Oct 022015


By Nolan Madden

As Governor Doug Ducey’s National Pollution Prevention Week concluded last Sunday, governments and businesses were engaged in dialogue and collaborative activities geared toward protecting and enhancing public health and the environment.

The state’s Department of Environmental Quality (ADEQ) began the month of September with the third of its forums addressing how Arizona will implement cleaner air pollution control measures based on the U.S. Environmental Protection Agency’s (EPA) proposed federal plan for the nation.

ADEQ’s approach to implementing the Clean Power Plan in Arizona consists of three phases. Stakeholder meetings during Phase 1 (Aug. 3 to Dec. 1, 2014) were held to gain an understanding of the proposed rule and generate comments to submit to EPA. Stakeholder meetings during Phase 2 (Dec. 1, 2014, to Aug. 3, 2015) were held to brainstorm potential compliance strategies.

During the Phase 3 meeting held Sept. 1, Eric Massey, ADEQ’s Air Quality Division director, summarized for more than 70 stakeholders how his agency arrived at its tentative action plan.

“We had 30 different potential compliance strategies that we received from our stakeholders. The top five strategies that were identified as part of our process include:

*      “Respect the remaining useful life of coal-fired units by not requiring premature closure impacting owners’ investments, employment and tax phases.

*      “Maintain a diversified portfolio without impacting reliability, limiting stranded investments and minimizing rate impacts.

*      “Consider natural gas limitations, including pipeline capacity, transmission, price volatility, water availability, and anticipated ozone standard changes.

*      “Develop interstate mechanisms for accounting, verification and tracking, and exchange of renewable energy/energy efficiency emissions reduction credits.

*      “Looking for equitable cost impact among rate payers. No one utility customer base or customer class is required to shoulder a disproportionate cost burden.”

Massey explained to the group that Phase 3 is the beginning of the state’s planning period. “This effort will continue for the next year until we submit the initial plan. We’ve been working hard to study and understand the more than 4,000 pages of preamble, regulatory text and limited technical support documentation that the EPA has proposed,” he said.

ADEQ officials note that the proposed Clean Power Plan would have required Arizona to achieve a 52 percent reduction in the CO2 emissions rate for affected power plants and to achieve about 90 percent of that reduction by 2020. The reduction for Arizona was much more stringent than the reductions proposed for neighboring Western states and was among the most severe imposed on any state. Current Arizona goals are now at 1,173 lbs. of CO2 per megawatt hour as an interim goal (24 percent reduction) and 1,031 lbs. CO2 per megawatt hour as a final goal (34 percent reduction).

ADEQ officials also noted that, partially as a result of extensive comments and technical data submitted by ADEQ and Arizona stakeholders, the reduction required has been reduced to 34 percent, and the timeline for achieving that reduction is much more gradual.

Massey said that ADEQ will look closely at the federal plan in order to develop comments on the final plan, “with the presumption that a state plan similar to the EPA’s federal implementation plan can gain approval.”

Massey also pointed out that a “robust ADEQ Technical Advisory Group of approximately 30 industry experts will continue to meet to provide a technical understanding of the rule. The group will also look at the federal plan and provide input on whether various strategies will work for Arizona.”

ADEQ’s next Clean Power Plan stakeholder meeting will be held on Tuesday, Oct. 6.