Document 8R6p0a4ebx200pyEDEGYxbz9K

electric markets, which in the case of the PJM Regional Transmission Organization (PJM) is being manipulated by an agreement between the Governor of Pennsylvania and the PJM to impede the ability for electric generating sources to recover these costs that would be obligated by the revised MATS regulation. Importantly, President Trump has identified that it is beyond dispute that a reliable and cost-effective electric grid is critical to the national security of the United States. Considering the substantial and unexpected increase in electricity demand growth, keeping the plant online will help to meet this national security objective. However, the issues relating to the ability of merchant generators to recover the costs that would be necessary to continuously achieve the revised FPM limit using the specified FPM CEMS to demonstrate compliance implicates the economic viability of Bay Shore Unit 1 and other merchant generators in a number of states with restructured electric generation threatening the reliability of various electric grids. It is also noteworthy that PJM and the Midcontinent Independent System Operator (MISO) have highlighted several EPA regulatory processes that it believes have forced the early retirements of electric generating sources and impaired their viability at such an accelerated rate that there may not be adequate generating resources to serve future system demand. System reliability and resilience requirements are only exacerbated by the coming wave of new data centers which have high electricity demands. Regulations such as the new MATS Rule only serve to call the system wide reliability and resilience further into question. Olympus appreciates the opportunity to make this request for a Presidential two-year exemption from the revised MATS rule FPM emissions standard for Bay Shore Unit 1. If there are any questions or additional information is required, please contact Vincent Brisini at vbrisini@olympuspower.com or Cody Magaan @cmagaan@bayshore-opo.com. Respectfully submitted, Vincent J. Bri'in)i Director of Environmental Affairs cc: Sean P. Lane, Olympus Power, LLC Todd Shirley, Olympus Power, LLC Shawn Smith, Olympus Power, LLC Frederick Kramer, Walleye Power, LLC -- Bay Shore Cody Magaan, Walleye Power, LLC -- Bay Shore Page 3 of 3 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000255-00003 SC_EVERSPLIT0006046