Document Jr4maD785my3q36drnYmRG4jK

TALEN 1:11 MONTANA [A] decline in population which occurs as works and families migrate to other economic opportunities, growing to more than 7,000 people by year 2043."' Colstrip also is vital to ensuring that Montanans have affordable and reliability electricity, especially during peak winter and summer months. Colstrip is one of Montana's most important energy assets, especially as demand for reliable bascload power in the western U.S. continues to grow. As Montana state Governor Gianforte has recognized, Montana needs Colstrip.' Thus, EPA's proposal to make the fPM limit more stringent, as well as require CEMS to demonstrate compliance with that limit, has far-reaching ramifications given Colstrip's unique design and circumstances. Ialcn Montana strongly recommends that EPA reconsider its proposed amendments or to provide the relief requested by Talen Montana herein. III. COMMENTS Ialcn Montana understands that EPA conducted the MATS Residual Risk and Technology Review ("RTR") pursuant to President Bich:1's Executive Order 13990.1 The order required EPA to review certain actions undertaken by the prior administration, including the MATS RTR finalized in May 2020. The 2020 MATS RTR indicated that I1AP emissions from the source category are acceptable and also did not identify any cost-effective controls that would achieve further HAP emission reciuctions.9 While EPA acknowledges in the Proposal that the 2020 Residual Risk Review was sound and is not proposing to modify it, EPA is proposing to determine that the 2020 Technology Review was flawed because it "did not consider developments in the cost and effectiveness of . . . proven technologies, nor did EPA evaluate the current performance of emission reduction control equipment and strategics at existing MATS-affected EGlis."1() Following the consideration of such factors, EPA is proposing that the updated technology review requires certain changes to MATS.[ 1 These changes include the fPM limit and the use of PM CEMS.' 2 Barkey, Patrick M. "The Economic Impact of the Early Retirement of Co'strip Units 3 and 4 Final Report." June 2018 at 6. "Governor Gianforte: 'Montana Needs Co'strip,'" State of Montana Neu sroom, Jan. 17. 2023, httris - news.mtgov1Governors-Office1Governor Gianfortc Montana Needs Colstrip. 88 Fcd Rcg at 24,856. 'See National Emission Standards for IIa7ardous Air Pollutants: Coal- and Oil-Fired Electric Utility Stearn Generating Units-Reconsideration of Supplemental Finding and Residual Risk and Technology Review, 85 Fed. Reg. 31,286 (May 22, 2020) See id. 88 Fcd Reg at 24,865 See id at 24,856 12 See id at 24,857-58 7 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000307-00008 SC_EVERSPLIT0006104