Document dQk1ab7XG5yGwZOVqvzkOkGYR

lb/MMbtu in order to ensure continuous in compliance. See Pet'rs' Brief at 72. Therefore, the CEMS technolo2y to demonstrate compliance with the revised fPM standard is unavailable. Second, there are significant costs and market limitations associated with PM CFMS, which make it "not available." Installing, upgrading. and operating CEMS is more costly than stack testing. See PUEN Comments at 25-26. Costs include purchasing and installation of CEMS, as well as potential modifications to the units to accommodate CFMS, extended correlation testing, and annual operational costs. See id. at 26; see also Class of '85 Comments at 18 (estimating $180,000 to $400,000 for "site preparation and engineering analysis, analyzer equipment and installation costs. and initial PS-11 correlation testing''). This does not include the costs of maintaining a full-time employee to operate PM CFMS and the costs of lost generation during testing events for CFMS. Luminant Comments at 16-17. There are also market factors which limit the availability of installing and operating CEMS by the compliance deadline. There are a limited number of vendors for CEMS. as well as a limited number of professionals certified to install and test CEMS. Currently, two-thirds of facilities utilize stack testing and would need to install CFMS by July 2027, which would overwhelm the current supply of CFMS and the availability of professionals certified to inspect and test the newly installed systems, as well as upgrading existing systems. See Class of '85 Comments at 16. Ill. It is in the Interest of National Securit3 to Issue an Exemption for the Rule The requested exemptions from the MATS RTR arc in the national security interests of the United States. The Rule adversely affects the nation's energy generation capacity and threatens grid stability and the supply of affordable, reliable energy. the Rule's stringent limits and the high costs associated with compliance, particularly in combination with other rulemakings impacting coal-fired EGUs, place a considerable burden on the operation of the Kincaid units. 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. Pet'rs' 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." Id. at 29. Energy generation and grid reliability have, in turn, been identified by the President as issues of national security. As set Forth in President Trump's Executive Order ("E.O.") 14156, Declaring, a National Encixv Erner.;encr, 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 F.O. 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 has been identified as contributing to the "inadequate and intermittent energy supply" and "increasingly unreliable grid." Id. at 8,433. Similarly, in F.O. 14154, ( tnica.vhing American Energy, President Trump acknowledged that prior regulations--which include this Rule--have "limited the generation of reliable and affordable electricity" and, in turn, "weaken[eci] our national security." 90 Fed. Reg. 8,353, 8,353 (Jan. 29, 2025). This E.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." Id. Providing an exemption for compliance with the MATS 4 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000161-00004 SC_EVERSPLIT0005933