CLEAN POWER PLAN (111D) AND THE STATE OF

NORTH DAKOTAL. David Glatt

North Dakota Department of Health

Environmental Health Section

Background History

Background History

Background History

Industry Issues

Potential to Achieve IF:

Time to develop strategy and business plans Address Significant Investments and

Obligations Bridge from current conditions to future

energy plan Impacts on Reliability and Cost Develop Technology Transmission

111(d) Questions:Building Block 1: Energy Efficiency

> Historically an ongoing process Coal Drying New Turbines

> 6 Percent Unrealistic under current proposal

111(d) Questions:Building Block 2: Redispatch

How to credit new development?

In a load growth climate new development may not replace existing coal generation.

111(d) Questions:Building Block 3: Renewable Power

How will it be credited?

Who will decide?

Wind potential in North Dakota

111(d) Questions:Building Block 4: Demand

Side Efficiencies

Efficiency program implemented by industry are currently dealing with reducing peak demand issues

Timing to allow for legislation

111 (d) Questions and Concerns

Adequate time to develop comprehensive plans

Enforceability of Multi State Plans How to address multiple agency

jurisdiction State Public Service Commission Federal FERC/NERC/RTO

How to address multiple plan types EPA Jurisdiction Allow time for litigation to take place

State Discussion

Propose (tentative) not comprehensive or final: Eliminate interim goal Set compliance date for 2030 Allow for applicable technology, reliability and

cost review by the state Provide Certainty for future actions-regulations Interim plan review Do not change proposed goal for North Dakota Allow for credit of all Natural Gas development

to meet demand