On June 21, 2022, NRECA filed comments on EPA's proposed “Transport Rule" that would require deep nitrogen oxide (NOx) reductions from power plants in 25 states under the auspices of meeting Clean Air Act “good neighbor" obligations for ozone pollution. NRECA has estimated that the proposed rule's overly-stringent standards, limitations on emissions trading programs, and extremely short compliance timelines could result in the loss of 42 gigawatts of coal-fired generation by 2026. In light of these impacts, NRECA has expressed serious concerns about the substantial impact this proposed rule would have on electric reliability and affordability. These concerns were echoed in comments filed by various regional transmission organizations and independent system operators.