To:
Jackson, Ryan[jackson.ryan@epa.gov]
From: Paul Bailey
Sent: Fri 8/18/2017 11:31:01 AM
Subject: CCR letter attached
EPA CCR Letter August 16.pdf
Paul Bailey President & CEO American Coalition for Clean Coal Electricity T: 202.459.4818 | M: 703.586.2422 pbailey@amencaspower.org
17cv1906 Sierra Club v. EPA
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\((( I
AMERICA'S POWER
August 16 ,2017
Mr. E. Scott Pruitt Administrator United States Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460
Dear Administrator Pruitt:
We are writing to urge that the United States Environmental Protection Agency ("EPA")take immediate steps to postpone the compliance deadlines under the Coal Combustion Residuals ("CCR") rule. Although EPA has just issued guidance to the states on implem entation of the CCR rule, the guidance does nothing to avoid the additional coal plant retirements that will result from this rule over the next few years.
An estimated sixt y percent (60%) (about 150,000 m egawatts) of the U.S.
coal fleet's electric gen
erating capacity relies on unlined surface
impoundments and, therefore, is at risk because of the CCR rule.
Many electric
utilities that operate coal -fired power plants will undertake compliance steps
soon that could lead to plant retirement decisions wit
hin a year unless the
compliance deadlines are postponed.
Besides the threat of these coal -fired generating unit retirements, the
required compliance steps will likely be unnecessary and wasteful for many
coal plants because there are likely to be change
s to the CCR Rule. These
changes are expected as a result of the pending petition for reconsideration
filed by the Utility Solid Waste Activities Group and the passage of the WIIN
Act to authorize implementation of the CCR rule through state permit
progra ms.
As you know, we are very appreciative of the efforts by you and President Donald J. Trump to help the coal industry. Thank you for considering our request that the EPA postpone the CCR compliance deadlines.
1155 15th Street N W I Suite 900 I Washington, DC 20005 I 202.459.4800 I www.americaspower.org
17cv1906 Sierra Club v. EPA
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Sincerely, The American Coalition for Clean Coal Electricity
Robert E. Murray Chairman
Paul Bailey President and CEO
1155 15th Street N W I Suite 900 I Washington, DC 20005 I 202.459.4800 I www.americaspower.org
17cv1906 Sierra Club v. EPA
ED_001523_00000566-00002