Document 3Jx3eDag6ekYOo0RDrZqkdd8J

ULSIEGILO2see##241-1280 Diaootrretant206638@3 FFfildc1006/2Y22024 PRigge459 of @28 permitting, siting, procurement, and construction. It is also the type of project that will engender protracted challenges. It is highly improbable such a project can be accomplished by the Final Rule's deadline. 28. The provision allowing for a one-year extension in the compliance deadline where the delay is needed to compete installation of controls and where the company has taken all steps necessary to otherwise meet the deadline does not make a difference. It is equally unrealistic to expect a 100-mile gas pipeline to be constructed for Colstrip by January 1, 2030, as it is unrealistic to expect it by January 1, 2031 29. For the reasons outlined above, gas-co-firing is not an option for Colstrip. Without a Stay, Talen will Suffer Immediate, Irreparable Harm 30. During the pendency of this litigation, the Talen Entities would sustain the following concrete, irreparable harms if a stay of the Final Rule is not granted: a. The costs to immediately begin designing, constructing, and permitting a gas pipeline for the ability to co-fire gas at Colstrip and to retrofit the units to provide for co-firing with gas; or b. The costs to retrofit Colstrip with CCS, to begin construction of a pipeline to transport CO, for sequestration, and to evaluate and develop an acceptable site for sequestration. 31. Talen personnel would immediately begin to dedicate substantial time, attention, and resources to tasks associated with evaluating, designing, and financing such projects, which would divert attention from other important duties. 9 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000309-00059 SC_EVERSPLIT0006222