Document MMNoBLp0avYj5L3zoyoVORGqx

Kincaid Generation, I,I,C March 31, 2025 Submitted via email to airaction(alepa.gov President Donald J. Trump c/o Administrator Lee M. Zeldin Office of the Administrator (1101A) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, V.W. Washington, D.C. 20460 Kincaid Ciencration, LLC Kincaid Power Plant 199 Illinois Route 104 Kincaid, IL 62540 Re: Presidential Exemption: National Emission Standardsfor Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technolo;y Review, 89 Fed. Reg. 38,508 (May 7, 2024): Kincaid Power Plant Units l & 2. Dear President Trump: Please accept this letter on behalf of Kincaid Generation, LLC requesting a Presidential exemption under Section 1 12(i)(4) of the Clean Air Act ("CAA") from compliance with the filterable particulate matter ("fPM") surrogate emission standard for non-mercury metal ha7ardous air pollutants ("I lAP") and the requirement to install continuous emissions monitoring systems ("CEMS" or "PM CEMS") under the above-referenced rule (the "MATS R-I- R" or the "Rule") for Kincaid Power Plant Units 1 and 2 ("Kincaid"). Kincaid Generation, LLC is requesting a two-year exemption, beginning July 6, 2027, from these requirements for the Kincaid facility. The MATS RTR amended 40 C.F.R. Part 63 Subpart UUUUU and became effective on July 8, 2024. Under the Rule, Kincaid's electric generating units ("EGUs") arc required to reduce IPM emissions from 0.030 lb/MMBtu to 0.010 lb/MMI3tu. Compliance is based on a continuous, 30-day rolling limit. In addition, the Rule requires all coal-fired EGUs to install CEMS to implement the revised fPM 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 IPM CEMS is July 6, 2027, but work to design, purchase, and install the necessary controls and the 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 years 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 U.S.C. 7412(i)(4). Accordingly, the President is authori7ed to exercise his discretion to exempt these units from complying with the MATS R-I-R 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 electric 1 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000161-00001 SC_EVERSPLIT0005930