South Dakota’s 111(d) Questions

1. Block 1 –If 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 due 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 EPA consider the issue where the coal-fired power plant is owned by one 

company and the NGCC is owned by another? Each unit is supplying electricity to a different 

distribution system and the power is already dedicated to the distribution system. How does 

re-dispatching work in the scenario?

4. Block 2 – Why did EPA use the maximum design rated capacity 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 instead of the design capacity? What is needed 

to assist in this matter?

5. Block 3 – If EPA does not allow existing hydropower to be used in the denominator for 

calculating compliance with the state goal, why did they use it in calculating the % of 

renewables used in establishing the state’s goal?

6. Block 3 – If a hydropower 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 actually had renewable portfolio programs, why wasn’t the states without 

programs included in calculating the average %? If 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? 

Why 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? If EPA bases it on the

state that purchases the energy, how does EPA reconcile that concept with energy produced 

from fossil fuels in one state but is purchased by 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?