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<br /> Figure 1
<br /> Annual Minnesota Generation from Selected Sectors,Sales,and Electric Industry CO2 Emissions 2005-2012
<br /> Electricity Net Electricity Net Electric Power Total
<br /> Electricity Net Generation Generation Electricity Net Minnesota Industry Carbon
<br /> Generation From From Nuclear Generation Total Retail Carbon Dioxide Dioxide
<br /> From Coal Natural Gas Electric Power From Wind Sales Emissions Emission
<br /> 1,000 Metric Rate
<br /> Year mWh mWh mWh mWh mWh Tons lbs/mWh
<br /> 2005 32,949,845 2,707,267 12,835,219 1,582,477 66,019,053 39,516 1,640
<br /> 2006 33,070,451 2,560,797 13,183,418 2,054,947 66,769,931 38,183 1,578
<br /> 2007 32,190,373 3,842,477 13,103,000 2,638,812 68,231,182 38,321 1,548
<br /> 2008 31,755,253 2,865,846 12,996,838 4,354,620 68,791,615 36,821 1,479
<br /> 2009 29,327,226 2,846,483 12,393,425 5,053,022 64,004,463 33,689 1,412
<br /> 2010 28,082,550 4,340,847 13,478,046 4,791,723 67,799,706 32,946 1,350
<br /> 2011 28,258,626 3,350,773 11,958,525 6,725,695 68,532,708 32,618 1,351
<br /> 2012 22,722.774 7,088,205 11,943,790 7,615,408 67,988,535 28,494 1,201
<br /> Change -31% 162% -7% 381% 3% -28% -27%
<br /> Source: EM Minnesota Electricity Profile, Tables 5, 7,and 8
<br /> 2005—2012 Unfair treatment of early adopter states
<br /> Figure 1 shows a 27 percent reduction in Minnesota's Minnesota is on track to achieve reductions in CO2
<br /> annual power sector CO2 emissions from 2005 to 2012. emissions from electric generation of perhaps 30 percent
<br /> As we point out below, Minnesota's newest'and most during the fifteen year period from 2005 to 2020. These
<br /> efficient coal plant was off line during all of 2012, reductions need to count toward achieving our goal
<br /> which makes Minnesota's CO2 emissions for that year under the CPP. The EPA plan disregards substantial
<br /> abnormally low. If we assume that half of the reduction reductions in CO2 that are being achieved in Minnesota
<br /> from 2011 to 2012 is due to the Sherco 3 outage and and other early adopter states. Minnesota would be
<br /> half due to the impact of Minnesota energy policy, the forced to achieve a 41 percent reduction in CO2 emissions
<br /> reduction is still 21 percent. The Great Recession had by 2030 after reducing emissions by perhaps 30 percent
<br /> an impact on electricity sales, but total retail sales in the years leading up to 2020.
<br /> have returned to pre-recession levels, so any recession
<br /> impact on CO2 reduction in the 2012 data is minimal. Minnesota's electric utilities are making substantial
<br /> To be conservative,we can state with confidence that investments to achieve today's greenhouse gas emissions
<br /> Minnesota achieved a genuine greenhouse gas reduction reductions.And the reductions achieved from 2005 to
<br /> of 15 percent to 20 percent from 2005 to 2012. 2020 will make further mandated reductions that much
<br /> more difficult and expensive to achieve. Our consumers
<br /> 2013—2020 will have to bear the huge cost of reducing CO2 emissions
<br /> Minnesota will continue its aggressive greenhouse by as much as 70 percent by 2030. EPA must recognize
<br /> gas reduction policy during the eight-year period from the pre-2020 emission reductions achieved by Minnesota
<br /> 2013 through 2020. In 2020 Xcel will be at 30 percent and other early adopter states in the final rule.
<br /> renewable and all other power suppliers will be at 20
<br /> percent renewable(on the way to 25 percent in 2025), Choice of baseline period
<br /> for a statewide renewable portfolio of 24.6 percent. Sherco 3,Minnesota's newest and most efficient coal
<br /> Minnesota's aggressive energy efficiency requirements plant(jointly owned by Xcel Energy and Southern
<br /> and energy efficiency performance standards for Minnesota Municipal Power Agency(SMMPA)) was
<br /> buildings will provide increasing levels of greenhouse off-line during all of 2012, the year used by EPA as the
<br /> gas reductions with each passing year. Minnesota energy baseline in the CPP.As a result, Minnesota's mandated
<br /> policy will provide additional greenhouse gas reductions CO2 reduction in the plan is substantially larger than it
<br /> from 2013 through 2020 of 10 percent to 15 percent. would be if EPA had used typical Minnesota annual coal
<br /> generation in the plan. EPA needs to allow Minnesota to
<br /> 2015 Federal Position Statements/5
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