State Goals Overview
Outline

•Background

•State Goals

•State Flexibility

•Examples

•On-the-way Reductions

•Walk Through of State Goal Derivation

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State Goals - Calculation

 The numerator is the sum of CO2 emissions at covered fossil fuel fired 

power plants in that state .

 The denominator is electricity generation in the state, factoring in 

megawatt hours from fossil fuel power plants plus other types of power 

generation like renewables and nuclear, as well as megawatt hour savings 

from energy efficiency in the state.

 More specifically -- this includes covered fossil sources, existing and 

new renewable energy (but excluding existing hydro), 6% of the 

nuclear fleet’s generation, and EE accounted for as zero emitting 

MWh. 

 No single fossil fired unit has to meet any of these goals. 

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State CO2 emissions from covered fossil fuel fired power plants (lbs)

State electricity generation from covered fossil plants + RE + nuclearar&UC + EE (MWh)

Basic formula 

for state goal
State Goals – What is BSER?

• State goals do not lay out a set of required mechanisms a state must 

use to reduce carbon pollution. They are a numeric target that a state 

must plan to meet through the measures they choose.

• EPA is setting state goals after determining the Best System of 

Emission Reduction (BSER).

• Because the power sector is interconnected, EPA determined that a 

set of 4 measures together are the best system to reduce carbon 

pollution from fossil fuel fired power plants. 

• The best system is made up of 4 building blocks that are being 

implemented now and can be implemented more broadly across the 

power system : 

(1) measures to make coal plants more efficient,

(2) increased use of high efficiency, natural gas combined cycle 

plants,

(3) generating electricity from low/zero emitting facilities, and 

(4) demand-side energy efficiency. 

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State Goals – Why They Are Different?

• State goals are unique to each state factoring in the amount of reductions that can be achieved 

through the 4 building blocks:

• Key factors that influence an individual state goal include:

• The ratio of coal to existing natural gas combined cycle units

• Magnitude of state RPS’s within region

• Energy demand (which impacts the potential for reductions from energy efficiency)

• Because the key factors that influence individual state goals are different for every state, 

each state’s goal (and reduction percentage) is different.

• The percentage reduction in emission rate implied by the 2012 actual rate (adjusted for RE) and 

the targets in other years is not the same as a required percentage reduction in mass emissions.

• This can be easily seen because increases in EE and RE can be accompanied by varying 

decreases in emissions.

• Overall, the 2012 rate to 2030 State goal comparison suggest a 33% reduction between the 

adjusted emission rate and the state goals, but this is achieved via a 17% reduction in 

emissions over that same time period.

• EPA is not proposing emission rate goals or guidelines for sources in Indian country and U.S. 

territories at this time. However, EPA will be proposing goals “if necessary or appropriate” for 

areas of Indian country with affected power plants and for U.S. territories with affected power 

plants in a supplemental proposal.

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State Flexibility – States Get to Decide

• State goals are unique to every state because they reflect the 

diversity of how states produce and consume electricity.

• For example, some states have more coal-fired generators 

and therefore more potential for heat rate improvements.

• State goals do not define or limit states compliance choices

• States can choose to meet their goal using more or less of 

any of the compliance options in the four building blocks.

• They can also use compliance options not included in the 

building blocks such as new NGCC, transmission 

improvements and retrofit CCS.

• State goals were not derived using any 2005 data

• EPA described the overall, nationwide reduction target in 

reference to 2005, because that is a common year to 

consider when evaluating GHG emission reductions

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State Goals – Learning More

• EPA’s analysis shows how each state goal was calculated and 

walks the reader through a detailed example.

• Remember: EPA calculated the goal based on the specific 

actions EPA has defined as BSER under the Clean Air Act– not 

on a particular compliance approach. 

• The proposal provides significant flexibility for states to 

achieve reduction in any number of ways, therefore state 

goals are not prescriptions for any specific actions in any 

state.

• Each state has substantial flexibility to determine how to 

meet its goal.

• A state can employ all, some, or none of the strategies 

EPA used to calculate the goal in its state plan as long as 

the state can demonstrate how the plan’s actions will get 

them to its goal and achieve real reductions in carbon 

pollution from power plants.

• Let’s take a look at a couple of examples of State Goals 7
Example 1 – Central State

“Central State” has a fossil intensive energy mix consisting primarily of 

coal and natural gas power plants sources which together generate 

approximately 114 TWh of electricity. It has no nuclear generation.

1. Central State’s starting 2012 emission rate is 1,924 lbs/MWh.

2. EPA applies Block 1 (reduced CO2 emissions 6% due to heat rate 

improvements at Central State’s coal fleet on average)

3. EPA applies Block 2 (redispatching generation away from coal and 

oil/gas steam sources and toward the state’s NGCC fleet, running 

them more)

4. EPA applies Block 3 (rate goes down as generation from zero and 

low-emitting renewable sources increases – only a small drop 

because Central State does not have any nuclear power)

5. EPA applies Block 4 (rate goes down as efficiency programs take 

hold and Central State’s residents and businesses use less power 

to do more work)

6. Central State’s final goal is 1,531 lbs/MWh, a 20% reduction from 

their 2012 emission rate.

Central State is already on its way to meeting this goal through a series 

of programs including energy efficiency codes for residential buildings 

and commercial buildings and renewable energy portfolio goals.

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Calculating

Central State’s Goal

Starting rate 1,924

After Block 1 1,817

After Block 2 1,772

After Block 3 1,707

After Block 4 1,531

---------------------------------

---

Final Goal 1,531
Example 2 – Western State

“Western State” has a more narrow energy mix consisting of one coal-fired power 

plant, 10 NGCC plants, and an abundance of hydro generation (80%) which 

together generate a similar amount of electricity as Central State. 

1. Western State’s starting 2012 emission rate is 756 lbs/MWh. (lower than 

Central State’s starting rate because more of Western State’s power comes 

from lower carbon emitting sources)

2. EPA applies Block 1 (small amount of reduced CO2 emissions due to 

potential heat rate improvements at Western State’s one coal plant)

3. EPA applies Block 2 (reflects a large drop in rate, due to complete 

redispatch from the one coal source (scheduled to retire) to existing NGCC. 

However, because of the limited fossil fleet and generation totals involved, 

the on-the ground impact is minimal)

4. EPA applies Block 3 (rate goes down as generation from zero and lowemitting renewable sources increases)

5. EPA applies Block 4 (rate goes down as efficiency programs take hold and 

Western State’s residents and businesses use less power to do more work)

6. Western State’s final goal is 215 lbs/MWh, a 72% reduction from their 2012 

emission rate.

While the rate change may look more significant than Central State’s, it does not 

necessarily entail more reduction measures, but is rather a reflection of the low 

fossil generation in Western State.

In fact, Western State is already well on its way to meeting this goal through a 

series of programs including greenhouse gas performance standards, energy 

efficiency standards, demand-side energy efficiency programs that advance energy 

efficiency improvements for electricity use, energy efficiency codes for residential 

and commercial buildings, appliance and equipment efficiency standards, and 

renewable energy portfolio standards. 9

Calculating

Western State’s Goal

Starting rate 756

After Block 1 728

After Block 2 444

After Block 3 298

After Block 4 215

-----------------------------

Final Goal 215
Unique Fleets = Unique Emission Rates

• In this example, Central State and Western State have very different 

power fleets

• In 2012, Central State produced 97% of its power from fossil fuels, while Western 

State produced 9% of its power from fossil fuels

• Because Western State has relatively less fossil fuel-fired generation, a 

given action to reduce its CO2 emissions will have a greater impact on its 

CO2 emission rate than the same action would have in a state like Central 

State with relatively more fossil fuel-fired generation

• For example, increasing renewable generation by 2 terawatt-hours can reduce 

Western State’s emission rate by 10% but would only reduce Central State’s 

emission rate by 2%

• Each state’s goal reflects its ability to improve its CO2 emission rate, 

taking its unique circumstances into account

• Therefore, Western State’s “lower” state goal doesn’t mean that this rule would 

ask Western State to “do more,” in part because its emission rate is more 

sensitive to a given action to reduce CO2.

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On-the-way Reductions

• Southern State’s adjusted rate for 2012 is 1,650 lb/MWh

(reflecting existing “at risk” nuclear and RE), BSER is applied to 

determine state goal of ~1,100 lb/MWh

• However, Southern State has already initiated measures to 

make significant progress towards the state goal*:

 Realization of Southern State’s RPS will bring the rate down 

to ~1,462 lb/MWh

 The 2,250 MW of under construction NGCC will bring the 

rate down to ~1,389 lb/MWh

Coal retirements in 2013 led to a drop from 50 TWh to 46 

TWh, bringing the rate down to ~1,354 lb/MWh

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* Rate changes are preliminary estimates and shown here for illustrative purposes. Actual rate will 

ultimately depend on the generation values for the state in a given year.
What Next?

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1) Review the inventory of “likely covered units”

2) Review the 2012 emissions and generation data for these units

3) Estimate the 2030 emissions and generation data for these units

4) Estimate the RE MWh and EE MWh achieved by 2030

5) Estimate ability to comply with 2030 state goal by plugging values from #3 and #4 

into the equation on slide 1 or the full equation below.

State Goal* = (coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen. uc + ar + RE gen. + EE gen.

* Relevant data for state goal calculation can be found in Appendix 1 of the Goal Computation TSD and tables 4-1 (existing 

renewable energy) and 4-10 (nuclear) in the GHG Abatement Measures TSD
Appendix - Example of State Goal Derivation

The following example shows the derivation for the Ohio’s State Goal.

• Additional explanation and discussion can be found in the goal 

computations Technical Support Document at 

http://www2.epa.gov/carbon-pollution-standards/clean-power-planproposed-rule-goal-computation

• The underlying data and calculations for all states can be found in 

Appendix 1 at http://www2.epa.gov/carbon-pollution-standards/cleanpower-plan-proposed-rule-technical-documents

• The underlying plant-level data and unit-level inventory can be found in 

Appendix 7 at http://www2.epa.gov/carbon-pollution-standards/cleanpower-plan-proposed-rule-technical-documents

• Discussion of the Building Blocks and corresponding state level 

assumptions for each can be found in the GHG Abatement Measures TSD 

at http://www2.epa.gov/carbon-pollution-standards/clean-power-planproposed-rule-ghg-abatement-measures

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Step 1 – Calculation of 2012 fossil emission 

rate (Ohio)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

(86,473,075 x 2,126) + (321,602. x 1,332) + (20,907,183 x 963) + 284,732,506

86,473,075 + 321,602 + 20,907,183 + 214,178

Rate – 1,897 lbs/MWh

Where can I find this data?

Appendix 1 of the Goal Computations TSD at http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule-technical-documents

2012 Rate (lbs/MWh) 2012 mass (lbs) 2012 Generation (MWh) 2012 Capacity

A B C D E F G H I

Coal Rate OG Steam Rate NGCC Rate Other Emissions Coal Gen OG Steam Gen NGCC Gen Other Gen NGCC MW

Ohio 2,126 1,332 963 284,732,506 86,473,075 321,602 20,907,183 214,178 4,343
Step 2 – Apply BB1 (6 % HRI)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

(86,473,075 x 1,999) + (321,602. x 1,332) + (20,907,183 x 963) + 284,732,506

86,473,075 + 321,602 + 20,907,183 + 214,178

Rate – 1,795 lbs/MWh

Where can I find this data?

Appendix 1 of the Goal Computations TSD at http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule-technical-documents

Emission Rate (lbs/MWh) Emissions (lbs) Generation (MWh)

2012 

Capacity

A B C D E F G H I

Coal Rate OG Steam Rate NGCC Rate

Other 

Emissions Coal Gen OG Steam Gen NGCC Gen Other Gen NGCC MW

Ohio 1,999 1,332 963 284,732,506 86,473,075 321,602 20,907,183 214,178 4,343
Step 3a – Apply BB2 (70% NGCC Redispatch 

Ceiling)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

(80,700,563 x 1,999) + (300,133 x 1,332) + (26,701,164 x 963) + 284,732,506

80,700,563 + 300,133 + 26,701,164 + 214,178

Pre Redispatch (TWh) Post Redispatch (TWh)

Coal 86.5 80.7

OG Steam .321 .300

NGCC 20.9 26.7

Total 107.7 107.7

Rate – 1,739 lb/MWh

State’s NGCC fleet 

at 70% CF
Step 3b – Apply BB2 for Under Construction 

NGCC

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. 

(79,993,008 x 1,999) + (297,502 x 1,332) + (27,411,350 x 963) + 2,791,474,084

79,993,008 + 297,502 + 27,411,350 + 2,818,194

Pre Redispatch (TWh) Post Redispatch (TWh)

Coal 86.5 80.0

OG Steam .321 .297

NGCC 20.9 27.4

Total 107.7 107.7

Rate – 1,715 lb/MWh

4,343 MW x 8784 hours x 70% CF = 26,701,164

539 x 8784 x 15% CF = 710,186

Total NGCC = 27,411,350

539 x 8784 x 55% CF =2,604,017

Total “other”= 2,604,017 + 214,178 = 2,818,195
Step 4a – Apply BB3 (nuclear)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen.AR + UC

Rate – 1,699 lbs/MWh

Where can I find this data?

Appendix 1 of the Goal Computations TSD at http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule-technical-documents

and

Chapter 4 of the GHG Abatement Measures TSD discusses the derivation of 

the “at risk” nuclear. Table 4-10 of the GHG Abatement Measures TSD at 

http://www2.epa.gov/carbon-pollution-standards/clean-power-plan-proposedrule-ghg-abatement-measures

(79,993,008 x 1,999) + (297,502 x 1,332) + (27,411,350 x 963) + 2,791,474,084

79,993,008 + 297,502 + 27,411,350 + 2,818,194 + 993,077

Ohio Nuclear Capacity 2,150 MW

“At Risk” Capacity (2,150 x 5.8%) 126 MW

“At Risk Generation (x .90% * 8784h) 993,077 MWh
Step 4b – Apply BB3 (RE Gen)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen.AR + UC + RE gen.

Rate – 1,512 lbs/MWh

Where can I find this data?

Appendix 1 of the Goal Computations TSD at http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule-technical-documents

and

Chapter 4 of the GHG Abatement Measures TSD Discusses the Derivation 

of the RE MWh for each state. Table 4-1 of the GHG Abatement Measures 

TSD at http://www2.epa.gov/carbon-pollution-standards/clean-power-planproposed-rule-ghg-abatement-measures

(79,993,008 x 1,999) + (297,502 x 1,332) + (27,411,350 x 963) + 2,791,474,084

79,993,008 + 297,502 + 27,411,350 + 2,818,194 + 993,077 + 13,775,594

RE Gen.

Existing as of 2012 1,738,622 MWh

Amount assumed in goal for 2030 13,775,594 MWh
Step 5 – Apply BB4 (MWh of EE)

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(Coal gen. x coal emission rate) + (OG gen. x OG emission rate) + (NGCC gen. x NGCC emission rate) + “Other” emissions

Coal gen. + OG gen. + NGCC gen. + “Other” gen. + Nuclear gen.AR + UC + RE gen. + EE MWh

Rate – 1,338 lbs/MWh

Where can I find this data?

Appendix 1 of the Goal Computations TSD http://www2.epa.gov/carbonpollution-standards/clean-power-plan-proposed-rule-technical-documents

and

Chapter 5 of the GHG Abatement Measures TSD describes the derivation of 

the 11.56% figure. http://www2.epa.gov/carbon-pollution-standards/cleanpower-plan-proposed-rule-ghg-abatement-measures

(79,993,008 x 1,999) + (297,502 x 1,332) + (27,411,350 x 963) + 2,791,474,084___

79,993,008 + 297,502 + 27,411,350 + 2,818,194 + 993,077 + 13,775,594 + 16,284,584

EE Avoided Gen.

2012 Sales (scale by 1.0751) 152,456,864 MWh

EE Savings 11.56%

Net Import Adjustment 86%

EE MWh 16,284,584 MWh
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Regional Contacts

Region Name Email Phone

1 Shutsu Wong wong.shutsu@epa.gov 617-918-1078

2 Gavin Lau lau.gavin@epa.gov 212-637-3708

3 Mike Gordon gordon.mike@epa.gov 215-814-2039

4 Ken Mitchell mitchell.ken@epa.gov 404-562-9065

5 Alexis Cain cain.alexis@epa.gov 312-886-7018

6 Rob Lawrence lawrence.rob@epa.gov 214-665-6580

7 Ward Burns burns.ward@epa.gov 913-551-7960

8 Laura Farris farris.laura@epa.gov 303-312-6388

9 Ray Saracino saracino.ray@epa.gov 415-972-3361

10 Madonna Narvaez narvaez.madonna@epa.gov 206-553-2117