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National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units - Additional Post-Promulgation Actions

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Dec 18, 2025
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Edison Electric Institute filings
8

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Edison Electric Institute filed 8 comments on this docket between Apr 2, 2019 and Aug 21, 2025. 129 other organizations filed here. The comment window closed 351d ago.

What Edison Electric Institute filed (8)

Aug 21, 2025· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-7733

August 8, 2025 Sarah Benish U.S. Environmental Protection Agency Sector Policies and Programs Division (D243–01) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, NC 27711 benish.sarah@epa.gov Docket No. EPA–HQ–OAR–2018–0794 [SUBMITTED ELECTRONICALLY] RE:Repeal of Amendments to National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units The Edison Electric Institute (EEI) appreciates the opportunity to submit comments to the Environmental Protection Agency (EPA or Agency) on the proposed rule Repeal of Amendments to National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, 90 Fed. Reg. 25,535 (June 17, 2025) (Proposed Rule). The Proposed Rule would repeal several revisions made as part of the 2024 final rule titled National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Fed. Reg. 38,508 (May 7, 2024) (2024 Final Rule), namely the revised filterable particulate matter (fPM) emission standard, the revised fPM emission standard compliance demonstration requirements, and the revised mercury (Hg) emission standard for lignite-fired EGUs. EEI is the association that represents all U.S. investor-owned electric companies. EEI members provide electricity for nearly 250 million Americans and operate in all 50 states and the District of Columbia. The electric power industry supports more than seven million jobs in communities across the United States. This year, EEI members will invest more than $200 billion to make the energy grid smarter, cleaner, more dynamic, more resilient, and more secure; to ensure a balanced energy mix; and to integrate new technologies that benefit both customers and the environment. Across the nation, investor-owned electric companies continue to reduce greenhouse gas (GHG) emissions while building new generation, including natural gas and clean energy resources demanded by our customers and investors. Electric companies are focused on keeping customer bills as low as possible, and this new generation is helping to meet rising demand while creating good-paying jobs and a cleaner, resilient, and affordable energy future for the communities they serve. These comments recommend EPA: •Reaffirm the 2020 Residual Risk review that found that current standards are protective of human health with an adequate margin of safety; •Continue to allow multiple proven, cost-effective compliance options for the MATS standards, including by finalizing the proposal to repeal the 2024 Final Rule requirement that allows only particulate matter continuous emissions monitoring systems (PM CEMS) to demonstrate compliance with the filterable particulate matter (fPM) standards; and •Reinstate the Low-Emitting EGU (LEE) program for units that significantly outperform the MATS fPM standards. EEI and its member companies actively engage with EPA on its entire regulatory agenda and look forward to continuing active engagement with EPA as the Agency works to finalize the Proposed Rule. Questions on these comments may be directed to Alex Bond (ABond@eei.org), William Niebling (wniebling@eei.org), and Daniel Whittle (dwhittle@eei.org). Sincerely, /Alex Bond/ Alex Bond Executive Director Legal & Clean Energy Policy

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Jun 28, 2023· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-5949

The Edison Electric Institute (EEI) appreciates the opportunity to provide the enclosed responses to the U.S. Environmental Protection Agency's (EPA) proposed rule, National Emissions Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review (RTR) (Proposed Rule), which is commonly known as the Mercury and Air Toxics Standards (MATS). 88 Fed. Reg. 24,854 (Apr. 24, 2023). EPA's Proposed Rule is of critical importance to EEI members as they continue to lead this clean energy transformation. 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 7 million jobs in communities across the United States. EEI's member companies are proud to provide America's resilient clean energy and to be leading the transformation of energy. If you have any questions or need additional information regarding EEI's comments, please feel free to reach out to me at abond@eei.org, 202-508-5523.

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Apr 13, 2022· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-5142

Filed on regulations.gov — full text not in the inline record.

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Apr 12, 2022· Comment submitted by Edison Electric Institute et al.· EPA-HQ-OAR-2018-0794-4968

Please find a joint comment letter from: The Edison Electric Institute The American Public Power Association The National Rural Electric Cooperative Association The Class of '85 Regulatory Response Group The U.S. Chamber of Commerce The Large Public Power Council The International Brotherhood of Electrical Workers The International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers & Helpers This comment replaces comment l1v-2czp-1heh, which contained an error. Apologies.

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May 13, 2020· Comment submitted by Alex Bond, Associate General Counsel, Energy & Environment, Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-4526

The Edison Electric Institute (EEI) appreciates this opportunity to submit comments on the proposed rulemaking Mercury And Air Toxics Standards For Power Plants Electronic Reporting Revisions issued by the U.S. Environmental Protection Agency (EPA or Agency). 85 Fed. Reg. 20,342 (Apr. 10, 2020). 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. Since the Mercury and Air Toxics Standards (MATS) rule became effective in 2012, it is estimated that the owners and operators of coal- and oil-based electric generating units (EGUs) have spent more than $18 billion to comply, as well as retired assets and invested in new, replacement generation. EPA data show that MATS implementation along with the industry's clean energy transition have led to significant reductions in hazardous air pollutants (HAPs) emissions, such as acid gases and mercury, and in criteria pollutants. The financial investments made to comply with MATS, the reduced emissions of HAPs, and the recent finalization of a Residual Risk and Technology Review of the standards all support continued operation of MATS-regulated EGUs and the importance of regulatory certainty and efficiency. Given the substantial reporting effort required to comply with MATS, EEI member companies have a significant interest in EPA's Proposed Rule. The Agency's permanent conversion to reporting exclusively through the Emissions Collection and Monitoring Plan System (ECMPS) provides the opportunity to streamline the reporting process, reduce administrative burdens, increase the efficiency of reporting, and can result in overall cost savings for reporting companies. The Agency should continue to work closely with all stakeholders as it fine-tunes the reporting system, including developing documentation and working on reporting software before actual reporting with the ECMPS begins. EPA also should issue a partial final rule before the end of June to extend the interim reporting process. EPA has ample authority to issue partial final rules and this is a situation where the Agency should do so to avoid expiration of the interim reporting process before a full final rule can be issued. This also will allow EPA the necessary time to both address substantive comments and technical corrections from stakeholders. EEI's comments also offer suggested adjustments to the proposed reporting requirements. Please contact Alex Bond (abond@eei.org, 202-508-5523) or John Kinsman (jkinsman@eei.org, 202-508-5711) with any questions.

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May 17, 2019· Comment submitted by Emily Sanford Fisher, General Counsel and Corporate Secretary, Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-4359

Filed on regulations.gov — full text not in the inline record.

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May 8, 2019· Comment submitted by Emily Sanford Fisher, General Counsel and Corporate Secretary, Edison Electric Institute (EEI)· EPA-HQ-OAR-2018-0794-2267

The Edison Electric Institute (EEI) appreciates the opportunity to provide the attached comments to the U.S. Environmental Protection Agency (EPA or Agency) regarding EPAs proposed rule entitled National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating UnitsReconsideration of Supplemental Finding and Residual Risk and Technology Review (Docket No. EPA-HQ-OAR-2018-0794). 84 Fed. Reg. 2,670 (Feb. 7, 2019).

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Apr 2, 2019· Comment submitted by Edison Electric Institute (EEI) et al.· EPA-HQ-OAR-2018-0794-0577

Please see the attached comments submitted by EEI, APPA, NRECA, CEG, the Class of 85, The U.S. Chamber of Commerces Global Energy Institute, the LPPC, the IBEW, the Boilermakers and LiUNA.

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Abstract

The U.S. Environmental Protection Agency is proposing to repeal specific amendments to the National Emission Standards for Hazardous Air Pollutants for Coal- and Oil-Fired Electric Utility Steam Generating Units (EGUs), commonly referred to as the Mercury and Air Toxics Standards (MATS), that were promulgated on May 7, 2024. The amendments that the EPA is proposing to repeal include the revised filterable particulate matter (fPM) emission standard, which serves as a surrogate for non-mercury hazardous air pollutant (HAP) metals for existing coal-fired EGUs; the revised fPM emission standard compliance demonstration requirements; and the revised mercury (Hg) emission standard for lignite-fired EGUs.

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Co-filers (129)

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