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Product Abstract

Comments of the Electric Power Research Institute On EPA’s Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units [CAA § 111 (d)]

Product ID:3002004658
Date Published:20-Oct-2014
Sector Name:Environment
Document Type:Technical Results
Price:No Charge

This Product is publicly available

   1.04 MB - Adobe PDF (.pdf)


In June of 2014 the U.S. Environmental Protection Agency issued a proposed rule under the Clean Air Act Section 111 (d) titled “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units”. This report contains comments from the Electric Power Research Institute (EPRI) submitted to the federal regulations docket # EPA-HQ-OAR-2013-0602. EPRI comments focus principally on three areas of assessment: (i) technical engineering assessment; (ii) economic assessment and analyses; and (iii) power sector system assessment. All comments reflect only EPRI’s opinion and expertise and do not necessarily reflect the opinions of those supporting and working with EPRI to conduct collaborative research and development. EPRI comments are organized into five areas that parallel the proposed rule’s structure.

  1. Definition of Best System of Emissions Reduction (BSER) and the building blocks;
  2. State Goals;
  3. State Plans;
  4. Impacts of proposed rule, including a technical assessment of the Regulatory Impact Analysis (RIA); and
  5. Benefits of the proposed rule.
2014 Program 102   Energy and Climate Policy Analysis
  • CO2 regulation
  • CAA Sec. 111 (d) Comments
  • Energy & Climate program

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