ACC Comments Submitted to EPA on State Guidelines for GHG Emissions from Existing Electric Generation Units

The American Coal Council submitted comments in response to the Environmental Protection Agency’s Dec. 28, 2017 advance notice of proposed rulemaking regarding State Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units.

Following are excerpts from ACC’s comments:

“As EPA considers a replacement of the CPP, we urge consideration of an approach in conformity with a traditional interpretation of the Clean Air Act on an ‘inside the fence line’ basis. This would limit emissions reductions to measures that can be implemented at the source – a single stationary power generation source or electric generating unit (EGU). Any such measures must be based on a physical or operational change to a building, structure, facility or installation at the source.

“Further, establishing the standard of performance must also reflect a traditional interpretation of the Best System of Emissions Reduction (BSER) – one that has been adequately demonstrated and considers the cost of achieving the greenhouse gas/CO2 emissions levels.

“Other measures or technologies such as converting coal to natural gas, other fuel switching, or co-firing should not be considered to be part of the BSER, as these would fundamentally alter a coal EGU. This, in turn, could negatively affect the appropriate mix of generation resources needed to reliably meet electricity demand at the company, state, regional or national level.”

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17. March 2018 by Terry Headley
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