NRECA is asking the Environmental Protection Agency to consider reliability of the electric grid as well as the significant investment by electric cooperatives in control technologies before setting new limits on mercury emissions and filterable particulate matter from coal-fired power plants.
“Co-ops would have to invest millions of dollars more in retrofits to comply with this proposal or retire units prematurely, leaving the nation short on available baseload generating resources when energy demand is escalating," said Rae Cronmiller, NRECA environmental counsel.
“With electric reliability at stake, we encourage EPA to withdraw this proposed rule and reconsider its impact to the electric grid."
EPA proposed the new Mercury and Air Toxics Standards for power plants on April 23 and is expected to issue a final rule in 2024.
In recent comments filed with EPA, NRECA outlined several specific reasons for the agency to rethink its proposal, which would update 2012 standards for mercury and fPM from coal and oil-fired generation. They include:
- The proposed mercury standard on lignite coal-based units from 4 pounds per trillion British thermal units (lbs/TBtu) to 1.2 lbs/TBtu is technically unachievable.
- The proposed fPM standard of 0.01 pounds per million British thermal units significantly underestimates the feasibility and cost of compliance.
- A requirement that only continuous emissions monitoring systems can be used to verify fPM is technically unworkable and significantly more expensive than existing testing options.
- Since EPA has found that implementation of the 2012 rule has reduced health risks from mercury and fPM to levels acceptable when compared to other industrial source categories, further regulation is not necessary.
“To date, fPM emissions regulated under the 2012 rule have declined more than 80% and mercury emissions more than 94%," said Cronmiller. “This notable progress must be considered by EPA in drafting an update. Instead of giving credit where credit is due, this proposed rule would lead to a costly mandate with no appreciable health benefits and the premature retirement of dependable coal-fired units that underpin reliable electricity.
“NRECA will continue to advocate for flexibilities that ensure these plants can continue to be used to provide reliable and affordable electricity."