Test Methods and Performance Specifications for Air Emission Sources

The Edison Electric Institute (EEI) appreciates the opportunity to submit these comments on the U.S. Environmental Protection Agency's (EPA or Agency) proposed rule regarding Test Methods and Performance Specifications for Air Emissions Sources. See 84 Fed. Reg. 68,069 (Dec. 13, 2019). EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for 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. EPA's efforts to clarify the requirements of Subpart KKKK are appropriate because they will ensure compliance with emissions standards. The Agency's move to align testing requirements with the original intent of Subpart KKKK by clarifying that owner/operators can utilize current, valid natural gas purchase contracts or tariffs to show compliance with the SO2 emissions standard is well supported. EEI's suggested clarification to the regulatory text is aimed at codifying EPA's stated intent. EPA's proposal, when paired with such clarification to the proposed regulatory text, would reduce unnecessary compliance costs and limit environmental impacts by limiting unnecessary sampling and testing and the related emissions. EPA should add this language to its proposed text and finalize it expeditiously.