Date: December 19, 2023
Venue: Environmental Protection Agency
EPSA submitted comments to the Environmental Protection Agency offering feedback from power generation owners on the agency’s November 20, 2023 Supplemental Notice of Proposed Rulemaking (NOPR) to its initial proposed rule further reducing carbon emissions by natural gas and coal generators. EPSA reiterated that the proposal would negatively impact overall grid reliability by establishing compliance timelines and requirements that are likely to lead to premature retirements or reduction of output from a significant number of thermal power plants. EPSA also responds to issues highlighted in the Supplemental NOPR that the unrealistic compliance regime acting as the keystone of the underlying NOPR affects generators in a myriad of communities and operating in all types of economic environments.