As the Environmental Protection Agency prepares to replace current regulations targeting greenhouse gas emissions from new or renovated power plants, NRECA offered key recommendations to ensure reliable, affordable power for members.

EPA's proposed revision of the 2015 New Source Performance Standards must ensure solutions that are "reasonable and achievable nationwide" for newly constructed or modified coal-based generating units, the association stated.

NRECA also encouraged the agency to install a replacement rule that is consistent with its authority to regulate power plants under section 111(b) of the Clean Air Act.

NRECA brought its message to EPA headquarters in Washington, D.C., at a Feb. 14 public hearing on the proposed rule change.

"Cooperatives are at the forefront of efforts to reduce CO2 emissions," said Dan Chartier, NRECA's regulatory director for environmental policy. He noted that electric co-ops invest broadly in energy efficiency measures, and more than 95 percent of co-ops provide power generated from renewable sources.

NRECA took issue with the 2015 designation of carbon capture and sequestration (CCS) as the "best system of emissions reduction" (BSER) for power plants, noting that such technologies are neither fully developed nor commercially available to electricity providers. Requiring CCS on all new or modified power plants essentially halted any development of coal generation.

"CCS cannot be implemented in many areas of the country due to the lack of appropriate geologic formations to store CO2 and because the necessary CO2 pipeline infrastructure does not exist to transport CO2 among regions," Chartier told EPA.

The new EPA proposal would define BSER for large power plants as a supercritical boiler design, and for small generating units, an efficient subcritical boiler design. These high-efficiency designs result in electric generation with reduced emissions of CO2. NRECA supports both changes.

"These technologies have been commercially demonstrated in the utility industry and will meaningfully constrain the greenhouse gas emissions of new power plants," Chartier said, adding that NRECA supports continued research and development on CCS.

Industry-scale CCS testing is taking place at a 422-megawatt generation facility owned by Basin Electric Power Cooperative. NRECA and Tri-State Generation and Transmission Association, Inc. are among the major contributors to the project, known as the Wyoming Integrated Test Center.

EPA proposed revising the 2015 rule last December and is expected to finalize new source performance standards for fossil-based generation later this year.

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