5.2. ERMUSR 07-15-2014 - Laserfiche WebLink

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stewards of public power in our community, to be progressive and strategically plan for the future. When attending industry events, staff is always looking for new ideas that may help ERMU improve our services. During this event and the pre-conference seminars there were many opportunities to engage other public power managers and policy makers to discuss issues facing Elk River Municipal Utilities. There were a number of reoccurring discussion points and takeaways from those conversations, the pre-conference seminars, and the conference break-out sessions. As follows in no particular order are the top topics from the APPA National Conference for ERMU Commission discussion: Environmental Protection Agency EPA)—Proposed Carbon Dioxide (COQ) Emissions Guidelines for Existing Fossil Fuel-Fired Power Plants: The guidelines were released days before this conference leaving little time for APPA to research and prepare presentation material. Teresa Pugh, APPA's Director of Environmental Services, and Alex Hofmann, APPA's Energy &Environmental Services Manager, did a great job working through 100's of pages of the rule to provide a report on their analysis of the proposal. This is a big deal for our industry and for our national economy. Some of the key points and questions regarding this proposed rule: • It is widely believed that this EPA proposed rule exceeds the authority given under the Clean Air Act(CAA). It is questionable whether the EPA through the CAA would be equipped to enforce the rule. Congress would better represent the citizens, and would be able to better address any concerns related CO2 reduction, and therefore should be the ones to develop a plan for CO2 reduction, not the EPA. • The proposed rule would reduce CO2 emissions by 30%nationwide by 2030. • Although the 30% goal is nationwide, states would be required to individually develop a plan from proposed options to meet their own goals. This approach does not take into account that many generation facilities are not sited in the same state as the end user. If states are not required to work together, there will likely be subsidization. • The goals are front loaded creating addition compliance concerns. • Minnesota's required reduction is among the highest in the nation at 41%. North Dakota's and Wisconsin's required reductions are 11%, and 34%respectively. This proposed rule is likely to put Minnesota at an economic disadvantage to our neighboring states and put the Midwest at an economic disadvantage to the country and the global economy. • Unclear whether the emissions reduction baseline is 2005 as originally noted, or is 2012. If the emissions baseline is 2012, it would mean that renewables installed between 2005 and 2012 would not count towards the reduction goal. This might eliminate the contribution towards the goal from MMPA's 44MW Oak Glen Wind Farm which entered commercial operation in October 2011. Essentially, early adopters may be penalized. • It is unclear which state entity would have ultimate jurisdiction over the rule: Minnesota Pollution Control Agency, Minnesota Public Utilities Commission, Minnesota Legislators, etc... • There will be a comment period before the rule go into effect. It is not too early to discuss the proposed EPA rule's impact on our community with our state agencies and elected officials. 'POWERED DV Page 2 of 4 NATURE 'URE Reliable Public Power Provider P O W E R E D T o S E R V E 73