Document 6Bvo31pDvrdkJB4dbLvdd9Ndd

EPA originally finalized the RTR for MATS on May 22, 2020 (the 2020 MATS RTR).' In that rulcmaking, EPA determined that the residual risks from coal-fired and oil-fireci EGUs were acceptable and did not identify any new technologies to control HAPs for these units. EPA finalized the RTR without any changes to emissions standards or work practices. When President Bidcn took office, he ciirecteci EPA to reconsider the 2020 MATS RTR. On May 7, 2024, EPA published the final MATS RTR. The MATS RTR lowers the PM emission standard from 0.030 lb/MMBtu to 0.010 lb/MMBtu. The Rule also tightens the standard for emissions ofmercury from lignite-fireci EGUs from 4.0 lb/TBtu to 1.2 lb/TBtu. The MATS RTR also requires that existing coal-fireci ECUs use PM CEMS to demonstrate compliance with the PM emission standard, eliminating the stack testing option. The LEE status option for PM, total non-Hg HAP metals, and individual non-11g HAP metals for coal-fired and solid-oil derived fuel-fired EGUs has also been removed. The compliance deadline for both of these requirements is July 6, 2027. On March 12, 2025, the Trump Administration announced its intention to reconsider the MATS RTR. In a fact sheet released that day, EPA cited concerns regarding the Rule. EPA stated that the Rule may be inconsistent with the authority granted under CAA and will require large estimated costs to comply given that industry has already successfully reduced emissions of mercury and other I IAPs. Otter Tail supports EPA's decision to reconsider the MATS RTR for the reasons identified in our comments in the MATS RTR docket. 2. The Presidential Exemption CAA 112(i) sets a schedule for compliance. In Section 1 12(i)(4), Congress provided the President with executive discretion to exempt a stationary source from compliance with standards and limitations provided under Section 112. The President may exempt any stationary source from compliance with any standard or limitation under this section for a period of not more than 2 years if the President determines that the technology to implement such standard is not available and that it is in the national security interests of the United States to do so. An exemption under this paragraph may be extended for 1 or more additional periods, each period not to exceed 2 years. The President shall report to Congress with respect to each exemption (or extension thereof) made under this paragraph. The President's discretion may be exercised upon satisfying a showing that (1) the technology is not available for implementing the standard, and (2) the national security interests of the United States warrant the President's exercise of the discretion. 85 Fed Reg 31286 (\lay 22, 202(1) EPA, Mercury and lor ionus Siandards (:1111:5') . Powering ohe (irea! imerocom Comeback Faco Sheei, (Mar 12, 2(125), https 'wv.rv.r.eria goy, system 'files, doeurnents 2025-03 fact-sheet-reconsideration-of-mcreurv-and-air-toxies- standards.pdf nor Iilil PoH or Company Conuneons on Va I.: R eon .51aoulfuyis for 11(12- f(pylons Air Potluiruds roctl- and 01 !red I leciriu Ufilily Steam Genc.rulimg UmIc Rerunt qf the Resiclurd Risk urrrl Fouhnology Rcuie" ; Propo.scrl Rule, Docket No. EPA-I IQ-OA R-2018-07')4-5L)75 (June 23, 2(123), https:1downloads regulations.gov:EPA-I IQ- OA R-2018-0794-5975/attachment 1.pdf (Otter 1 ail Comments). 3 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000194-00003 SC_EVERSPLIT0005966