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DMDMIL regulator of electric power within the United States, including regulating(i)the dispatch of electric generation, (ii)the amount of renewable power to be built, and(iii) the electricity consumption of customers. This is an enormous and transformative expansion in EPA's regulatory authority without clear congressional authorization, which is precisely what the Supreme Court recently invalidated in UARG v. EPA, 573 U.S. at 2431 (2014). CPP treatment of early action Under EPA's methodology, states are assumed to achieve minimal reductions in CO2 emissions from the electric utility industry during the 15-year period from 2005 to 2020. States are then required to achieve their entire assigned reduction(41 percent for Minnesota)during the 10-year period from 2020 to 2030. This construct not only flies in the face of reality in early adopter states such as Minnesota,it also ignores the incremental pace of change that occurs in the highly regulated and capital- intensive electric utility industry. Although the goal of the CPP is to achieve a 30 percent reduction in 2005 carbon dioxide emissions,the actual it base year for the plan is 2012. Reductions in CO2 :<, t emissions achieved during the seven-year period from 1/ 2005 to 2012 are completely ignored by EPA's formula. ' ! rz "` $ �� Further, any CO2 reductions during the eight-year period from 2013 through 2020 beyond EPA's modest Minnesota utilities have been diligently adding renewable assumptions should count toward achieving the state's resources for years.These two wind turbines south of Fairmont goal. were dedicated in 2003.They are owned by SMMPA and feed directly into the Fairmont Public Utilities distribution system. Minnesota Greenhouse Gas Reduction Efforts Minnesota has been a leader in the Upper Midwest in developing state energy policy to reduce greenhouse gas emissions. Minnesota has established a goal of reducing greenhouse gas emissions from 2005 levels by 15 percent by 2015, 30 percent by 2025 and 80 percent by 2050. Our RES requires power suppliers in the state other than Xcel to achieve 25 percent renewable energy - "' �•• '" ""` by 2025.Xcel, which accounts for about 46 percent of 4°'_ — - _ _ total sales,is required to achieve 30 percent renewable energy by 2020. Minnesota has banned the construction The Hometown BioEnergy plant near LeSueur, owned by the of or purchase from large new coal-fired power plants Minnesota Municipal Power Agency,produces fuel made from and imposed one of the most stringent energy efficiency refined food and agricultural processing wastes. The eight- requirements in the country. megawatt plant entered service in 2014. The Sustainable Building 2030 program requires least 1.5 percent of retail electric sales made by investor- performance standards for new and substantially owned utilities must come from solar energy. reconstructed buildings to reduce their CO2 emissions by 60 percent in 2010; 70 percent in 2015; 80 percent in Greenhouse Gas Reduction Program Results 2020; and 90 percent in 2025. It is an energy goal of the A review of Minnesota data clearly shows both how state that by 2030, 10 percent of the retail electric sales effective Minnesota's efforts have been, and how severe in Minnesota be generated by solar energy. By 2020, at the penalty can be for an early adopter state. 2015 Federal Position Statements/4