Document Bv7jzDNrQ93DxOvKB7jKkqYqX

Dynegy Midwest Generation, I,I,C March 31, 2025 Submitted via email to airaction(depa.zov President Donald J. Trump cio Administrator nee M. Zeldin Office of the Administrator (1101A) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, I.C. 20460 Dynegy Midwest Generation, I,I,C Baldwin Power Plant 10901 Baldwin Road Baldwin, IL 62217 Re: Presidential Exemption: National Emission Standardsfor Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Fed. Reg. 38,508 (May 7, 2024): Baldwin Posner Plant Units 1 & 2. Dear President Trump: Please accept this letter on behalf of Dynegy Midwest Generation, I.I.C requesting a Presidential exemption under Section 1 12(i)(4) of the Clean Air Act ("CAA") from compliance with the filterable particulate matter (11)M") surrogate emission standard for non-mercury metal hazardous air pollutants ("HAP") and the requirement to install continuous emissions monitoring systems ("CEMS" or "PM CEMS") under the above-referenced rule (the "MATS RTR" or the "Rule") for Baldwin Power Plant Units 1 and 2 ("Baldwin"). Dynegy Midwest Generation, LI,C is requesting a two-year exemption, beginning July 6, 2027, from these requirements for the Baldwin facility. The MATS RTR amended 40 C.F.R. Part 63 Subpart UUUUU and became effective on July 8, 2024. Under the Rule, Baldwin's electric generating units ("EGUs") are required to reduce fPM emissions from 0.030 lb/MMBtu to 0.010 lb/MMBtu. Compliance is based on a continuous, 30-day rolling limit. In addition, the Rulc requires all coal-fired EGUs to install costly CEMS to implement the revised [PM standard, rather than allowing EGUs to continue to use stack testing to demonstrate compliance. The compliance deadline for meeting the revised fPM standard and for installing and using fPM CEMS is July 6, 2027, but work to design, purchase, install, and/or test any necessary controls or changes to operating procedures, as well as install new CEMS would need to begin much sooner. Under Section 112(i)(4) of the Clean Air Act. the President may issue exemptions from compliance with any standard or limitation under this section for a period of not more than 2 vcars 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." 42 L.S.C. 7412(i)(4). Accordingly. the President is authorized to exercise his discretion to exempt Baldwin Units 1 & 2 from complying with the MATS RTR where (1) the technology required "to implement" the standard is not available and (2) where it is in the interest of national security. In light of this authority, and in light of the burden imposed on 1 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000174-00001 SC_EVERSPLIT0005952