The Honorable Gina McCarthy
Environmental Protection Agency
U.S. EPA Headquarters -- William J. Clinton Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Dear Administrator McCarthy,
We are writing to request that the Environmental Protection Agency (EPA) provide at least a 120 day comment period on the upcoming draft proposal for the regulation of greenhouse gases from existing power plants. The EPA should provide this extended comment period as soon as the proposed rule is noticed in the federal register, given the significant impact this rule could have on our nation's electricity providers and consumers, on jobs in communities that have existing coal-based power plants, and on the economy as a whole.
The upcoming proposal will be far more complex and critical for the industry to deal with than the proposal for new plants, and stakeholders will need time to analyze the rule and determine its impact on individual power plants, reliability and consumer cost, and on the electric system as a whole. This analysis will be no small undertaking, as this will be the first ever regulation of greenhouse gases from existing power plants. EPA recognized that additional time was needed and extended the original 60 day comment period for the Agency's proposal regarding new source performance standards for newly constructed power plants, so it only makes sense to provide at least the same timeline from the outset for the existing plant rule.
Affordable, reliable, and redundant sources of electricity are essential to the economic well-being of our states and the quality of life of our constituents. While we all agree that clean air is vitally important, EPA has an obligation to understand the impacts that regulations have on all segments of society. As one step toward fulfilling this obligation, we urge you to provide for a comment period of at least 120 days on the forthcoming performance standards for existing coal-based power plants.
Thank you for your consideration of this request.