Comments to the U. S. Environmental Protection Agency (EPA)

a nd U. S. Small Business Administration (SBA)

Regarding Proposed EPA GHG Rules Affecting Small Entities or Small Businesses Reflecting Regulatory Impacts for Public Power Electric Utilities for Regulating

Greenhouse Gas Emissions Including:

P ROPOSED PSD T AILORING R ULE (P UBLISHED O CTOBER 30, 2009)

E NVIRONMENTAL P ROTECTION A GENCY
40 CFR P ARTS 51, 52, 70, AND 71 [EPA

- HQ

- OAR

- 2009

- 0517]

RIN 2060

- AP86

With References to:

 Proposed BACT Interpretative Guidance ( i.e. ―Steve Johnson Memo‖)

(Published October 7, 2009)

Docket ID No. EPA

- HQ

- OAR

- 2009

- 0597

 Endangerment Question and Call for Comments (resubmittal of APPA‘s June 23, 2009 comments)

Dock et ID No. EPA

- HQ

- OAR

- 2009

- 0171

 GHG Reporting Rule (Final Rule Published October 30, 2009)

Docket ID No. EPA

- HQ

- OAR

- 2008

- 0508 74 Fed. Reg. 16448 (April 10, 2009)

s ubmitted December 1, 20091

What is APPA

The Amer i can Public Power Association (APPA) is the national service organization representing the interests of the more than 2,000 , not

- for

- profit municipal and other state and local community

- owned electric utilities that collectively provide electricity to approximately 45 million Americans. These utilities , or ― public power ‖ systems

, are among the most diverse of the electric utility sectors, representing utilities in small, medium and large communities in 49 states (all but Hawaii). Seventy percent of public power systems are located in cities with populations of 10,000 or less. APPA was

created in 1940 as a non

- profit, non

- partisan organization. Its purpose is to advance the public policy interests of its members and their consum ers, and to provide member services to ensure adequate, reliable electricity at a reasonable price with the proper

prote ction of the environment

.

Overall, public power accounts for about 16 percent of all kil owatt

- hour sales to retail electricity consumer s. Approximately 46% of the megawatt hours of electricity produced by public power systems are generated using coal. In addition, the majority of communities operating public power utilities also manage water utilities that provide drinking water to res idential, institutional, commercial and industrial customers. Moreover, more than 90% of public power systems meet the definition and qualify as small businesses under the Small Business Act and the Small Business Regulatory

Enforcement and Fairness Act of 1996 (SBREFA).

Executive Summary

More than 90% of APPA s‘ members are small businesses as interpreted by the U. S.

Small Business Administration. Ironically, while we commend the EPA for its general approach in the PSD tailoring proposal, we are sur prised that the EPA did not take a more expansive view toward ―tailoring‖ to include the electric generation sector. APPA‘s

comments to be submitted on December 28 th will fully explain why the proposed

comments on PSD ― Tailoring ‖ have no direct benefits t o our electric utilities. However,

we believe that the U. S. EPA and U. S. SBA need to take a reasonable regulatory approach to the PSD and Title V operating permit issue that will, indirectly

, provide

benefits for APPA‘s member utilities by removing some of our electricity customers from the first phase of PSD/Title V permitting.

At the November 17, 2009 EPA/SBA SER small entity outreach panel meeting, the EPA

offere d a slide (Handout on slide 17) that suggests that 161 electric utilities or ―EGUs‖ in the United States will be positively affected by the proposed rule since the tailoring rule would raise the triggering PSD threshold to 25,000 tons. The slide also suggested that 25 EGUs would not need PSD permits. While this is technically correct, A PPA believes the

―EGUs‖ referenced are actually standby or emergency generation, and are not representative of typical utilities with baseload generation

– i.e., those that have generation that satisfies customer load under non

- emergency or extraordinary

c ircumstances . One example would be a small utility with approximately 1,000 customers which has only a 2MW generating unit designed to operate in emergencies or2

other rare circumstances that was run less than 50 hours in each of the past few years. An

an alogy to this type of ― generation ‖ would be a homeowner who owns a diesel emergency generator for their home. Typically, th is type of emergency generator would run it only a few times a year just to check to make sure it can start and that all systems

are operating correctly

– they don‘t use it to power their house except in the case of an

emergency.

T he proposed rule affected all our electric utilities with fossil fuel generation and delayed the PSD triggering date for some very small emitters. In fact, we believe that the EPA has inadvertently counted some cogeneration manufacturing facilities as ―EGUs‖ because we cannot see how there are any electric utilities with coal or natural gas generation that would be allowed to delay their PSD permitting requi rements. However APPA would

not oppose granting any electricity generator provide r a regulatory delay in permitting (PSD or Title V) should such electric utilities with 25,000 tons given potential to emit

definitions.

The following chart indicated the number of hours that plants of varying size would need to operate prior to emitting 25,000 tons of CO 2 . These numbers are approximations as each plant is unique in terms of its efficiency. 1



### EPA’s Proposed 25,000 Ton Threshold Does Not Benefit Power

Generation

An additional concern relates to the idea of ―Potential to Emit.‖ As is discussed later in the information about APPA‘s generation mix, the emissions from a fossil fuel generation unit are typically much lower than its theoretical ―potential‖ to emit as units cannot be operated 24 hours a day, 365 days per year over time . This difference is best described

1 The emission factors used are based on EIA data from 1998 and 1999 contained on page 2 of a report

available at: http://tonto.eia.doe.gov/FTPROOT/environment/co2emiss00.pdf

476

238

119 758

379

189

50 MW 100 MW 200 MW 

## Hours to Trigger 25,000 Tons of CO 2

Coal Natural Gas3

by the ―capacity factor‖. The capacity factor is the ratio of the actual output of a power plant over a period of time and its output if it had operated at full nameplate capacity the entire time. For example, if a plant operated 24 hours a day, 365 days per year at its full potential, it would have a capacity factor of 100%. This is never the case. Baseload coal plants typically have ca pacity factors of between 70

- 90%.

There are two main reasons why a plant would have a capacity factor lower than 100%. The first reason is that it was out of service or operating at reduced output for part of the

time due to routine maintenance , repair, an d replacement . This accounts for most of the unused capacity of base load power plants. Base load plants have the lowest costs per unit of electricity because they are designed for maximum efficiency and are operated continuously at high output. C oal plant s are generally operated as base load plants.

The second reason that a plant would have a capacity factor lower than 100% is that output is curtailed because the electricity is not needed or because the market price of electricity is too low at that time to make production from this particular plant economical. This accounts for most of the unused capacity of peaking power plants

. Peaking plants may operate for only a few hours per year or up to several hours per day;

intermediate generation plants may ope rate more frequently, but are not baseload plants. Most of the natural gas plants operated by public power are either peaker or inte rmed iate plants and practically all of the diesel and fuel

- oil plants are peakers. Peaker plants generally operate only wh en there is a high demand, known as peak demand

, for electricity . This often occurs in the afternoon, especially during the summer months

when the air conditioning load is high (though in cold parts of the country, the peak can occur on winter days). The peak power load generally occurs between 4pm and 5pm when people return home from work, start cooking dinner, and turn up the air conditioning.

Therefore, a rule based on potential to emit would cover many more units than would ever approach emitting the threshold. For example, a 25MW diesel unit has the potential

to emit in excess of 25,000 tons of CO 2 . In reality, it probably will operate only a few hours a day during a few weeks of summer peak, thus emitting far less than 25,000 tons

of CO 2

. (see illustration on page 2) For this reason, APPA believes it would be wise to ―tailor‖ units that are used only as ―emergency generators 2 ‖ which would be consistent with the Mandatory Reporting of GHG Emissions Rule which exempts ―emergency generators‖ from reporting their GHG emissions.

2 As de fined in the Mandatory GHG Reporting Final Rule, ― Emergency generator” means a stationary combustion device, such as a reciprocating internal combustion engine or turbine that serves solely as a secondary source of mechanical or electrical power whenever t he primary energy supply is disrupted or discontinued during power outages or natural disasters that are beyond the control of the owner or operator of a facility. An emergency generator operates only during emergency situations, for training of personnel under simulated emergency conditions, as part of emergency demand response procedures, or for standard performance testing procedures as required by law or by the generator manufacturer. A generator that

serves as a back

- up power source under conditions of load shedding, peak shaving, power interruptions pursuant to an interruptible power service agreement, or scheduled facility maintenance shall not be considered an emergency generator. ( Federal Register, Vol. 74, No. 209, p. 56387)4

In addition to the issues with potential to emit for generation, APPA‘s transmission and

distribution utilities would also have concerns and impacts. Sulfur hexafluoride ( SF 6 ) is

used in the electrical industry as a gaseous dielectric medium for high

- voltage (35 kV and above) circuit breakers

, switchgear , and other electrical equipment, often replacing oil

filled circui t breakers (OCBs). SF 6 gas under pressure is used as an insulator in gas insulated switchgear (GIS) because it has a much higher dielectric strength than air or dry nitrogen. This property makes it possible to significantly reduce the size of electrical

ge ar. This makes GIS more suitable for certain purposes such as indoor placement, as opposed to air

- insulated electrical gear, which takes up considerably more room.

Gas

- insulated electrical gear is also more resistant to the effects of pollution and climate, as well as being more reliable in long

- term operation because of its controlled operating

environment. SF 6 is a potent greenhouse gas, with a global warming potential of 22,800

times that of CO 2

. Therefore, only approximately 1 ton (2,000 pounds) of SF 6 in a utility‘s distribution system would give it the potential to emit in excess of 25,000 tons of

CO 2 equivalent. As all of our systems with generation also have transmission and distribution syst ems, this is an even greater impact to generators.

APPA also notes that the presence of SF 6 is not the same as potential to emit . While CO 2 is emitted under normal conditions SF 6 emissions occur primarily from leaks in electrical transmission system equi pment in which SF 6 is used as an electrical insulator. EPA does not count ―potential‖ emissions from coal piles, gas pipelines, etc. for PSD and Title V

purposes

.

APPA believes that even where the proposed tailoring rule falls short of benefitting the pub lic power electric utility sector the proposed rule is generally positive. APPA‘s member utilities will clearly still be caught up in future PSD/Title V operating permit requirements under far tighter thresholds. The proposed tailoring rule does not elimi nate or delay our regulatory obligations. However, we believe that the EPA has honorable and commendable intentions to reduce the regulatory burden, costs, and administrative ―nightmare‖ for processing permits for millions of parties under a revised PSD/Title V operating permit threshold of 100

- 250 tons of CO 2

. Because this proposal generally helps the commercial and very small manufacturing community we must support the rule because these parties are our electric utility sector’s customers. If we ca nnot help the general small business community in this tailoring or streamlined permitting process then we cannot even help ourselves since confusion over increased emissions at a small business may contribute to more economic disruptions and the additiona l reduction of the sale of electricity.

While these comments are primarily focused on the proposed GHG tailoring rule, APPA will reference some positions on the other proposed rules since, ultimately, all the proposed rules and the EPA final rule on GHG r eporting do affect power plants. APPA

refers in this set of comments on PSD Tailoring/Title V permits to comments submitted earlier on the GHG Reporting Rule (attached in Appendix) and Endangerment (see in Appendix).5

APPA presumes that by the time these comments are received by the EPA and SBA that a final endangerment will be made. However, that does not mean that a decision should

be made on how best to regulate the electric power sector. APPA believes that the comments offered today should help get the EPA to think about ―next steps‖ in regulating

electric utilities in the most reasonable manner.

Our prior comments and new comments ( offered on Dec. 28 th ) on PSD Permitting are relevant since they refer to the best way to avoid an administrative problem in implementing CO 2 controls under the existing Clean Air Act. APPA re

- submits the comments on endangerment and points out , in this set of preliminary GHG regulation comments regarding SBREFA

, that any regulations on CO 2 will have a tremendous

economic i mpact on our community owned, not for profit, electric utilities.

APPA’ s Generation M ix:

In the public power community, approximately 550 utilities generate some or all of their own power; the remaining 1,450 are Transmission & Distribution utilities which purchase all of their power and re

- sell it to their residential, commercial, and industrial customers. Of the 550 utilities that generate some or all of their power, approximately 120 utilities own coal generation, particularly in the Midwest and So utheastern parts of the United States, approximately 265 utilities own natural gas generation, and 250 utilities own diesel or fuel

- oil generation (note, these numbers do not add to 550 as some utilities own multiple generation sources). While this may be a small number which own coal generation, this amounts to over 192 million MWh of electricity; the amount generated from natural gas is only 65 million MWh, and the amount generated from diesel or

fuel

- oil is less than 0.35 million MWh.

Please s ee A ttachments 1 and 2 which provide a map which illustrates public power‘s generating capacity mix by fuel and region and graphs which indicate APPA member electric generation by fuel type, both nationally and by region. It is important , again, to
note the d ifference between the two figures. The bar and pie charts (Attachment 1) illustrate the actual generation by fuel source

– this is different from the map (Attachment 2) which illustrates the generation capacity. As is clear, while there is a higher capac ity of natural gas, most of these units are peaking units that operate only a limited number of hours per year, thus contributing a smaller percentage of the actual number of megawatt hours generated. Coal plants, on the other hand, are baseload generatio n which is operated almost continuously, therefore making a larger percentage of the actual number of megawatt hours generated. In addition to the fossil fuel generation , public power members generate power from methane from municipal landfills, hydroelec tric, nuclear, wind, and other sources.

APPA’ s General Observations about SBREFA and UMFRA Impacts:

More than 90% of the APPA member utilities are SBREFA utilities

. All 100% of our electric utility members are units of state or loca l government and have Unfunded

M andates impacts resulting from any CO 2 regulations

. If all states air agencies had to6

manage the permitting requirements for all commercial and industrial enterprises with the lower PSD threshold at the same time, the presumption would be that the permitting costs

w ould increase

—

perhaps to necessitate a Title V operating permit fee since the states would likely have to hire additional personnel to manage the permit process. Whether due to the simple costs of a PSD and Title V permit process or t he risk of a Title V operating permit fee for CO 2 and other GHG emissions, APPA expects that the costs of a Title V operating permit fee will only increase. Currently most states charge $43 per ton of regulated pollutant for Title V permits.

APPA believ es that this is an example of how poorly the EPA conducted an economic analysis on the impacts of the proposed rule and “business as usual” if the millions of regulated parties needed PSD and Title V permits. If Title V permits and PSD permits necessitated the hiring of state employees, it would be a logical assumption that there would be some cost to perm ittees

– perhaps through a fee on GHGs.

APPA presumes that the costs of obtaining permits will increase from current permitting costs . Those costs will l ikely reduce the payment in lieu of taxes that the APPA member utilities provide to their local governmental agencies. It is a surprise to APPA that the EPA did not do a more thorough UMRA analysis. APPA believes that the EPA did a very poor job in its ass essment of costs to state governmental agencies

– including those electric utilities in APPA‘s membership.

APPA believes that the U. S. EPA grossly underestimated the impacts to both governmental entities including not

- for

- profit electric utilities with unfunded mandates and small business regulatory costs and obligations that drive up the costs of electricity

. Often the hardest hit customers for higher electricity rates are small businesses with less  ̳elasticity‘ in their energy usage

While the costs o f electricity are passed onto the local consumers (ratepayers) and other small business parties, the reduced funds for PILOT or Payment in Lieu of Taxes 3 are significant. The reduction in PILOT fees are especially significant during this time of economic distress in many communities and states. In most public power communities, approximately 6% of the electric utility‘s revenues are sent back to the municipal government‘s g eneral fund. The general fund contribution from the electric utility is used to fund firemen, police and emergency response personnel (EMT) in ambulances etc. In some public power communities, the PILOT fees may also provide revenue to the school

system to pay for teachers. The primary purpose of public power PILOT contributions to the municipal general fund is to pay for fire, police and EMT

— always essential personnel. In many public power towns, this general revenue payment is especially

critical since t he downturn in the fall, 2008. Since that time there has been an additional loss to municipal government for local sales tax, property tax payment, commercial real estate payments, and losses in residential real estate payments due to home foreclosure.

A ll these pressures on the municipal/state electric utility come at the same time when

3 Payments and Contrib utions by Public Power Distribution Systems to State and Local Governments, 2006
Data, American P ublic Power Association, Published March 20087

industrial and commercial load has dropped by as much as 20% due to manufacturing losses, plant closures, cessation of second and third manufacturing shifts at factories, and

milder winter 2008

- fall 2009 climate in most parts of the United States. (The 200 8 year study on PILOT fees and public power is provided in Attachment).

This graph shows the reduction in retail sales of electricity that has been occurring. 4

While not indicated on the graph, year

- to

- date electricity sales as of August 2009 have experienced a 4.7

- percent decrease from the same period in 2008. APPA believes that

at this time of economic uncertainty that the U.S. EPA should fully use the discretionary powers it has to “tailor” or phase in regulatory impacts on smaller commercial enterprises. While APPA realized many industries will still be “in the permitting mess,” we have an obligation to minimize t he permitting problems to businesses needing permit s and state regulatory agencies often facing budget cuts and staff shortages or layoffs.



### Trends in Retail Sales of Electricity, 1995

- 2008

EIA‘s Annual Energy Outlook (2009) predicts that the general trend of reduction in demand growth will continue , as illustrated in the following graph 5 :

4 Source: DOE/EIA

- 0226 (2009/11)

5 Source: EIA Annual Energy Outlook, 2009. Figure 54.

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Million KWh 

## Retail Sales of Electricity

Residential

Commercial

Industrial8

Impact Resulting F rom the Proposed Tailoring Rule to APPA’s SBREFA Qualified

Member Utilities :

APPA believes that more than 350 electric utilities will be affected by the PSD/Title V Operating Permit requiremen ts once the triggering date commences. Approximately 46 %

of the APPA ‘s member utilities electricity generate electricity using coal, and a nother

19 % generate using natural gas , including peaking or backup generation. 6

APPA’s Preliminary Comments/Recommendations on the EPA Proposed Tailoring

Rule : A PPA will file further comments on December 28, 2009. However, following are

some preliminary comments in advance.

1. The EPA has significantly more discretionary authority than the EPA described in the proposed tailoring rule. In fact, the EPA could use that discretionary authority in making regulatory determinations as to the actual triggering date and what happens to various sources after the triggering date. The EPA should also make the trigge ring threshold higher than 25,000 tons

. APPA is no t adv ocating for categorical exemptions for PSD or Title V permitting . APPA is describing the use of discretionary authority in phasing, sequencing or ―tailoring‖ the regulatory impacts based upon the emiss ions from various industrial and commercial parties (including municipal electric generation using fossil fuels).

APPA‘s December 28 th comments will more fully describe the discretionary measures and decisions made by the EPA that were not referenced in t he EPA request for comments in addition to the addressing the legal premise of

6 Source: Ventyx (formerly Energy Velocity) Database, March 2009 (based on 2007 data).9 ―Administrative necessity‖ and ―absurdity doctrine‖. APPA will make other suggestions that the EPA did not propose for small electric utilities.

2. APPA is worried about the commercial and light manufacturing customers of public power electric utilities

– especially during this economic downturn

. If there is great doubt as to the future of the PSD/Title V operating permitting program in the states and at the U. S. EPA then thi s permitting “ juggernaut ” is not going to be helpful to the customers of the electric power sector or to

our economy.

APPA assumes that the U. S. EPA did intend to not regulate mobile sources of emissions from electric utilities ( i.e. fleet vehicles, cus tomer service vehicles, service vehicles, and emergency or outage management vehicles) or from the office buildings of Transmission and Distri bution (―T &D‖) utilities which do not burn fossil fuels (coal or gas) directly. APPA supports this postponement of regulation of these parties and outright exemption of emergency generat i on

. While the EPA may have believed that all trucks merely act as transportation vehicles, there are circumstances where small diesel generators are placed on utility trucks to opera te as emergency generation for a school, small medic al clinic or rural hospital, nursing home, and dialysis treatment centers etc. This usually takes place during storms. (APPA realizes that all motor vehicles will ultimately be regulated under the Sectio n 202 rules and APPA is not questioning this decision). We are merely reminding the EPA that electric utility trucks should be exempt from PSD permitting and Title V permits . The PSD program and Title V operating permit conditions should only apply to true stationary sources

— not trucks with emergency generation. APPA believes that the EPA has considerable discretion in postponing or delaying PSD/Title V operating permit requirements for office buildings

— including the office buildings or auxiliary business centers
for electric utilities (such as bill paying centers) for electric utilities with no fossil fuel generation. The EPA final rule on GHG gas reporting did not cover fleet vehicles or T& D facilities with no generation. APPA commends the EPA for this pragmatic decision and believes that this should be the same decision in the ―tailoring rule‖. EPA‘s proposal did not call for comments on non

- generation operations at electric power utilities but did call for comments on office buildings Collectively the emissions from emergency generation is very small since often those emergency generators only run for 2

- 3 days due to a storm Occasionally the emergency generator might run a week in the event of a very serious storm. These emergency generation units are not to be confused with peaking units. In particular, APPA believes that emergency generation (often referred to as “reserve generation”) required by North American Electric Reliability Corporation (NERC)’ s reliability standards should be exempt. This sh ould include those generating units that meet the “black start” definition except where those units run more than 1,000 hours.

3. APPA believes that the EPA has discretion in increasing the 25,000 TPY in

emissions threshold when that threshold is increased primarily due to the10 installation of pollution control devices, renewable energy technology (including those installed as a result of state, county, city or other Federal renewables laws and regulations). This should also include public power or municipal decisions made in response to Federal, state or municipal purchasing requirements where some percentage of the energy produced must come from renewables or be made in conjunction with Renewable Energy Credits (RECs).

4. APPA believes that biomass used for F ederal, state, county or other renewables purposes should not be counted toward the 25,000 PTE threshold. In this rulemaking, APPA believes that renewables should be considered, consistent with international agreements on climate, that the biomass used is CO 2 neutral. To do otherwise, places the EPA in the position of creating disincentives to investing in the capital improvements necessary to utilize renewables.

5. APPA believes that the use of general permits or permits by rule is generally a good idea and will prov i de further comment on this later in the Dec. 28,

2009 comments. This support for permit by rule does not extend to the implementation of BACT by Rule

. APPA believes that once the PSD/Title V operating permit triggering date has come that th e use of general permits or permits by rule will minimize the regulatory burden on business (especially smaller businesses), local and state government and the U. S. EPA.

6. Although the EPA has not yet called for comments on ―what‖ or ―how‖ to regulate sm aller businesses under either NSPS or other regulatory mechanisms, APPA firmly believes that any technology selected must be commercially demonstrated and deployed before setting BACT standards. At this time, there is no commercially demonstrated and depl oyable technology for CO 2 other than energy efficiency. APPA has repeatedly commented on the hopes for CCS technologies to reduce CO 2 in the future. (See White Papers on CCS in the appendix). APPA does not believe that CCS is a commercially demonstrated

t echnology and it should not be presumed to be BACT.

7. EPA‘s proposal has asked for questions about BACT and presumptive BACT. Energy Efficiency i s the only demonstrated and commercially available technology to reduce CO 2 emissions on a wide scale basis

. Wh en referring to ―energy efficiency

, ‖ APPA means end

- use energy efficiency , i.e., energy efficiency and conservation measures undertaken by the customer, whether residential, commercial, or industrial, or the municipality itself. While there are certainly utility specific factors that must be considered and there cannot be a

―one

- size

- fits

- all‖ approach, many national studies show the potential for energy efficiency as a cost

- effective method of reducing CO 2 emissions, including EPRI‘s PRISM analysis and re ports by McKinsey & Company. The National Action Plan for Energy Efficiency, a private

- public initiative begun in the fall of 2005 by the EPA and DOE, has created a September 2009 resource document titled ―Energy Efficiency as a Low

- Cost Resource for Ach ieving Carbon Emissions Reductions‖ which addressed the potential of energy efficiency to11 reduce CO 2 emissions. APPA will expand on this later during the EPA‘s call for

comments under NSPS.

8. APPA urges the EPA to not make any presumptive BACT decisions that switching to natural gas should be required for existing or newly constructed power plants. While the nation may indeed have enormous supplies of natural gas (especially shale gas) we do not have su fficient natural gas storage or natural gas pipelines to service the 1,000 power plants all across the United States. (see map in Appendix) Further, natural gas plants will have more difficult CO 2 capture circumstances due to increased parasitic power req uired to ca pture the

CO 2 which is less concentrated in natural gas plant emissions than coal plant

emissions. The Agency should make no change in its practice of defining

BACT on a case

- by

- case basis, using the same established criteria that have

been used in their successful regulation of other emissions. BACT should only be based upon currently demonstrated and commercially deployed technology. For the power sector, this means energy efficiency with the ultimate consumer of electricity

— not just at the pow er plants

.

Attachments

Atta chment 1: Maps showing APPA‘s Generating Capacity by Region and Fuel Type

Attachment 2: Public Power‘s 2007 Generation by Region and Fuel Type

Attachment 3: Maps showing Natural Gas pipelines and storage

APPENDIX (under separate email file)

APPA White Papers on Carbon Capture and Storage ( 6 )

Carbon Capture and Storage: Analysis of Potential Liabilities Associated with Groundwater Contamination Due to Geological Sequestration Operations September 10, 2008

Retro fitting Carbon Capture Systems on Existing Coal

- fired Power Plants A White Paper for the American Public Power Association (APPA) L.D. Carter, November 2007

Geological CO 2 Sequestration Issue Spotting and Analysis white Timothy R Gablehouse, July 22, 200 9

Carbon Capture and Sequestration Legal and Environmental Challenges Ahead, August, 200712

Carbon Capture and Storage From Coal

- based Power Plants: A White Paper on Technology, L.D. Carter, May 22, 2007

Will Water Issues/Regulatory Capacity Allow or Prevent Geologic Sequestration for New Power Plants? A Review of the Underground Injection Control Program and Carbon Capture and Storage

N ovember 3 EPA CCS Meeting N otes from EPA Contractor

APPA Presentation to EPA on November 3 (contained in Appendix C of EPA CCS November 3 Meeting Notes from EPA Contractor)13 Attachment 114 Source: Ventyx Velocity Suite, March 2009 Attachment 215 Source: Ventyx Velocity Suite, March 2009 

## Public Power Generation Mix by Region and Energy Source, 2007 Attachment 216

Attachment 3 

## Natural Gas Pipeline Map, 200917 Attachment 3 

## Natural Gas Storage Map Illustrating the Small Number of Storage Locations18

APPA Contacts

Theresa Pugh

Director

, Environmental Services

American Public Power Association (APPA) 1875 Connecticut Ave, NW

12 th Floor Washington, D. C. 20009

202 467 2943 tpugh@appanet.org