From: Wayland, Robertj [mailto:Wayland.Robertj@epa.gov] 

Sent: Thursday, May 29, 2014 1:07 PM 

To: Cortney Higgins 

Cc: Culligan, Kevin 

Subject: FW: Comments on TSD Chapter 4 (version dated 5/23) 

Cortney – 

Here are responses to your comments/questions on Chapter 4. Please let Kevin/me know if you 

have any questions/concerns. 

thanx! 

bob 

Robert J. Wayland, Ph.D. 

Leader, Energy Strategies Group 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Mail Code D243-01 

Research Triangle Park, NC 27709 

Office: (919) 541-1045 

Cell: (919) 306-2290 

Fax: (919) 541-5450 

Email: wayland.robertj@epa.gov 

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 DRAFT/Deliberative Document - FOIA Exempt 

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From: Stenhouse, Jeb 

Sent: Thursday, May 29, 2014 11:21 AM 

To: Wayland, Robertj; Srivastava, Ravi 

Cc: Culligan, Kevin; Conlin, Beth; Sims, Ryan 

Subject: RE: Comments on TSD Chapter 4 (version dated 5/23) 

Bob, here are responses that we feel are ready to go back to OMB. 

Below are comments received on chapter 4 of the GHG abatement TSD. 
General comment: It is not clear how prior recommendation to take comment on a wider variety 

approaches to determining RE potential has been resolved. To reiterate, commenters suggest that 

EPA allow the targets to grow beyond the regional average to meet existing RPS levels already 

determined by that state. We recommend that EPA take comment on other approaches as well, 

including those based on modifications to the existing RPS methodology or those that rely on 

estimates of economic potential. 

EPA: EPA is taking comment on an alternative RE approach that derives targets based on 

technical and economic potential. 

** 

Comment A44 & A45: “2013 has been a strong year for solar, and we expect continued 

acceleration in deployment, especially with the ITC continuing to 2016 and rapidly declining 

technical costs. We also expect 2014 to be a strong year for wind, with many projects starting 

construction prior to expiration of the PTC. Keeping renewable growth flat from 2012 to 2017 will 

grossly underestimate the renewable deployment in the 2017 start year. For states with existing 

RPSs, DOE recommends assuming they continue to meet their RPS targets through 2017. “ 

EPA Response: These calculations apply the RPS requirements as the target-setting criteria to 

historical generation data that does not make any projections as to future behavior. Any additional 

qualifying capacity added between 2012 and 2017 will be able to have its generation during the 

program period count towards state compliance. 

New* response to EPA response: Not adjusting for the significant growth in RE generation that 

we’ve already seen since 2012 weakens the stringency of the rule, since, as EPA stated, states will 

be able to count generation that has already been deployed, enabling some states to potentially 

meet their RE goals before the policy ever takes effect. Any generation that was added last year 

should not be considered “future behavior.” While early action should be counted and encouraged, 

RE goals should be beyond BAU, in order to adequately represent BSER. 

EPA: The proposed RE target-setting approach requires a data set reflecting the current 

level of performance for all utility-scale RE sources for all states, and the most recent data 

available is EIA 2012 detailed state generation data. The targets derived from the proposed 

approach reflect a reasonable increase in RE generation over expected levels across the 

regions analyzed. EPA is also requesting comment on an alternative method that derives 

targets based on technical and economic potential, a method which uses 2012 generation of 

leading states as a benchmark for development of technical potential instead of as a 

baseline for growth. 

Comment A48: EPA response: This is an adjustment made to the method following submission of 

the TSD to interagency review. This adjustment assures that Alaska and Hawaii are treated 

differently in determination of growth rate, based upon their unique historical generation. 

New* response to EPA response: If EPA is treating HI and AK like the least stringent region (SE), 

then they should also have to meet the SE’s growth requirement of 13%/year. 

EPA: EPA assigned the least stringent regional RE target to Alaska and Hawaii to account 

for the fact that they do not have bordering states from which we can derive a collective 

regional basis for RE potential, however this regional target does not reflect the unique RE 

resources available to these two states. The use of their individual historical RE generation 

as a basis for their growth factor integrates data unique to Alaska and Hawaii into the 
derivation of their state targets. EPA is also specifically seeking comment on the treatment 

of Alaska and Hawaii as part of RE target-setting. 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Wednesday, May 28, 2014 5:43 PM 

To: Wayland, Robertj 

Cc: Culligan, Kevin; Elman, Barry 

Subject: Comments on TSD Chapter 4 (version dated 5/23) 

Hi Bob, 

Below are comments received on chapter 4 of the GHG abatement TSD. 

General comment: It is not clear how prior recommendation to take comment on a wider variety 

approaches to determining RE potential has been resolved. To reiterate, commenters suggest that 

EPA allow the targets to grow beyond the regional average to meet existing RPS levels already 

determined by that state. We recommend that EPA take comment on other approaches as well, 

including those based on modifications to the existing RPS methodology or those that rely on 

estimates of economic potential. 

** 

Comment A44 & A45: “2013 has been a strong year for solar, and we expect continued 

acceleration in deployment, especially with the ITC continuing to 2016 and rapidly declining 

technical costs. We also expect 2014 to be a strong year for wind, with many projects starting 

construction prior to expiration of the PTC. Keeping renewable growth flat from 2012 to 2017 will 

grossly underestimate the renewable deployment in the 2017 start year. For states with existing 

RPSs, DOE recommends assuming they continue to meet their RPS targets through 2017. “ 

EPA Response: These calculations apply the RPS requirements as the target-setting criteria to 

historical generation data that does not make any projections as to future behavior. Any additional 

qualifying capacity added between 2012 and 2017 will be able to have its generation during the 

program period count towards state compliance. 

New* response to EPA response: Not adjusting for the significant growth in RE generation that 

we’ve already seen since 2012 weakens the stringency of the rule, since, as EPA stated, states will 

be able to count generation that has already been deployed, enabling some states to potentially 

meet their RE goals before the policy ever takes effect. Any generation that was added last year 

should not be considered “future behavior.” While early action should be counted and encouraged, 

RE goals should be beyond BAU, in order to adequately represent BSER. 

Comment A48: EPA response: This is an adjustment made to the method following submission of 

the TSD to interagency review. This adjustment assures that Alaska and Hawaii are treated 

differently in determination of growth rate, based upon their unique historical generation. 
New* response to EPA response: If EPA is treating HI and AK like the least stringent region (SE), 

then they should also have to meet the SE’s growth requirement of 13%/year.