Document 2JR9L5vZwdLbKQkm228GZjvjN

USCA Case #24-1190 Document #2062093 Filed: 06/27/2024 Page 24 of 92 54. Additionally, litigating the MATS Final Rule in a normal course would likely take a minimum of two to three years. Talen Montana and the Colstrip owners must make immediate and consequential decisions about Colstrip's future, with ramifications for Talen Montana, Colstrip, the State of Montana, its citizens, and beyond. These decisions must be made in the face of significant uncertainty over the Final MATS Rule (and the GHG Rule) given ongoing litigation. As described above, this decision uncertainty inflicts immediate significant harm on Talen Montana. If the MATS Final Rule is not stayed, yet is ultimately reversed on appeal, Talen Montana will have suffered the irreversible harm of either closing the plant prematurely or spending its share of hundreds of millions of dollars on unnecessary controls, by the time the legality of the MATS Final Rule is determined. The consequences of early closure of Colstrip on Montana and its local economy are severe. 55. Early closure of Colstrip would cause significant economic harms to the local area and Montana. 56. Colstrip is pivotal to Montana. Colstrip is a primary source of safe, reliable electricity for Montanans and provides significant economic benefits in the form of direct and indirect jobs, tax revenue, and economic development. The impact of the MATS Final Rule, should it result in the premature closure of Colstrip, will extend well beyond the plant, the Rosebud mine, and the local community. 23 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000309-00024 SC_EVERSPLIT0006187