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Continuing the Legacy New Beginnings September 15, 2016 Randy Eminger Executive Director Energy Policy Network Clean Air Act FIPs Source: William Yeatman globalwarming.org Sooner Station Victory Scrubbers vs. convert 4.4 million tons


  1. Continuing the Legacy New Beginnings September 15, 2016 Randy Eminger Executive Director Energy Policy Network

  2. Clean Air Act FIPs Source: William Yeatman – globalwarming.org

  3. Sooner Station Victory Scrubbers vs. convert 4.4 million tons PRB • to natural gas 2015 (CPE, Arch) Commission voted 3-0 • in favor of OG&E Opposition - sierra club, • wind, natural gas industry $500 million investment •

  4. Formula for Success Build a coalition Comments and Contacts • Electric Utilities (IOU, • Large industry (Michelin, Coops) IBM, American Airlines, • Transportation Tysons Food) (Railroads) • UP, ORRA • Large Industrials (OIEC) • Jones Public Relations • Conservative • Grassroots and earned Consumer Groups media (AFP) • Article in ‘ NewsOK ’ Educate • 600 emails to • Keep it simple stupid Commissioners Activate • 250 direct phone calls • Timing to Commissioners

  5. Texas Regional Haze Victory EPA Regional Haze FIP targeted 15 coal-fueled plants (8 • scrubbers and 7 upgrades) ERCOT predicted the closure of 3,000 – 8,400 MW of coal- • fueled power These 15 plants used 17.5 million tons of PRB coal (2015) • EPN joined with a small group of Balance Energy Texas • members in filing an intervention in support of the State of Texas 5 th Circuit Court of Appeals ruled in favor of Texas •

  6. Wichita Mountains National Park • Visibility benefit from FIP (adding controls to 15 plants) is .112 Deciview 1 Deciview is the measurement of what a human eye can detect 28 • miles away. 5

  7. Findings of the 5 th Circuit EPA rule was ‘stayed’ because Texas has an overwhelming • case with the likelihood of winning at the Supreme Court States Rights: EPA can set the visibility goal, but it can not prescribe the specific implementation plan Cost: EPA used a ‘cost per ton’ of emissions reduced to decide the cost of their FIP must use ‘cost per deciview ’ The jurisdiction should be with the District Court of Appeals, not • the DC Court of Appeals

  8. New Battleground - Arkansas White Bluff – 1,657 MW Independence – 1,678 MW U.S. EPA issued a Regional Haze FIP calls for Scrubbers on all four units • CAA sets a deadline of 5 year for the power plant to come into compliance • Estimated cost $2 billion •

  9. Reasonable Progress Assessment - Upper Buffalo Wilderness Area 16 14 12 10 (deciview, dv) Haze Index 8 6 4 2 0 Natural Conditions Observation Glide Path Baseline Rolling Average

  10. Reasonable Progress Assessment - Caney Creek Wilderness Area 14 12 10 (deciview, dv) Haze Index 8 6 4 2 0 Natural Conditions Observation Glide Path Baseline Rolling Average

  11. Arkansas’s Response “EPA’s mandates to impose billions of Strong response from both the dollars in economic costs without clear Governor and ADEQ health or environmental benefits is questionable at best and irrational at worst.” “I am mindful of litigation in surrounding states regarding their haze plans and I have directed ADEQ to work with the Arkansas Attorney General to pursue all available legal remedies.” Gov. Asa Hutchison “This Federal Plan mandates controls that are both unnecessary and costly and does not take into account the real progress Arkansas has made… Dir. Becky Keogh

  12. Campaign Strategy Define the Win • Measures for Success Develop Stategic Plan • funding/manpower • TimelineResource Needs (internal/external) Communication • internal/external Collaboration • Public and Private entities Step-by-step Operation periodic progress check

  13. EPA’s Clean Power Plan In other words, we rely tremendously on the generation that’s in place today to provide voltage support. And so when you lose the capability of the generation to provide that voltage support then you create voltage conditions so severe that you have blackout conditions and cascading outages.” Lanny Nichell, VP Engineering SPP

  14. Battling the Clean Power Plan SB 318 (Kansas) “We’re working like Crazy to get states to HB 1631(Missouri) take advantage of the Clean Energy Suspends all state agency Incentive Plan by the end of the year” activity on CPP AG letter to EPA and Congress “Obey the Stay”. Stop pushing states to draft plans. State Policymaker Outreach NARUC, ECOS, ALEC State Policy Network (47 state conservative organizations and think tanks) Engaging in Michigan IRP

  15. The loss of base load generation raises serious concerns about the electric reliability and fuel diversity. MISO projects a generation shortfall of 300 MW, 800 MW, and 1.2 GW in parts of Michigan, Missouri, and Illinois, respectively.

  16. Transfer of Funds Under CPP Winners and Losers Sponsored by: EPN and the U.S. Chamber of Commerce Produced by: Natural Resource Economics ( Dec. 2016)

  17. Advancing Existing Technology PolkPower Station (TECO Energy) Kemper County MS (Mississippi Power)

  18. Advanced Carbon Capture Petra Nova Project NRG Parish Power Plant (Houston, TX) WY Integrated Test Center (Dry Fork Station)

  19. Energy Policy Network Randy Eminger reminger@tepn.org Phone – (806)674-7079 Website www.energypolicynetwork.org

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