Document aBGR3dYQ3KXJygQ0JM9JYaZnB

adversely affects the nation's energy generation capacity and threatens grid stability and the supply of affordable, reliable energy. Fhe Rule's stringent limits and the high costs associated with compliance, particularly in combination with other rulemakin2s impacting coal-fired EGUs, place a considerable burden on the operation of Oak Grove. And MATS rules have historically resulted in the loss of generation capabilities the 2012 MATS rule resulted in the retirement of approximately 60,000 MW of coal-fired capacity. ?errs' Brief at 23. As explained in Lurninant's Comments, coal plants "continue to be of paramount importance for grid reliability during the transition to renewables." Icl. at 29. The President has identified energy generation and grid reliability as issues of national security, and it is, therefore, in the interest of the nation to exempt these units from compliance with the MATS RTR. As set forth in President 'Frump's Executive Order ("E.O.") 14156, Declaring a :National Energy Emergency, the "generation capacity of. the United States [is] . . . far too inadequate to meet our Nation's needs" and "a reliable, diversified, and affordable supply of energy" is necessary to ensure "military preparedness." 90 fed. Reg. 8,433, 8,433 (Jan. 29. 2025). The E.U. continues, "integrity . . . of our Nation's energy infrastructure from coast to coast is an immediate and pressing priority for the protection of the United States' national and economic security," while "insufficient energy production . constitutes an unusual and extraordinary threat to our Nation's economy, national security, and foreign policy." Id. at 8,433-34. As explained above, the MATS RTR is one of the "policies" that the President has indicated will contribute to the "inadequate and intermittent energy supply" and "increasingly unreliable grid." M. at 8,433. Similarly, in E.U. 14154, Unleashing American Energy, President Frump acknowledged that prior regulations which include this Rule have - limited the generation of reliable and affordable electricity" and, in turn, "weaken' edl our national security." 90 Fed. Reg. 8,353, 8,353 (Jan. 29, 2025). This F.O. plainly states it is in "the national interest to unleash America's affordable and reliable energy" and that ensuring "an abundant supply of reliable energy" will help "protect the United States's economic and national security and military preparedness." hi. Providing the requested exemptions will achieve these goals of ensuring national security through the supply of reliable energy. Moreover, F.O. 14154 specifically calls for the review and potential rescission of rules like this one, which "impose an undue burden on the . . . use of domestic energy resources." hi. at 8,354. Thus, in order to ensure a sufficient and reliable supply of energy, President Trump should use his lawful authority under Section 1 12(i)(4) of the CAA to grant the requested exemptions from compliance with the standards set forth in the MATS RTR. If you have any questions regarding this submittal, please contact Renee Collins at Rence.Collinsgvistracorp.com. Sincerely, Ocytar-- Cynthia Vodopivec Senior Vice President, Environmental, Health & Safety Sierra Club FOIA 2025-EPA-04883 ED_018388_00000159-00005 SC_EVERSPLIT0005929