Environment Filings and Resources | American Public Power Association

Climate

Comments on the Supplemental Notice of Proposed Rulemaking for the New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule.

Small Business Advocacy Review Panel Comments on the Proposed New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units.

Comments on the proposed Greenhouse Gas Emissions (GHG) rules for new, modified, reconstructed, and certain existing power plants under section 111 of the Clean Air Act (CAA). The proposed rules, if finalized, would impose stringent new source performance standards (NSPS) on power plants fueled by natural gas and impose strict limits on GHG emissions from existing fossil-fired generators. Specifically, EPA proposed to take five regulatory actions: update the NSPS for fossil-fuel-fired stationary combustion turbines (CTs); update the NSPS for GHG emissions from fossil-fuel-fired steam generating units that undertake large modifications; create emission guidelines for fossil fuel-fired steam generating EGUs’; create emission guidelines for GHG emissions from certain stationary combustion turbines and repealed the Affordable Clean Energy (ACE) rule.

First, Second, and Third Joint APPA-NRECA Request for an Extension of Comment Deadline for New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule

Comments in response to EPA’s pre-rulemaking Federalism Consultation on CAA 111(d), 111(b), and MATS RTR Rulemakings.

Comments on the Securities and Exchange Commission proposed climate risk disclosure rule, "The Enhancement and Standardization of Climate-Related Disclosures for Investors."

This paper summarizes Carbon Capture Utilization and Sequestration projects representing various stages of technology development and scale underway in North America.

APPA's issue brief Federal Efforts to Address Climate Change.

Environmental Permitting

Comments of the American Public Power Association on the National Environmental Policy Act Implementing Procedures for the Department of Energy, Categorical Exclusions

Comments on the National Environmental Policy Act Implementing Regulations Revisions Phase 2.

Summary of the Council for Environmental Quality (CEQ) Final National Environmental Policy Act (NEPA) Phase 1 Rule. The final rule amends three provisions―(1) the factors to be considered in the purpose and need section of an environmental impact statement; (2) establishment of CEQ’s NEPA regulations as a floor for agency-specific NEPA regulations; (3) and the definition of “effects”―of the 2020 NEPA regulations.

Comments of the National Rural Electric Cooperative Association and the American Public Power Association on the Council of Environmental Quality’s National Environmental Policy Act Interim Guidance on Consideration of Greenhouse Gas Emissions and Climate Change.

Air

Comments on the proposed Revisions to the Air Emissions Reporting Requirements (AERR).

Comments on the National Emission Standards for Hazardous Air Pollutants: Reciprocating Internal Combustion Engines and New Source Performance Standards: Internal Combustion Engines Electronic Reporting.

Comments on EPA’s proposed rule to amend the National Emissions Standards for Hazardous Air Pollutants for Coal- and Oil-fired Electric Utility Steam Generating Units Residual Risk and Technology Review.

Summary of the EPA’s final rule, Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standards. The Final Rule seeks to reduce nitrogen oxide emissions from power plants and industrial sources that contribute to problems attaining and maintaining EPA’s 2015 Ozone National Ambient Air Quality Standards (NAAQS) in downwind states.

Comments on EPA’s proposed Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standards.

Comments on the Adoption and Submittal of State Plans for Designated Facilities: Implementing Regulations Under Clean Air Act Section 111(d).

Comments of the American Public Power Association and the National Rural Electric Cooperative Association on the U.S. Environmental Protection Agency’s Proposed Rule, Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process.

Water

Summary of the final Water Quality Certification (WQC) rule under Clean Water Act section 401.

Comments on EPA’s proposed Supplemental Effluent Limitation Guidelines (ELG) and Standards for the Steam Electric Power Generation Point Source Category.

Summary of EPA’s proposed Supplemental Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category, which includes a discussion of the EPA’s proposed preferred option, proposed new subcategories, the cost benefit analysis, and a list of areas where EPA is seeking public comment.

Summary of the Revised Definition of “Waters of the United States” Final Rule. This update to the rule seeks to create a durable and clear rule that is based on the pre-2015 WOTUS regime and the sum of EPA’s 1986/88 WOTUS regulations, Supreme Court precedent on the interpretation of WOTUS, and the Agencies’ guidance documents which implement those holdings.

Comments on the Proposed Revised Definition of "Waters of the United States"

Waste

Comments on the Notice of Data Availability in response to the proposed Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments.

Comments on the Proposed Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments

Summary of the Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments in which the Agency proposes to regulate two different sets of units for the first time: legacy surface impoundments and CCR management units (CCRMUs).

Comments on EPA's proposed CCR Part A Rule: A Deadline to Initiate Closure.

Comments on EPA's proposed CCR Part B Rule: Alternative Demonstration for Unlined Surface Impoundments; Implementation of Closure.

EPA granted APPA’s application to renew its existing risk-based disposal approvals for APPA regular members on April 12, 2023. The renewal allows APPA regular members to dispose of PCB remediation wastes generated at secure utility assets with as-found concentrations of less than 50 ppm PCBs in non-TSCA units, including municipal solid waste landfills. In 2017, APPA initially applied for and was granted approval for its regular members to dispose of PCB Remediation Waste generated at secure utility assets with as-found concentrations of < 50 ppm PCBs in non-TSCA approved disposal facilities; subsequently, the approval was updated as the membership changed. APPA members have appreciated and benefited from the cost savings resulting from the approval.

Petition for Rulemaking on Regulating Photovoltaic Solar Panels as Universal Waste in which the American Public Power Association participated. This petition requested that the U.S. Environmental Protection Agency adopt a universal waste management standard for photovoltaic solar panels (“PV Panels”) to support the transition to clean energy.