On January 9, ​​NRECA submitted comments on the EPA convened small business pre-panel on new source performance standards for natural gas simple and combined cycle electric generation. EPA has not proposed any regulatory language, so the comments are generic in nature but do sound concerns regarding promulgating a rule that would jeopardize electric reliability. According to EPA, the small business panel will continue introducing specific regulatory concepts for discussion and comment. All proceedings will be entered in the rulemaking docket when there is one.  With NRECA, eleven G&T representatives are on the panel, with 3 municipals and APPA. We expect a regulatory proposal by early spring.