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Comment Details

Comment Author:Brad Albert
Organization:Arizona Public Service Co.
Comment Date:Friday, 30 October 2009
Comments: Are there any specific plants that have been misclassified with respect to whether they are marginal? If so, which ones and why?:
It appears that two data problems are leading to an error in the default emissions rate calculation for Arizona. The most significant is related to the Springerville coal-fired plant which is operated by Tucson Electric Power. These units should be classified as non-marginal units. I suspect that the capacity factor calculation is in error. The problem appears to be a mismatch between the amount of actual net energy production (included only 2 units) and the amount of capacity (includes capacity of 3 units). There also may be a data problem with TEP's H Wilson Sundt Generating station. Only one of the units at this station burns coal and the capacity assigned in the calculation is too high for that single unit.