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I,,I,IwV <br /> select a baseline period that provides an accurate picture MMUA Position <br /> of our coal generation in a typical year. As proposed, EPA's Clean Power Plan presents very <br /> serious problems for Minnesota. In the final rule EPA <br /> Cross-state ownership of renewables must recognize and take into account the very real <br /> The CPP treats all renewables located in a state as greenhouse gas emission reductions that Minnesota <br /> essentially"belonging"to that state. But ownership of and other early adopter states have achieved and will <br /> renewable energy projects isn't that simple.Minnesota continue to achieve prior to 2020. Minnesota must be <br /> power suppliers have developed or contracted with allowed to select a base period that provides an accurate <br /> renewable projects in other states in order to meet picture of our coal generation in a typical year. EPA <br /> the requirements of our renewable energy standard. must exercise great care in determining how renewable <br /> Conversely, utilities from other states have developed energy projects are to be allocated among states that <br /> renewable projects in Minnesota. EPA will have to have legitimate reasons to claim the output under the <br /> clarify how renewable energy projects are to be allocated CPP. <br /> among states that have legitimate reasons to claim the <br /> output under the CPP.Any decision the EPA makes will We urge the members of Minnesota's Congressional <br /> produce winners and losers, and will have a significant delegation to tell EPA that Minnesota needs relief in <br /> impact on Minnesota's ultimate obligations under the the final rule from these troublesome and ill-designed <br /> CPP. aspects of the proposed CPP. <br /> ,,,,,,... ..,,,,,4-„,...,,* 'N*...• ` - -. *:;,:wirs 4 r .' i- or <br /> alp y - -ate A �1 '�' '/- <br /> 4,„... to <br /> ./ <br /> . .„..:. ,.„,.q s - r•i 4: "a' S. > F- ,, ,ems !+r it <br /> ;r } t <br /> *fi r.-' 14. A? ? , r,iky 7,„ `�3-i:r._ ' - <br /> ti•4 '"' fib' { 2' it* ''.5 .y is' °.? ` ... <br /> *IA f il'4 #6. Y st . 'r <br /> , � _'._ -'r- r- Wind Speed <br /> ti. w :i rills <br /> toe:410a ,....os <br /> .t . ' .0,,_,.,..., '''C <br /> w-.4-' t t+ate ;;ii <br /> 5.0 <br /> 4.0 <br /> . cd0 <br /> Source:Wind resource estimates devetoped by AWS True r, f <br /> LLC for windNain atorg.Web.hlt alwwwwlndnavr ator.00m ' <br /> ° NREL <br /> ht1p:/A vw aws1ruepower.cam.Spatial resolution or wind resource •:;" <br /> data:2-5 km.Projection:Albers Equal Area VUGS84. - <br /> Recognizing the greater wind resource to the west,Minnesota utilities have built significant wind resources there.However, <br /> the Clean Power Plan credits those resources to North and South Dakota,not Minnesota. <br /> 2015 Federal Position Statements/6 <br />