Washington D.C., August 8, 2023 — The American Public Power Association today submitted comments to the Environmental Protection Agency on the agency’s 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.
In its comments, APPA recognizes the importance of reducing greenhouse gas emissions to address climate change and points out that public power utilities reduced their carbon dioxide emissions by 31 percent from 2005 to 2022, which contributed to the electric generating industry being the industrial sector with the largest amount of GHG emissions reductions in that period. Equally important to APPA members, however, is their duty to provide their communities with a reliable supply of affordable electricity. They are concerned that the proposed rule would impede this responsibility.
APPA calls for EPA to:
- Analyze how the proposed rules would affect electric reliability and implement changes to the proposed rules to ensure grid reliability.
- Find that carbon capture and storage and hydrogen co-firing, while promising technologies, are not mature enough to be considered the best system of emissions reduction.
- Consider raising the size and capacity factor threshold for existing natural gas-fired units that are subject to the proposed rule.
- Revise the unrealistic timeline for compliance with the rules.
- Issue a model trading rule for existing generating sources.
- Provide states with alternative mass-based presumptively approvable emission limits.
- Examine how environmental justice communities would be harmed by a rule that increases electricity prices and reduces the reliability of electricity.
APPA’s full comments are available upon request. Contact [email protected].