Kentucky Energy and Environment Cabinet Submits Comments on Proposed Standards for Greenhouse Gas Emissions from New Fossil Fuel-Fired Power Plants
By Kelly D. Bartley, Attorney, Bingham Greenebaum Doll LLP
On April 22, 2014, the Kentucky Energy and Environment Cabinet (EEC) submitted written comments regarding EPA’s proposed Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Generating Units as published in the Jan. 8, 2014 Federal Register.
The EEC commended EPA for addressing several of the issues raised in its previous comments submitted in June 2012 regarding the previously proposed rule but expressed continued concern that “this iteration of rulemaking continues to jeopardize our state’s economy and future prosperity” by “establishing an unreasonable and unattainable emission limit for coal combustion.” In this regard, the EEC requested that EPA consider a limit of 1,700 lbsCO2 /MWh rather than the proposed range of 1,000 to 1,200 lbsCO2/MWh as the limit for coal-fired boilers. The EEC submitted that a 1,700 lbsCO2/MWh would accomplish nearly 20 percent CO2 emission reductions and is the standard being achieved by only the cleanest and most recently commissioned coal-fired units in the nation.
Consistent with previous comments, the EEC also reiterated its concern with increasing reliance on natural gas for electricity production, arguing that “substitution of natural gas for coal is not a long-term solution for climate change and potentially results in disastrous short-term consequences of decreasing state gross domestic product, rising unemployment, dramatically fluctuating prices that negatively impact consumers, increasing security risks and decreasing the standard of living for many Kentuckians.” The EEC’s complete comments can be found at www.regulations.gov at EPA Docket ID No. EPA-HQ-OAR-2013-0495.