Document pmbaX98X8KxxzGVkbY5aB825d

Miami Fort Power Company, LLC Miami Fort Power Company, LLC 11021 Brower Rd North Bend, OH 45052 March 31, 2025 Submitted via email to airaction(depa.gov President Donald J. Trump do Administrator Lee M. Zeldin Office of the Administrator (1101A) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, I.W. Washington, D.C. 20460 Re: Presidential Exemption: National Emission Standardsfin. Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review, 89 Fed. Reg. 38,508 (May 7, 2024): Miami Fort Power Plant Unit 1 (B015) and Unit 2 (B016). Dear President -Frump: Please accept this letter on behalf of Miami Fort Power Company I,I,C 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 hazardous air pollutants ("HAP") and the requirement to install continuous emissions monitoring systems ("CEMS" or "PM CEMS") under the above-referenced rule (the "MATS RTR" or the "Rule") for Miami Fort Power Plant Units 1 (B015) and Units 2 (B016) ("Miami Fort"). Miami Fort Power Company LLC is requesting a 2-year exemption, beginning July 6, 2027, from these requirements for the Miami Fort Power Plant. The MATS RTR amended 40 C.F.R. Part 63 Subpart UUUUU and became effective on July 8, 2024. Under the Rule, the Miami Fort electric generating units ("ECUs") are required to reduce fl'M emissions from 0.030 lb/MMI3tu 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 ECUs to continue to use stack testing to demonstrate compliance. The compliance deadline for meeting the fPM standard and for installing and using PM 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 1 12(i)(4) of the Clean Air Act, the President may issue exemptions "from compliance with any standard or limitation under this section fora period of not more than 2 ,'ears 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 authorized to exercise his discretion to exempt FGIJs from complying with the MATS RTR where (1) the technolo2y required to implement" the standard 1 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000163-00001 SC_EVERSPLIT0005935