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Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Primary Ozone National Ambient Air Quality Standard

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Edison Electric Institute filings
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Edison Electric Institute filed 1 comment on this docket between Jun 22, 2022 and Jun 22, 2022. 117 other organizations filed here. The comment window closed 1002d ago.

What Edison Electric Institute filed (1)

Jun 22, 2022· Comment submitted by Edison Electric Institute (EEI)· EPA-HQ-OAR-2021-0668-0332

The Edison Electric Institute (EEI) appreciates the opportunity to submit comments to the Environmental Protection Agency (EPA) on the proposed rule, Federal Implementation Plan Addressing Regional Ozone Transport Pollution for the 2015 Ozone National Ambient Air Quality Standard. 87 Fed. Reg. 20,036 (Apr. 6, 2022). EEI is the association that represents all U.S. investor-owned electric companies. EEI members provide electricity for more than 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 $120 billion 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. EEI's members are committed to getting the energy they provide as clean as they can as fast as they can, keeping affordability and reliability front and center. EEI members are well-positioned to continue to lead the nation's clean energy transformation through the deployment of new clean resources and its supporting infrastructure as they retire older coal-based and less-efficient natural gas-based generating units, along with significant investment in a broad range of affordable, carbon-free technologies and approaches. EPA should recognize the benefits of providing operational and regulatory flexibility to EEI's members in order to ensure that the clean energy transformation continues in a way that is positive for customers, positive for the economy, and equitable for the communities we serve. To that end, EEI's comments focus on four key themes that emphasize our industry's clean energy leadership: •It is appropriate for EPA to continue to utilize a trading program for the power sector. The Agency's selection of a trading program for the power sector is well founded and appropriate, as the sector has successfully implemented trading programs related to NOx emissions for decades and can continue to do so effectively, especially with several potential additional regulatory flexibilities. •Electrification can play a pivotal role in compliance. As the power sector makes tremendous strides in reducing its own emissions, EPA should leverage that progress to help other sectors reduce emissions that contribute to ozone formation, through use of clean, efficient electric energy. •The Agency should finalize a rule that requires reductions from the industrial sector. EPA is correct to include requirements for all significant contributors to interstate ozone transport. •EPA should make several beneficial implementation adjustments to the trading program to provide additional flexibility. The Agency should incorporate several additional flexibilities and adjustments to the proposed program—discussed further herein—to ensure that the trading program can both accomplish its environmental goals and successfully allow the sector to engineer compliance solutions that benefit customers and the economy. We look forward to continuing to work with EPA as it moves forward to finalizing the proposed rule.

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Abstract

This action would apply in certain states for which EPA has either disapproved a “good neighbor” state implementation plan (SIP) submission under CAA section 110(a)(2)(D)(i)(I) or has made a finding of failure to submit such a SIP submission for the 2015 ozone NAAQS. This action would determine whether and to what extent ozone-precursor emissions reductions are required to eliminate significant contribution or interference with maintenance from upwind states that are linked to air quality problems in other states for the 2015 8-hour ozone NAAQS. For states that EPA determines to be linked to a downwind nonattainment or maintenance receptor, EPA would conduct further analysis consistent with the four-step interstate transport framework to determine what (if any) additional emissions controls are required in such states and develop an enforceable program for implementation of such controls.

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Co-filers (117)

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Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Primary Ozone National Ambient Air Quality Standard (EPA) — Edison Electric Institute | OpenPolis