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Extend Public Comment Period

on Rules for Existing Power Plants

Background: On June 25, 2013, President Obama issued a Memorandum directing the EPA to use the Clean Air Act (CAA) to issue proposed carbon dioxide (CO2) pollution standards and guidelines for existing and modified or reconstructed power plants, by June 1, 2014, and to finalize those rules by June 1, 2015. In addition, it tells EPA to collect state implementation plans by June 1, 2016.

In the past, EPA has set a performance standard - an emissions rate (e.g., pounds per megawatt-hour) for all affected units. Under the CAA, existing plants standards must reflect the degree of emission limitation achievable through use of the “best system of emission reduction” (BSER) that has been adequately demonstrated.

However, no control technologies for CO2 have been adequately demonstrated. While Carbon Capture and Storage (CCS) technology is being tested, it has never been deployed at a utility scale. The only adequately demonstrated onsite action to reduce CO2 emissions at existing power plants has been energy efficiency improvements to the plant.

Since most utilities maintain power plants as efficiently as possible, onsite measures to increase efficiency and limit CO2 emissions will likely yield small reductions. When EPA releases its proposed rule in June, it may seek to require greater CO2 emission reductions than can be achieved at individual power plants by looking beyond the individual plants and considering the entire electric utility system (from generator to the end-use consumer) to determine the “best system of emission reduction”. This could include requirements for utilities to:

Shift electricity generation from coal to lower-emitting fossil units such as natural gas.

Shift from coal or natural gas to non-emitting sources like wind or solar.

Reduce energy consumption through energy efficiency or demand-side management programs (such as co-op programs to reduce peak demand by controlling water heaters, etc).

These new regulations will likely be the most complex and important regulations written under the Clean Air Act for the utility sector. They also follow closely on the heels of other significant environmental regulations affecting power generation, including proposed CO2 rules that would essentially ban coal as a fuel for new power plants. EPA has provided an extended comment period on the rule governing new power plants (on top of a several month delay in actually publishing the rule in the Federal Register). EPA needs to provide sufficient time for the industry to read, analyze, and comment on this rule – at least the 120 days it has provided on the rule governing new power plants (which is a much more straightforward rule than we expect this regulation to be).

NRECA Position: Cooperatives believe that all emission reduction requirements must be tied to what is achievable at each unit. Currently, the only onsite action to reduce carbon dioxide emissions at existing units is to improve the energy efficiency of the unit itself, called a “heat rate improvement”. Measures that EPA may suggest outside the plant, across the broad utility system, will often be out of reach or ineffective for electric cooperatives.

Remind your Congressional Delegation:

In June, EPA will propose regulations to limit greenhouse gas emissions from existing power plants.

This regulation could threaten system reliability and affordability for electric co-op consumer members. It needs time for careful and thorough consideration.

Ask your delegation to support an adequate comment period of at least 120 days to allow co-ops and others the time to evaluate the implications of the EPA proposal and provide meaningful comments to the Agency.

For more information:

John Cassady, NRECA

703-907-5839

john.cassady@nreca.coop

John Novak, NRECA

703.907.5798

john.novak@nreca.coop