Edison Electric Institute filed 2 comments on this docket between Jun 30, 2020 and Apr 5, 2023. 245 other organizations filed here. The comment window closed 1218d ago.
The Edison Electric Institute (EEI) appreciates the opportunity to comment on EPA's Proposed Reconsideration of the National Ambient Air Quality Standards for Particulate Matter.
Dear Dr. Jenkins: The Edison Electric Institute (EEI) appreciates this opportunity to submit comments on the rulemaking Review of the National Ambient Air Quality Standards For Particulate Matter proposed by the U.S. Environmental Protection Agency (EPA or Agency). 85 Fed. Reg. 24,094 (Apr. 30, 2020) (Proposed Rule or Proposal). EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for about 220 million Americans and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than seven million jobs in communities across the United States. EEI member companies invest more than $100 billion dollars annually to make the energy grid smarter, cleaner, more dynamic, more flexible, and more secure in order to provide affordable and reliable electricity to customers The power sector has been successful in reducing particulate matter (PM2.5) and precursor air pollutant emissions, and the increasingly clean power generation from the sector can play a large role in reducing emissions from other sectors through beneficial electrification of the transportation and industrial sectors. EEI members are investing heavily to make the energy grid smarter, cleaner, more dynamic, more flexible, and more secure while continuing affordable and reliable serviceand the electric power industry's progress has been successful in reducing air emissions and improved air quality. EEI members maintain a balanced mix of resources while transitioning to an increasingly cleaner grid as evidenced by reducing key air emissions by approximately 90 percent since 1990. The industry has also reduced its carbon emissions by one-third since 2005, exceeding the Clean Power Plan reduction targets more than a decade early. Today almost 40 percent of all U.S. power generation comes from carbon-free sourcesa fourfold increase from 2005. EEI's member companies collectively are on a path to reduce carbon emissions 50 percent by 2030, and these reductions also come with concomitant criteria pollutant reductions. Relevant to this rulemaking, electric power sector emissions of sulfur dioxide (SO2) and nitrogen oxide (NOx) are down 94 and 86 percent, respectively, over the period 1990 to 2019. The power sector can help to further reduce PM2.5 and other criteria pollutant PM2.5 precursor emissions by supporting transportation electrification, leveraging increasingly clean power generation to reduce transportation sector emissions. EEI urges EPAas the Agency looks forward to implementing the PM2.5 NAAQSto provide the states and industry with significant regulatory flexibility to allow for states and sources to leverage these advances. Please contact Alex Bond (abond@eei.org, 202-508-5523) or John Kinsman (jkinsman@eei.org, 202-508-5711) with any questions.
Based on EPA’s reconsideration of the air quality criteria and the NAAQS for particulate matter (PM), the EPA proposes to revise the primary annual PM2.5 standard by lowering the level. The Agency proposes to retain the current primary 24-hour PM2.5 standard and the primary 24-hour PM10 standard. The Agency also proposes not to change the secondary 24-hour PM2.5 standard, secondary annual PM2.5 standard, and secondary 24-hour PM10 standard at this time. The EPA also proposes revisions to other key aspects related to the PM NAAQS, including revisions to the Air Quality Index and monitoring requirements for PM NAAQS.
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