In a recent Integrated Resource Plan (IRP) proceeding, the AEP System Operating Company Indiana Michigan Power (I&M) was requested by the Michigan Public Service Commission (MPSC) to perform an Environmental Justice analysis on the base case and preferred cases being presented. The significant issue with this analysis is that all of the fossil generation represented in the Plan is not located in the IRP jurisdiction. The closest any specifically identified resources are located to any Environmental Justice areas of concern in the IRP jurisdiction is several hundred kilometers away. Any fossil generation that may originate within the jurisdiction being studied would be part of an imported resources category in the Resource Plan that is not able to be defined at the generating facility level for analysis as this category represents energy purchased from the grid. Due to its membership in the PJM Regional Transmission Organization, I&M would preferentially source needed import power from the PJM Region and not from facilities in Michigan that are not in the PJM Region. This paper discusses the methods used to perform this analysis focusing on the air quality aspects of the analysis.
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