NRECA submitted comments to the U.S. Environmental Protection Agency (EPA) on its proposed Affordable Clean Energy (ACE) rule, which would replace the Clean Power Plan (CPP). Generally, NRECA believes the proposed ACE rule is consistent with the statutory provisions of Section 111(d) of the Clean Air Act, including limitations on EPA's authority to regulate existing coal-fired power plants. Unlike the CPP, the ACE proposal appropriately confines the requirements to what can be achieved "inside the fence line." FULL FILING
NRECA also submitted a Black & Veatch study it commissioned to analyze the ACE rule and a Sargent & Lundy report on the CPP along with its comments.