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Most importantly, based on EPA's own analysis, the reduced PM standard was not implemented for any reasons of health impact or risk', but simply because EPA determined, in the Residual Risk and Technology Review, (incorrectly we believe, at least as to the sources burning coal refuse), that the lower standard was promulgated to reflect "the control levels currently achieved by the vast majority of regulated units."2 As to the removal of the option to qualify as a LEE unit, the pending change to the regulation imposes a significant financial burden on the cleanest of the coal-fired units, removing an option for less frequent testing after showing that the emissions are significantly less than the current standard. National Security I ntcreslic; tH: SLItes As President Trump has expressed on many occasions, reliable and cost-effective energy is in the national security interest of the United States. The entire United States is facing an unprecedented surge in energy demand, driven by the rapid expansion of data centers supporting artificial intelligence, widespread electrification of vehicles and heating systems, as well as demand from the new manufacturing industries that this Administration is promoting. At the same time, the energy landscape is undergoing a major transition, with many thermal and dispatchable generation units retiring while new capacity additions are largely dominated by intermittent renewable resources such as solar and wind projects, as well as short-term storage solutions based on battery storage systems. PJM, the ISO in which this facility operates, has expressed concerns about the increasing load and decreasing generation in its region. PJM predicts that 40 GW of its existing supply, largely, thermal based generation will retire by 2030. The PJM Long Term Growth Forecast expects loads to increase by over 55 GW by 2035. Finally, PJM's reliability study assumes a major contribution from offshore wind projects in New Jersey, an uncertain resource given the public's opposition to these projects. The Trump Administration recognizes the urgent need for a balanced, reliable, and affordable power grid, as well as the need to rein in regulations that are not needed to protect public health. Granting of an extension for this facility will provide financial relief to allow a full evaluation of the technical and financial feasibility of the benefits and costs of the more restrictive regulations and allow our plant to continue to provide a dispatchable generation resource for the security of the United States and give us, and PJM more time to plan for the continued operation of this critical resource and continue to provide a stable energy supply for the PJM grid. The PJM-RTO is already warning of serious impending Capacity shortfalls (as are other RTOs), and actions like the implementation of MATS RTR will serve to further 1 National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Federal Register 38508. National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Federal Register 38510 4 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000287-00004 SC_EVERSPLIT0006083