Document 6R1BqVo7NYqG6mbmMOqmqdxjR

Additionally, there are high costs associated with procuring, installing, certifying, testing, and operating PM CEMS.22 Assuming that the technology would somehow be feasible to install, Otter Tail and the Co-owners have budgeted S400,000 to install PM CEMS in 2026 at Big Stone. Granting this exemption would avoid these costs if EPA were to reconsider the MATS RTR and provide relief from the PM CEMS requirement. Finally, PM CEMS must be installed and tested by vendors that are certified, and there arc only a limited number of vendors that are available. As two-thirds of coal-fired EC- is have not yet installed PM CEMS, the MATS RTR requirement will overwhelm the current supply of PM CEMS and the availability of vendors to perform the necessary work. 23 For these reasons, and because CEMS technology is unavailable at low PM levels, Big Stone should receive a twoyear exemption from compliance with the MATS RTR. IV. National Security Interests Support an Exemption Compliance with the requirements in the MATS RTR is not in the national security interest of the nation. President 'Frump's Executive Order (E.0.) 14156 declares a national energy emergency and confirms that energy generation and grid reliability arc issues of national security.'` The MATS RTR is one of the "policies of the previous administration" that will contribute to the "inadequate and intermittent energy supply" and "increasingly unreliable grid."2' Similarly, in E.O. 14154, Unleashing American Energy, President 'Frump acknowledged that the past administration's regulations which include this Rule have "limited the generation of reliable and affordable electricity" and, in turn, "weakenied1 our national security."26 The E.O. calls for the review and potential rescission of rules like this one, which "impose an unburden on the . use of domestic energy resources."21 To ensure "an abundant supply of reliable energy" that will help "protect the United States's economic and national security and military preparedness," the MATS RTR should be subject to exemption? The Rule's stringent new limits and the high costs associated with compliance, in combination with other prior rulcmakings impacting coal-fired EGLls, could force source owners to prematurely retire coal-fired ECUs before there is sufficient new dispatchable generation to replace them, seriously endangering grid reliability. Further, grid reliability is already in jeopardy in South Dakota: The North American Electric Reliability Corporation (NERC) estimates continued future resource adequacy concerns in South Dakota in both the M1S0 and .Sec PGEN Comments at 26: ,see aim) Class of '85 Cornments at 18 (estimating $180.000 to S,4110,000 for - site preparation and engineering analysis, analyzer equipment and installation costs, and initial PS-1 1 correlation testina"). `.Sc e Class of '85 Comments at 16. '.5ce 90 bed Reg 8433, 8433 (Jan 29, 2025) ("generation capacity of the United States [is] . . far too inadequate to meet our Nation's needs" and "a reliable, diversified, and affordable supply of energy" is necessary to ensure "military preparedness"). Id at 8433 90 Fed Reg 8353, 8353 (Jan 29, 2025) r Id at 8354 Id at 8353 6 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000190-00006 SC_EVERSPLIT0005961