December 20, 2013

Ms. Gina McCarthy

Administrator

US Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460

carbonpollutioninput@epa.gov

Mr. George Czerniak

Director, Air and Radiation Division

US EPA Region 5 Office

77 W. Jackson Blvd.

Chicago, IL 60604

czerniak.george@epa.gov

Re: EPA Regulation of Carbon Dioxide Emissions from Existing Power Plants

Dear Ms. McCarthy and Mr. Czerniak:

The Municipal Electric Utilities of Wisconsin (MEUW) appreciates the opportunity to provide 

comments regarding development of carbon dioxide (CO2) regulations for existing power plants 

under section 111(d) of the Clean Air Act.

MEUW is a statewide trade association that represents all 82 municipally owned electric utilities 

in the state of Wisconsin. Combined, our utilities distribute about 11 percent of Wisconsin’s 

electric load to nearly 280,000 residential, commercial, industrial and farm customers. The 

median size municipal electric utility in Wisconsin serves 1,888 customers.

Our members play a significant role in the success of their municipalities by providing low-cost 

and reliable electricity. As with other utilities in the Midwest, Wisconsin utilities have relied on 

coal for baseload energy requirements. MEUW is concerned that proposed rules will result in 

rate increases for our customer base while making our industries less competitive in a global 

market.

The MEUW Legislative and Regulatory Committee agreed to a set of principles that we 

recommend the EPA consider when developing standards of performance for existing electric 

generating units. They are as follows:

Appropriate Emissions Baseline – It is critical that a reasonable baseline year is selected to 

credit proactive utilities that have invested in project-based CO2 emissions reductions; whether 

that project was part of, or outside of, statutory or regulatory mandates.
Appropriate Compliance Timeline – It will take time and substantial economic resources to 

achieve significant emissions reductions. In addition, there is currently no commercially 

available technology to capture, store and sequester CO2. The economic impact of proposed 

GHG regulations can be mitigated by adopting a reasonable and phased in approach to 

implementation.

Systemwide Compliance Basis – Standards should not apply to individual plants because GHG 

reduction projects at individual plants are extremely limited. Allow entities to average their 

emissions over their entire fleet or provide for an even broader base for compliance.

Allow for Total System Emission Reducing Actions – Affected entities should be able to 

comply with the standards of performance utilizing any activities that reduce emissions. These 

activities include supply- and demand-side energy efficiency measures, and shifting generation 

from fossil resources to renewables and other emission-free or lower emitting resources.

State DNR Flexibility – The state’s environmental agency should be provided flexibility to set 

CO2 standards based on commercially viable emission reduction systems currently in use for 

large generation units based on fuel type. This allows state agencies to balance carbon reductions 

with minimal cost impact to consumers.

Recognition of Regional and State Differences – Standards of performance must recognize 

significant differences in generation mix, potential for emission reductions, utility industry 

structure and participation in regional transmission organizations. 

Thank you for the opportunity to share our concerns and for your consideration of our views.

Sincerely,

Zachary Bloom

Executive Director

Municipal Electric Utilities of Wisconsin