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Dennis Hill

Co-ops studying proposed EPA regulations

By Dennis Hill

Electric cooperatives and other utilities are studying the proposed guidelines for carbon dioxide emissions from existing power plants, which were released June 2 by the Environmental Protection Agency (EPA) and published in the Federal Register on June 18.

The proposed rule is under section 111(d) of the Clean Air Act. The proposed 111(d) guidelines establish goals for each state to reduce its carbon dioxide emissions rate (lbs. of CO2/megawatt-hour of generation). The plan would give states the flexibility to choose how to meet their goals using a combination of measures that reflect each state’s particular circumstances. States have one to three years to submit their final plans to EPA after the agency publishes its final rule, which is expected next year.

At a recent industry update hosted by our association, attendees heard from Dave Glatt, chief, Environmental Health Section for the N.D. Health Department, about approaches that could be used to comply with the proposed rules. The reduction proposed for North Dakota would be about 11 percent from its 2012 level and is the lowest goal of any the 49 states affected by the rule.

The EPA derived each state’s goal, in part, by analyzing four building blocks of existing technology that it believes could be used to reduce carbon dioxide emission rates. These include establishing energy-efficiency programs, implementing coal power plant efficiency measures, increasing production of renewable energy, extending the life of current nuclear plants, and ramping up use of combined-cycle natural gas plants that emit less carbon dioxide than existing coal plants.

The Health Department began working with Basin Electric Power Cooperative, Bismarck, and other utilities in April to gauge interest in regional approaches to respond to the proposed rule. Fifteen states agreed to take part in the discussion. At the end of a two-day meeting, the participating states agreed to send a letter to that EPA that expressed early concerns about the proposed rule. The concerns noted in the letter are:

  • States should remain in the lead role for implementing federal rules or guidelines established under the Clean Air Act;
  • The timetable for 111(d) implementation is unrealistic and unachievable;
  • Any rules must not adversely affect electrical system reliability, affordability and accessibility; and
  • Any rules must utilize applicable and available technology.

These points outlined by the states are a good starting point in fashioning a response to the proposed rule. They are common-sense approaches, and if accepted, could limit the economic impact the rules could have on the operation of our existing plants.

The North Dakota Association of Rural Electric Cooperatives will continue to review the details of the proposed EPA guidelines, and work with our cooperative members, our national association, and our state officials and Congressional delegation to provide the EPA with comments and any recommended changes to the guidelines during the formal comment period, which ends Oct. 15.

Dennis Hill, editor-in-chief of North Dakota Living, is executive vice president and general manager of the North Dakota Association of Rural Electric Cooperatives, Mandan. Comments can be mailed to Dennis Hill, NDAREC, P.O. Box 727, Mandan, ND 58554-0727 or by email to


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