5.5 ERMUSR 03-17-2015 - Laserfiche WebLink

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larrigivie am:1 0 Position Statement The EPA Clean Power Plan — Minnesota Needs Major Changes in the Final Rule The electric utility industry is suddenly facing more /7--- - than a dozen environmental regulations over the next few years on a host of issues, including air pollutants, greenhouse gases, water, and coal combustion residuals. Several regulatory programs could transform the entire electricity industry,causing major concerns over reliability of the grid and possible significant increases / in consumer rates.The most problematic regulatory ii effort for Minnesota is EPA's Clean Power Plan, a major undertaking that seeks significant nationwide / reductions in carbon dioxide emissions from existing power plants. r` / f On June 18, 2014, the U.S. Environmental Protection r ' Agency(EPA)published a proposed rule known as the Clean Power Plan(CPP).The CPP would establish r emission guidelines for existing electric generating units t (EGUs)under section 111(d) of the Clean Air Act(CAA). EPA is expected to issue the final version of the CPP in mid-summer 2015.MMUA filed extensive comments on the proposed rule.The final rule will likely contain ' significant changes and clarifications. a=/, Legal Issues The CPP is very different from clean air regulations developed by EPA in the past. It is subject to numerous legal challenges and is probably more susceptible to ,' being overturned than most new regulations. A. Section 111(d)of the CAA is intended to regulate f stationary sources of air pollution,but the CPP doesn't regulate individual sources, such as power plants. It regulates states.The law intends that states develop ! / plans which establish standards of performance for 1j,it power plants. But the CPP turns this process on its head and makes states the regulated entities rather than the The CapX2020 transmission lines will serve Minnesota's regulators that the law intends them to be. expected growth and help begin to meet Minnesota's Of the nearly 100 New Source Performance Standards Renewable Energy Standard (RES). The Brookings County (NSPS) and emission guidelines EPA has developed Hampton 345 kV line (pictured) will expand access to wind resources by adding about 700 MW of capacity to the since 1970,every one has been based on a"system of transmission grid.This line,along with other projects recently emission reduction"that is incorporated into the design completed or currently under construction or in the planning or operation of individual sources.The CPP instead stages, has the potential to add nearly 2,000 MW of wind uses a series of"building blocks"that go well beyond the capacity to the transmission grid. It's estimated Minnesota operational characteristics of the power plant that is needs about 5,000 MW of renewable energy to meet the RES, the source of the CO2 emissions that the EPA wants to one of the nation's most aggressive renewable energy laws. reduce. Unfortunately, early actions to reduce greenhouse gases are not recognized under the Clean Power Plan as proposed. The EPA would replace the Federal Energy Regulatory Commission and the states to become the primary 2015 Federal Position Statements/3