East Kentucky Power Cooperative is a generation and transmission co-op that provides electricity to 16 co-ops. Together, these co-ops provide energy to 520,000 homes, farms and businesses across 87 Kentucky counties. The communities served include some of the poorest rural areas in the nation. Nearly half of the counties served by EKPC face persistent poverty. Most of these families rely on electricity for water heating and to heat their homes.

EKPC generates more than half of its electricity from power plants that would be affected by the Environmental Protection Agency's power plant rule. If the rule goes into effect, the communities that rely on EKPC are likely to find themselves with less reliable power or without the means to pay for it, or both.

Deploying carbon capture and storage technology would cost the co-op an estimated $10.7 billion for all four units at its Spurlock plant. Assuming that EKPC could finance a project of this size—an impossibility even with tax credits—residential electricity rates would rise between 67% and 96%. This increase would be especially hard on the poorest consumers that EKPC serves. This estimate does not include the cost to install CCS at the co-op's Cooper plant. Further complicating matters, carbon dioxide storage is not geologically possible at scale in Kentucky.

Co-firing natural gas at its plants would require the construction of a natural gas pipeline at a cost of $500 million. Construction would need to begin immediately, and there is no guarantee that a pipeline would be approved or completed in time.

That leaves building new generation or buying power from the market. The EPA's power plant rule limits how much a new gas power plant could run. As a result, EKPC would need to build two natural gas power plants to generate the same amount of electricity that one natural gas plant can produce, doubling the project's scope with no net reduction in emissions.

Had EKPC not had use of its power plants and been forced to buy all of its power on the open market during Winter Storm Elliott on Dec. 23-24, 2022, the total cost of just those two days of extreme cold would have been over $74.5 million.

Kentucky has already experienced rolling blackouts during peak winter conditions. Closing always-available power plants is likely to further strain the ability of grid operators to keep the lights on. A grid failure would damage EKPC, its members, the economy and public health.

An additional complication: Kentucky law prohibits a utility from shutting down a power plant without the approval of the Kentucky Public Service Commission. There is no guarantee that the commission would allow EKPC to retire its plants. This could put EKPC in the position of being unable to comply with the power plant rule while also being unable to avoid violating the rule by retiring plants that can't be brought into compliance.