### South Dak **ota’s 111(d) Questions** 1. Block 1

– I f a coal
- fired unit can demonstrate it has already implemented the process efficiency projects specified in the proposal and has already achieved the 6% efficiency improvement, would EPA remove this block from the goal calculation ? Did EPA consider the reductions that will occur d ue to other regulations such as BART? 2. Block 2

–Will EPA reconsider how it defines what an existing NGCC versus a new NGCC is ? What is needed to assist in this matter? 3. Block 2

– Did EP A consider the issue where the coal
- fired power plant is owned by one compan y and the NGCC is owned by another? Each unit is supplying electricity to a different distribution sy stem and the power is alread y dedicated to the distribution system. How does re - dispatching work in the scenario? 4. Block 2

– Why

did EPA use the maximum design rated capacit y of the NGCC when weather and other conditions have a big influence on the actual maximum capacity? Would EPA consider using the actual maximum capacity instea d of the design capacit y? What is needed to assist in this matter? 5. Block 3

– If EPA does not allow existing hy dropower to be used in the denominator for calculating compliance with the state goal , wh y did they use it in calculating the % of renewables us ed in establishing the state’s goal? 6. Block 3

– If a h ydropower improves its efficiency, how much of the efficiency is allowed to be included in the denominator and how is it verified? 7. Block 3

– If EPA based the renewable % on what was achieved in a group of states with the states that actuall y had renewable portfolio programs, why wasn’t the states without programs included in calculating the average %? I f these renewable portfolio programs did not require the renewable energy be produced in the state (i. e. other states renewable sources may be used to meet the other states requirement) , isn’t EPA double counting when it requires the state that supplies renewable energy to these states to match that state’s goal ? W hy does the goal calculation assume that amount of renewable energy is achievable for each individual state ? 8. Block 3

–Which state is allowed to account for the renewable energy ? Is it the state that produced the wind energy or the state that purchases the wind energy ? I f EPA bases it on th e state that purchases the energy , how does EPA reconcile that concept with energy produced from fossil fuels in one state but is purchased b y another state? 9. Blocks 3 and 4

– If a state does not have authority to implement 111(d) on tribal land, why does the goal calculation include energy produced and energy

purchased on tribal lands?10. Block 4

– How does EPA anticipate states demonstrating they are meeting the energy efficiency goals ? How does EPA anticipate keeping cities , small businesses and even private citizens from third party

lawsuits ? 11. Will new coal
- fired power plants and NGCCs be used in the formula to demonstrate states are meeting their goal? 12. If best selective emission reduction is allowed to be this broad, what is stopping EPA or even environmental groups to push for BACT, LAER, BART, etc. from being this broad? 13. How does EPA plan on funding this program?