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AFPM comment on proposed utility NSPS

Hydrocarbon Engineering,

The AFPM filed comments on Friday 9 May with regards to the EPA’s proposed utility NSPS for greenhouse gas (GHG) emissions from new electric utility generating units.

The new rule

The rule, which would establish new regulations designed to address GHGs from stationary sources, represents a dramatic, unprecedented and unauthorised change, according to the AFPM, and puts EPA in the position to dictate energy policy, as opposed to its intended purpose of crating environmental policy. If enacted, the AFPM believe the rule would essentially mandate the types of fuels used to electric generating units constructed in the future and will have long term negative implications for US energy and environmental policy.

Thoughts from the AFPM

Charles T. Drevna said, "the EPA is not only regulating emissions, it is now involving itself in setting an energy policy that does not support an all of the above approach to our nation’s energy needs. Mandating the use of specific energy sources will only serve to drive up US manufacturers’ costs. Our nation is on the verge of a manufacturing renaissance, but this and other all cost, little to no benefit rules will threaten our tremendous opportunity, erode our competitive advantage and drive business overseas."

The AFPM comments centre on the fact that EPA expressly ignored the intent of Congress to prohibit the Agency from considering federally funded demonstration projects from serving as the basis for any emission limitation standards of performance. When establishing a NSPS EPA is required to set performance standards that are achievable, cost effective, and based on technologies that are adequately demonstrated in practice. In this proposed rule, EPA established the performance standards on technologies that do not meet the requirements and are not feasible. Furthermore, they are not consistent with the Clean Air Act.

Drevna continued, "EPA’s reliance on projects that did not meet the minimum requirements to set standards of performance for GHG emissions from fossil fuel fired power plants is unlawful, and EPA should immediately withdraw the proposed rule."

Electricity costs are usually the second highest cost for American fuel and petrochemical manufacturers, behind the cost for crude oil and natural gas. Dramatic increases in electricity costs threaten the ability of AFPM members to produce affordable transportation fuels and chemicals that are the basis for everything from cell phones to seat belts and medicine.

Adapted from press release by Claira Lloyd.

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