) Guam**  Hydro 0 0

Non - hydro 0 NA **Puerto Rico** Hydro 149,000 148,000

Non - hydro 0 NA

22 National Renewable Energy Lab (NREL), 2003. Caribbean 40km Tilt Equals Latitude. Available at www.nrel.gov/gis/data/GIS_Data_Technology_Specific/International/Solar/Low_Resolution/Caribbean_40km_Tilt _Equals_Latitude.zip . 23 National Renewable Energy Lab (NREL), 2009. Annual average modeled wind speed (m/s) for Puerto Rico and the Virgin Islands at a 70 meter hub height . Available at http://en.openei.org/datasets/dataset/annual -average modeled -wind -speed - m -s-for- puerto- rico-and -the-virgin - islands-at-a - 70- meter- hub- hei . 24 Lopez, et al, 2012. U.S. Renewable Energy Technical Potentials: A GIS- Based Analysis. Available at http://www.nrel.gov/docs/fy12osti/51946.pdf. 25 Campbell - Howe & Wilkins-Crowder (eds), 1999. Proceedings of the Solar 99 Conference. Available at http://www.nrel.gov/gis/pdfs/proceedings_solar99.pdf. 26 Elliot & Schwartz, 2005. Development and Validation of High - Resolution State Wind Resource Maps for the United States. Available at http://www.nrel.gov/docs/fy05osti/38127.pdf. 27 Available at http://www.eia.gov/electricity/data/eia861/ ( see "operational data" workbook) 28 Available at xxxxxxxxxxTSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

10 Source: EIA, International Energy Statistics, Total Renewable Electricity Net Generation. Data required for the calculation of building block 4 goals for territories and their sources are: 1. 2012 electricity sales (MWh): Form EIA-861 29 2. 2012 energy efficiency incremental effects – total (MWh): Form EIA-861 30 These data are inputs to the supporting technical files to this TSD [ reference EE spreadsheet files]. Table 11 summarizes data on 2012 electricity sales for the territories. None of the territories reported energy efficiency data on their Form EIA-861 submittals for 2012. Unlike the tribes and states, electricity sales projections are not available from the 2013 AEO reference case. EPA is not aware of another source for this information and, thus, is holding sales constant at their 2012 levels through the analysis period. **Table 11**  **: 2012 total electricity sales for territories**  **Territory Utility Number**  **Utility Name Total Sales**  **(MWh) Guam**  40428 Guam Power Authority 1,563,475 **Puerto Rico** 15497 Puerto Rico Electric Power Authority 18,150,330 

## BSER factors informing territories’ emission rate goals As discussed in the section on BSER factors informing tribal lands’ emission rate goals, t he methodology for calculating emission rate goals generally applies the same approach to determining BSER as described in the Goal Computation TSD from the June 2014 proposed rule. 

### Building block 1 – heat rate improvement at coal

-fired power plants Using the data discussed above, the Agency applied a 6% heat rate improvement to the coal -fired EGUs in Puerto Rico . The Agency assumes that a 6% heat rate improvement at the facility with the coal -fired EGU s will directly translate to a 6% reduction in the net CO 2 emission rate. To calculate the alternative goal, the Agency applied a 4% heat rate improvement to the EGUs. The results from building block 1 are presented in Table 12 . **Table 12**  **: Adjusted average coal CO**  **2 emission rate for coal** **- fired EGUs**  **Territory 6% HRI** 

**Coal CO**  **2 rate**  **(lbs/MWh) 4** **% HRI**

**Coal CO**  **2 rate**  **(lbs/MWh) Puerto Rico**  2,241 2,289

29 Available at http://www.eia.gov/electricity/data/eia861/ (see “retail sales”). 30 Available at http://www.eia.gov/electricity/data/eia861/ (see “dsm”).TSD for Calculating Carbon Pollution Goals for Existing Power Plants in Territories and Areas of Indian Country

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### Building block 2 – redispatch to lower

- emitting NGCC EGUs In 2012, Puerto Rico had one facility with two NGCC EGUs. Based on the Agency’s calculations described above, the facility operated at approximately a 37% capacity factor. The GHG Abatement Measures TSD31, suggests that the average availability of an NGCC is significantly greater than 70%. Because the NGCC EGUs in Puerto Rico use imported LNG, the Agency reviewed the capacity of the existing LNG port and gasifiers to ensure they would not constrain the ability of the EGUs to achieve a 70% capacity factor. Based on data available to the Agency, we believe the port has sufficient importing and processing capacity to supply LNG for the NGCCs to achieve a 70% capacity factor which offsets generation at both coal -fired ST EGUs and oil -fired ST EGUs. 

### Building block 3 – renewables Because neither Guam n or Puerto Rico have utility-scale, grid -connected, non - hydroelectric renewable energy generation for 2012, the analysis of renewable energy using the proposed methodo logy from the June 2014 proposed rule resulted in no renewable energy targets, and, therefore, no change to the goals for these areas. The second co- proposal option includes an adjustment to the proposed methodology that changes the amount of renewable energy in 2017 to be consistent with the lowest amount among the 5 0 states in 2012, which is 0.37% of the 2012 total electricity gen eration. EPA then applies the 9% annual growth factor through 2029. The 9% annual growth factor is based on Hawaii’s historical growth between 2002 and 2012 renewable energy generation. For Puerto Rico’s renewable energy target based on the alternative approach, the Agency use d estimates provided by DOE for wind and utility-scale solar PV (urban and rural) from available wind and solar resource data for the region. The wind resource data used are 70 hub height wind speed estimates modeled by AWS Truepower and NREL in 2008. The solar resource data used was produced by the NREL Climatological Solar Radiation model in 2007. Consistent with the June 2014 proposed rule, the Agency also includes renewable energy targets for Puerto Rico with the inclusion of 2012 hydroelectric generat ion. These data are presented in the technical files to this TSD [ reference R E spreadsheet files]. 

### Building block 4 – energy efficiency The analysis of energy efficiency for building block 4 used the proposed methodology from the June 2014 proposed rule.

31 See footnote 6 .