The National Rural Electric Cooperative Association (NRECA) and the American Public Power Association (APPA) sent a letter today to Administrator Michael S. Regan
of the U.S. Environmental Protection Agency, seeking an additional 60 days to comment on the agency’s proposal for regulating power plant carbon emissions.
The agencies stated that the proposal has sweeping implications for the power sector, is highly complex and spans hundreds of pages, warranting a thorough review and meaningful response: “The proposal has significant economic and operational implications for the electric sector. There is a substantial amount of material to review to fully understand EPA’s proposal and provide meaningful comment. The proposal includes the 181-page proposed rule, a 359-page regulatory impact analysis, and references several technical supporting documents that have yet to be posted to the rulemaking docket."
Another concern from the agencies is that the 60-day comment period is far shorter than EPA provided for similar rules in the past. “EPA has also solicited comment on dozens of various topics in the proposed rule preamble. The Associations and their members need additional time to evaluate EPA’s proposal, the supporting documents and analyses, and develop responses to EPA’s requests for comment.”
In a statement on May 11, National Rural Electric Cooperative Association (NRECA) CEO Jim Matheson said that “This proposal will further strain America’s electric grid and undermine decades of work to reliably keep the lights on across the nation,” Matheson said. “And it is just the latest instance of EPA failing to prioritize reliable electricity as a fundamental expectation of American consumers. We’re concerned the proposal could disrupt domestic energy security, force critical always available power plants into early retirement, and make new natural gas plants exceedingly difficult to permit, site, and build.
“Nine states experienced rolling blackouts last December as the demand for electricity exceeded the available supply. Those situations will become even more frequent if EPA continues to craft rules without any apparent consideration of impacts on electric grid reliability. American families and businesses rightfully expect the lights to stay on at a price they can afford. EPA needs to recognize the impact this proposal will have on the future of reliable energy before it’s too late.”
Five issues are currently impacting the reliable delivery of electricity across the nation. They include:
- Increasing demand for electricity as other sectors of the economy are electrified.
- Decreasing electricity supply due to the disorderly retirement and insufficient replacement of existing generation.
- Permitting delays that prevent new electric infrastructure from being built and connected to the grid.
- Supply chain challenges.
- Problems with natural gas availability.
Today's letter to the EPA states that there is ample precedent for providing longer comment periods. EPA provided a 120-day comment period following a 60-day extension when it first proposed New Source Performance Standards (NSPS) for fossil fuel-fired electric generating units in 2014. When EPA proposed emissions guidelines for existing sources later that year, it provided a 120-day comment period that it later extended by 45 days.
Compounding the difficulty of meeting a 60-day deadline are several concurrent open comment periods on other EPA rules with major impacts on the electric sector, according to NRECA and APPA.
