The American Public Power Association on Oct. 15 submitted comments to the Environmental Protection Agency in response to questions that EPA posed during its federalism consultation regarding the pending rules to regulate emissions from stationary combustion turbines.
The forthcoming CT Rules include proposed new source performance standards for stationary combustion turbines, a proposed reconsideration of the national emissions standards for hazardous air pollutants for stationary combustion turbines, and proposed emissions guidelines for greenhouse gas emissions from existing stationary combustion turbines.
The CT Rules, which are expected to be issued in Fall 2024 and January 2025, will have major implications for public power utilities that own and operate stationary combustion turbines.
As such, APPA’s comments made a series of recommendations in its comments.
Specifically, APPA urged EPA to develop a suite of CT Rules that are both flexible and tailored so that electric reliability is not hampered.
APPA also recommended that EPA meaningfully engage with regional grid operators during the development of the CT Rules as their feedback is essential to understanding the resource and reliability challenges and interconnection timelines.
In addition, APPA reiterated its position that greenhouse gas emissions performance standards for existing stationary combustion turbines should not be based on carbon capture and sequestration nor hydrogen co-firing as these are emerging technologies and cannot be considered the best systems of emission reduction.
APPA also said it supports evaluating BSER at the individual regulated source as certain efficiency improvements may be more appropriate as BSER for certain facilities.
The public power group suggested that EPA develop subcategories tailored to the diverse CT fleet, paired with flexible implementation options for state plans.
Also, APPA recommended that EPA provide clear guidance on how states should conduct a remaining useful life and other factors analysis in state plans and said it believes it would be premature for EPA to establish emission limits for trace metals from CTs.
