What is your reaction to how the EPA’s carbon emissions rule might affect your state? What are some ways your state is already prepared and what might be more challenging?

It’s going to impact all states differently and regions differently for that matter, the way they’ve calculated the state goals. Take the West for instance. It imposes a higher sort of proxy for renewable energy expectations on the West than say on the Southeast. So in general Western states’ component of that goal will be larger than other regions. And some states…with very aggressive energy policies like California, they’re probably not going to have any problem complying but for states with low populations that have a lot of electricity generation in them that is exported to other (Montana, Wyoming, North Dakota) compliance could be very difficult and trying to figure out who pays and who the compliance obligation is lodged on will be a difficult task.

(On renewable energy targets) it’s unclear…in the western grid whether the grid could even accommodate all that new generation…We’re severely transmission constrained in the West. We send power thousands of miles over 500 KB lines its very different than in any other region of the United States, and although EPA has given great lip service to allowing regional flexibility the actual computation of state goals derives from a cookie cutter formula the best system of emission reduction that fails to make any kind of meaningful distinction between regions and states.

The simplest (option) would be just to close down this or that coal plant but that ends up possibly jeopardizing West Coast utilities who are relying on those coal plants. Second best – you know we will have to think about regional solutions, but it’s hard enough for states to get together and work together on relatively mundane things…Imagine the difficulty of putting together a multi-state plan on something like carbon, where a politically sensitive subject is actually involved.

But it’s so preliminary I couldn’t talk intelligently on how the state of Montana would comply.

Do you foresee your state having a formal or informal stakeholder process?

How many times have I been at meetings like NARUC and heard the complaint there’s no national energy policy. There’s nothing guiding us. Well, now there is. And who would of thought that the national air quality regulator, the EPA, would be the one to substantially dictate energy policy in the U.S.…We have some kind of a new mandate that we are going to grapple with. Preliminarily it appears to be a legal mandate executed under their authority not withstanding the challenges that I’m sure will be filed.

People in RTOs may have an easier time. They already have a structure that allows them to grapple with some of the really contentious state issues like transmission. (Some states) don’t have that kind of structure, and I really don’t understand what organization will be a natural home for these conversations in the West to occur.

Certainly it’s already happening informally. I have no idea whether a formal organization will surface as well.

What are some of the biggest energy issues facing your state?

It’s the changing resource mix. It’s the degree to which the West in general is weather-dependent…If you’re moving away from known dispatchable resources like coal and (toward) a greater reliance on gas on wind and weather- dependent resources then you’re exposing yourself to more risk.

This interview was conducted at the NARUC summer meetings in July 2014. To see Q&As with commissioners from other states, visit our interactive map. For a broader story about how state regulators from around the country are reacting to the EPA’s carbon emissions proposal, click here.

If you’re a commissioner and didn’t get to talk to Morning Consult at the conference, feel free to contact Emily Holden. We’d love to hear from other state officials and stakeholders too.

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