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