Statement of Large Public Power Council on EPA’s final utility MACT rule

Dec. 22, 2011 — Statement from Large Public Power Council: LPPC appreciates the efforts of EPA to address several core concerns with the proposed Utility MACT rule.  Although we are still in the early stages of reviewing the final rule, we continue to be concerned with the potential impacts of the final rule on electricity reliability.
The members of the LPPC remain concerned that electric reliability could be jeopardized unless there is an effective mechanism in place to extend the compliance deadline for those electric generating units that pose local or regional reliability problems.
EPA’s plan to address any such reliability impacts on a case-by-case basis through administrative orders is too cumbersome of a process to address wide-spread reliability problems and creates too much legal uncertainty.
LPPC stands ready to work with EPA and the Obama Administration to craft a mechanism that can quickly evaluate the cumulative reliability impacts of the MACT rule for each region and then provide a true compliance extension for those electric generating units for which an extension can be justified based on the cumulative impact analysis.
EPA appears to have made improvements to the Utility MACT requirements for limiting PM emissions and operating during startup and shutdowns.  These improvements are welcomed by the members of the LPPC.
The LPPC’s membership includes 25 of the nation’s largest publicly owned, not-for-profit energy systems.  Members are located in 11 states and provide reliable, low cost electricity to some of the largest cities in the country including Los Angeles, Seattle, Omaha, Phoenix, Sacramento, San Antonio, Jacksonville, Orlando and Austin.
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