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11111111/1 <br /> IVIIVIWt <br /> state that by 2030, 10 percent of the retail electric sales to 2020. EPA's treatment of early adopter states in the <br /> in Minnesota be generated by solar energy. By 2020, at final rule will have huge implications for Minnesota. <br /> least 1.5 percent of retail electric sales made by investor- <br /> owned utilities must come from solar energy. Choice of <br /> � � � <br /> baseline period <br /> Greenhouse Gas Reduction Program Results Sherco 3, <br /> A review of Minnesota data clearly shows both how Minnesota's <br /> effective Minnesota's efforts have been and how severe newest and <br /> the penalty can be for an early adopter state. most efficient I: - <br /> coal plant <br /> 2005—2012 (jointly owned •y` <br /> Figure 1 (facing page) shows a 28 percent reduction by Xcel Energy <br /> in Minnesota's annual power sector CO2 emissions and Southern <br /> from 2005 to 2012.As we point out later, Minnesota's Minnesota The Southern Minnesota Municipal Power <br /> newest and most efficient coal plant was off line during Municipal Agency owns 41 percent of Sherco 3.The <br /> all of 2012, which makes Minnesota's CO2 emissions Power Agency plant is co-owned and operated by Xcel <br /> for that year abnormally low. If we assume that half (SMMPA))was Energy. <br /> of the reduction from 2011 to 2012 is due to the Sherco off-line during <br /> 3 outage and half due to the impact of Minnesota all of 2012, <br /> energy policy, the reduction is still 21 percent. The the year used by EPA as the baseline in the CPP.As a <br /> Great Recession had an impact on electricity sales, result, Minnesota's mandated CO2 reduction in the plan <br /> but total retail sales have returned to pre-recession is substantially larger than it would be if EPA had used <br /> levels, so any recession impact on CO2 reduction in the typical Minnesota annual coal generation in the plan. <br /> 2012 data is minimal. To be conservative, we can state EPA needs to allow Minnesota to select a baseline period <br /> with confidence that Minnesota achieved a genuine that provides an accurate picture of our coal generation <br /> greenhouse gas reduction of 15 percent to 20 percent in a typical year. EPA's decision on the baseline issue <br /> from 2005 to 2012. will have a major impact on Minnesota's mandated CO2 <br /> reduction in the final version of the CPP. <br /> 2013—2020 <br /> Minnesota will continue its aggressive greenhouse • Cross-state ownership of renewables. The CPP treats all <br /> gas reduction policy during the eight-year period from renewables located in a state as essentially"belonging" <br /> 2013 through 2020. In 2020 Xcel will be at 30 percent to that state. But ownership of renewable energy <br /> renewable and all other power suppliers will be at 20 projects isn't that simple. Minnesota power suppliers <br /> percent renewable, for a statewide renewable portfolio have developed or contracted with renewable projects <br /> of 24.6 percent. Minnesota's aggressive energy efficiency in other states in order to meet the requirements of <br /> requirements and energy efficiency performance our renewable energy standard. Conversely, utilities <br /> standards for buildings will provide increasing levels from other states have developed renewable projects <br /> of greenhouse gas reductions with each passing year. in Minnesota. EPA will have to clarify how renewable <br /> Minnesota energy policy will provide additional energy projects are to be allocated among states that <br /> greenhouse gas reductions from 2013 through 2020 of 10 have legitimate reasons to claim the output under <br /> percent to 15 percent. the CPP.Any decision the EPA makes will produce <br /> winners and losers, and will have a significant impact on <br /> Unfair treatment of early adopter states Minnesota's ultimate obligations under the CPP. <br /> Minnesota is on track to achieve reductions in CO2 <br /> emissions from electric generation of perhaps 30 percent MMUA Position <br /> during the fifteen year period from 2005 to 2020.And As proposed, EPA's Clean Power Plan presents very <br /> none of these reductions will count toward achieving our serious problems for Minnesota.We can only hope that <br /> goal under the CPP.This result completely disregards EPA will address these issues in the final version of the <br /> substantial reductions in CO2 that are being achieved rule, which is expected in mid-summer 2015. Only when <br /> in Minnesota and other early adopter states. Minnesota the rule is final can Minnesota begin in earnest on the <br /> would be forced to achieve a 41 percent reduction in development of its CPP plan. It would be premature and <br /> CO2 emissions between 2020 and 2030 after reducing unwise to make any changes in state laws that would be <br /> emissions by perhaps 30 percent in the years leading up affected by the rule until then. <br /> 2015 State Position Statements/5 <br />