Document Ddm3k0nrrGeJwJNbegaoDqBQO

March )8, 2025 Page 3 because (I) granting the exemptions will protect vital national security interests: and (II) the technology necessary to implement the 2024 MATS is not "a\ ailable." I. Granting Presidential Exemptions for Basin Electric's Affected EGUs Will Protect America's National Security interests. As President Trump recognized in his January 20, 2025 Executive Order "Declaring a National Energy Emergency." "our Nation's inadequate energy supply and infrastructure" is an la]ctive threat to the American people."' The Executive Order tbrther emphasizes that an "affordable and reliable domestic supply of energy is a fundamental requirement for the national and economic security of any nation" and highlights the need to "protect the United Statcs's economic and national security and military preparedness by ensuring that an abundant supply of reliable energy is readily accessible in every State and territory of the Nation."' Achieving compliance with the stringent standards under the 2024 MATS Rule at Basin Electric's affected EGUs will exacerbate the National Energy Emergency and generate significant national security risks. If Basin Electric's affected EGUs do not receive Presidential Exemptions, they may he forced to significantly curtail operational capacity because the technology necessary to comply with these requirements is not available and not feasible to implement by the 2027 deadline. as discussed further below. Such curtailments would result in the removal of up to 3,665 MW from the electricity grids that these EGUs serve. at a time when the supply of electricity is already inadequate and demand is only. increasing. Additionally, as the Class of `85 Letter will further highlight, the short compliance deadline prevents Basin Electric and other electricity producers from constructing sources to replace such significant losses of electricity production. This gill directly threaten the reliability of these electricity grids. Not only will there he significantly less electric power available on such grids, hut the loss of this power will also cause serious transmission issues. As Basin Electric's affected EGI.Ts currently provide essential voltage support and inertia to local and regional sections of the electricity grids that they serve, curtailment of their operations will risk voltage collapse in these areas. To protect these areas, significant investment to upgrade the existing transmission infrastructure and to potentially construct new transmission lines and facilities will be necessary. As a result, compliance with the 2024 MATS will inflate the already high energy costs for the rural Americans that depend upon the electricity that Basin Electric provides.' Indeed, regional transmission organizations and independent system operators ha`.e already issued warnings about the adequacy of generation resources to meet peak demand situations. For instance. in a February 2024 report. the Midcontinent Independent System Operator ("M1S0") emphasized that "[w]idesprcad retirements of dispatchable resources, lower reserve Executive Order 14156, Declaring rd .N-cnional Energy Emergency. 90 Fcd. Reg. 8.433 (Jan. 29. 2025). Id. /d. at 4. 3 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000312-00003 SC_EVERSPLIT0006288