Document 7R6r4RmJzqajJO9wBDJx65bXE

IIl. It is in the Interest of National Security to Issue an Exemption for the Rule The requested exemptions from the MATS RTR are in the national security interests of the United States. The Rule adversely affects the nation's energy generation capacity and threatens grid stability and the supply of affordable, reliable energy. The Rule's stringent limits and the high costs associated with compliance, particularly in combination with other rulemakings impacting coal-fired FGUs, place a considerable burden on the operation of the Baldwin Units. And MATS rules have historically resulted in the loss of generation capabilities--the 2012 MATS rule resulted in the retirement of approximately 60,000 MW of coal-fired capacity. ?errs' Brief at 23. As explained in Luminant's Comments. coal plants "continue to be of paramount importance for grid reliability during the transition to renewables." M. at 29. The President has identified energy generation and grid reliability to be issues of national security and it is, therefore, in the interest of the nation to exempt these units from compliance with the MA FS RTR. As set forth in President Trump's Executive Order ("E.O.") 14156, Declaring a National Energy Etnergency, the "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." 90 Fed. Reg. 8,433, 8,433 (Jan. 29, 2025). The E.O. continues, "integrity . . . of our Nation's energy infrastructure from coast to coast is an immediate and pressing priority for the protection of the United States' national and economic security," while "insufficient energy production . . . constitutes an unusual and extraordinary threat to our Nation's economy, national security, and foreign policy." Id. at 8,433-34. As explained above, the MATS RTR is one of the "policies" that the President has indicated will contribute to the "inadequate and intermittent energy supply" and "increasingly unreliable grid." Id. at 8,433. Similarly, in E.O. 14154, l.'nleashing American Energy, President Trump acknowledged that prior regulations which include this Rule have "limited the generation of reliable and affordable electricity" and, in turn, "weaken[ed] our national security." 90 Fed. Reg. 8,353, 8,353 (Jan. 29, 2025). This F.O. plainly states it is in "the national interest to unleash America's affordable and reliable energy" and that ensuring "an abundant supply of reliable energy" will help "protect the United States's economic and national security and military preparedness." M. Providing the requested exemptions will achieve these goals of ensuring national security through the supply of reliable energy. Moreover, E.O. 14154 specifically calls for the review and potential rescission of rules like this one, which "impose an unburden on the .. . use of domestic energy resources." Id. at 8,354. Thus, in order to ensure a sufficient and reliable supply of energy, President Trump should use his lawful authority under Section 112(i)(4) of the CAA to grant the requested exemptions from compliance with the standards set forth in the MATS RTR. If you have any questions regarding this submittal, please contact Jim Ross at Jim.Rossgvistracorp.com. Sincerely, Cynthia Vodopivec Senior Vice President, Environmental Health and Safety 4 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000174-00004 SC_EVERSPLIT0005955