Document 6wLEqEk1k2JE4V65z11QpN5j1

NorthWestern Energy Delivering a Bright Future Consequently, NorthWestern respectfully urges EPA to use its discretion under thc Clean Air Act and LO.s 13990 and 12898 to take thc following actions: (1). Withdraw thc Proposed Rule, revisiting the subject closer to thc eight ycar timeframc provided in Clean Air Act Section 1 12(d)(6), or earlier if and when actual technological advancements occurring since the 2020 RTR satisfy the conditions for revisitation of standards set forth in Section 112(d)(6); (2). If the Proposed Rule is not withdrawn, create a source subcategory that exempts those facilities presently employing wet scrubber technology without ESP or fabric filter add-ons until the next RTR; and/or (3). Create a retirement subcategory allowing units to continue to meet the existing 0.03 lb/MMF3tu fPM standard so long as thcy opt-in to the rctircmcnt subcategory within 18 months after finalization of the rule, with a rctircmcnt date no later than December 31, 2035 (and where continued operation after 2035 would later be permitted if (i) the unit is essential to maintain regional grid reliability, as determined by the Western Regional Adequacy Program, Regional Transmission Organizations, Independent System Operators, North American Electric Reliability Corporation, or other similar system reliability authorities; or (ii) or if EPA determines that additional time is required to allow the unit to transition to renewable or clean energy generation). The foregoing courses of action are the only options that comply with the statutory requirements of the Clean Air and Administrative Procedure Acts, and are consistent with the objectives of E.O.s 13990 and 12898. 2. NorthWestern's commitment to environmental and climate revonsihilitv NorthWestern is a strong proponent of environmental protection, consistent with its responsibilities to deliver reliable, cost-efficient electrical service to its customers. To that end, NorthWestern has a corporate objective to achieve net zero emissions by 2050 ("Net Zero 2050"). A copy is attached as Exhibit A. NorthWestern already has one of the highest percentages of carbon-free generation in the United States, and has significant additional carbon and other emissions-reducing projects in development. Although NorthWestern disagrees strongly with the Proposed Rule, this should not be confused with opposition to environmental protection or thc objectives of LO. 13990. 4 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000308- 00005 SC_EVERSPLIT0006142