From: "Pugh, Theresa" <TPugh@publicpower.org>

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Date: 07/06/2011 02:22 PM

Subject: NRECA/APPA follow up with suggestions for EPA's July 13 NSPS meeting

July 6, 2011

Ms. Lanelle Bembenek Wiggins

RFA/SBREFA Team Leader

U.S. Environmental Protection Agency

Office of Policy

1200 Pennsylvania Avenue, NW (1806A)

Washington, DC 20460

Dear Ms. Wiggins:

Good afternoon. On behalf of the Small Entity Representatives (SER) for the NSPS for the electric 

generation sector (EGU-NSPS for CO2) group we write to make several suggestions.

We believe that the proposal of an NSPS in September should be delayed until the SER panel spends 

considerable time discussing regulatory options for various sizes, types, a variety of fuels and ages of

plants. We don’t think that the last meeting even scratched the surface. We think that it could have been 

more useful to discuss specific efficiency opportunities with different types of generation technology.

We note that, as of July 6, 2011, we have received no agenda or listing of specific regulatory alternatives 

identifying options on fuel types, generation types, or ages of plant. In light of the general discussions
regarding the June 17, 2011 meeting, we would like to make some recommendations. We believe that these 

recommendations will enable the U. S. EPA staff (and contractors) to make better decisions regarding least 

cost or less burdensome regulatory options. Although the U. S. EPA has not offered specific regulatory

alternatives (as requested and as is the standard for a SER panel), we do believe, based upon your slides,

that a pounds/mwH has been informally implied by your staff.

On behalf of the participants, we suggest the following issues to be added to the agenda for July 13th 

assuming that you intend to proceed with the SER meeting. If the EPA had already planned a full day’s

program, then we would like to suggest that these topics be added to the meeting. If needed, we suggest

that you add a third day to the SER process to make certain that these topics are included in the SER panel.

(As you might recall, APPA requested 4 or 5 SER meetings to discuss NSPS for CO2 and other GHGs).

• Limited use boilers with limited opportunities for efficient improvements due to NSR complications 

for conventional pollutants (even though we believe that the pollution control exclusion applies in the

context of NSPS) (30 minutes)

• Variances per kwH and heat rates over monthly and annual operations (six real world case studies by 

utilities totaling 45 minutes)

• Why age of plant is significant in setting any NSPS for CO2 (Wyandotte) (1hour) (if speaker is 

available by phone or in person)

• A brief presentation on legal issues on NSPS for CO2 (Bill Wehrum) (30 minutes)

• Why knowing the end game on biomass is critical before proposing NSPS for EPA and utilities 

(Holland) (30 minutes)

• Why municipal government electric utilities are different from other utilities. Examples: why the 

business model is based upon cost-effective decisions that integrate wastewater treatment waste

combustion, etc. Why waste heat for snow melt and community energy plan provides high temperature for 

high temperature water in buildings to reduce CO2 used from heating of water, etc (Holland) (30 minutes)

These recommendations, totaling about 4 hours, should improve the SBERFA SER process significantly 

given the importance of a NSPS for the power sector and your impending September 30th deadline. Thank 

you for your consideration.

Thank you,

(approval given for electronic signature by e-mail)

Rae

Theresa

Rae Cronmiller

Theresa Pugh

NRECA

APPA

Sent by:

Theresa Pugh

Director, Environmental Services

APPA

1875 Connecticut Ave, NW

Suite 1200

Washington, D. C. 20009

202 467 2943 (direct)

202-495-7443 personal fax number

Note new e-mail address: mailto:TPugh@publicpower.orgTPugh@publicpower.org