Multi-Association Comments to EPA on ANPR on State Guidelines for GHG Emissions from Existing Electric Generating Units

TO: The Honorable E. Scott Pruitt
Administrator
U.S. Environmental Protection Agency
Attention Docket ID No. EPA- HQ-OAR-2017-0545
EPA Docket Center, U.S. EPA, Mailcode: 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

RE: State Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units, Advance Notice of Proposed Rulemaking, Docket ID No. EPA–HQ–OAR–2017–0545; FRL–9972–50–OAR, 82 Fed. Reg. 61507 (Dec. 28, 2017)

Dear Administrator Pruitt:

The U.S. Chamber of Commerce, the American Chemistry Council, the American Coke and Coal Chemicals Institute, the American Forest & Paper Association, the American Iron and Steel Institute, the American Wood Council, and the Council of Industrial Boiler Owners (collectively, “the Associations”) appreciate the opportunity to comment on the U.S. Environmental Protection Agency’s (“EPA’s”) State Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units, Advance Notice of Proposed Rulemaking, Docket ID No. EPA–HQ–OAR–2017–0545; FRL–9972–50–OAR, 82 Fed. Reg. 61507 (Dec. 28, 2017) (“ANPRM”).

I. INTRODUCTION

The Associations represent the United States’ leading energy and manufacturing sectors that form the backbone of the nation’s industrial ability to grow our economy and provide jobs. The Associations support the EPA’s proposal to repeal and consider replacing its final rule regulating greenhouse gas emissions (“GHGs”) from existing electric utility generating units (“EGUs”) known as the Clean Power Plan (“CPP”). The CPP transgressed EPA’s statutory authority under the Clean Air Act, as the Agency attempted to aggressively transform the way electricity is produced and dispatched across the United States. The CPP was not only unlawful, but it would have caused significant economic disruption across the American economy...