Document J3ox5BgODox2Xn47NpbgOG2Rv

To: Jackson, Ryan[jackson.ryan@epa.gov] From: Paul Bailey Sent: Fri 8/18/2017 11:31:01 AM Subject: CCR letter attached EPA CCR Letter August 16.pdf Paul Bailey President & CEO American Coalition for Clean Coal Electricity T: 202.459.4818 | M: 703.586.2422 pbailey@amencaspower.org 17cv1906 Sierra Club v. EPA ED_001523_00000565-00001 \((( I AMERICA'S POWER August 16 ,2017 Mr. E. Scott Pruitt Administrator United States Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Dear Administrator Pruitt: We are writing to urge that the United States Environmental Protection Agency ("EPA")take immediate steps to postpone the compliance deadlines under the Coal Combustion Residuals ("CCR") rule. Although EPA has just issued guidance to the states on implem entation of the CCR rule, the guidance does nothing to avoid the additional coal plant retirements that will result from this rule over the next few years. An estimated sixt y percent (60%) (about 150,000 m egawatts) of the U.S. coal fleet's electric gen erating capacity relies on unlined surface impoundments and, therefore, is at risk because of the CCR rule. Many electric utilities that operate coal -fired power plants will undertake compliance steps soon that could lead to plant retirement decisions wit hin a year unless the compliance deadlines are postponed. Besides the threat of these coal -fired generating unit retirements, the required compliance steps will likely be unnecessary and wasteful for many coal plants because there are likely to be change s to the CCR Rule. These changes are expected as a result of the pending petition for reconsideration filed by the Utility Solid Waste Activities Group and the passage of the WIIN Act to authorize implementation of the CCR rule through state permit progra ms. As you know, we are very appreciative of the efforts by you and President Donald J. Trump to help the coal industry. Thank you for considering our request that the EPA postpone the CCR compliance deadlines. 1155 15th Street N W I Suite 900 I Washington, DC 20005 I 202.459.4800 I www.americaspower.org 17cv1906 Sierra Club v. EPA ED_001523_00000566-00001 Sincerely, The American Coalition for Clean Coal Electricity Robert E. Murray Chairman Paul Bailey President and CEO 1155 15th Street N W I Suite 900 I Washington, DC 20005 I 202.459.4800 I www.americaspower.org 17cv1906 Sierra Club v. EPA ED_001523_00000566-00002