HOOSIER ENERGY 

R URAL E LECT R IC C OOPERATIVE, IN C . 

A Touchstone Energy" Cooperative ~ 

May 23,2012 

My name is Craig Chrispell; I work in the Environmental Affairs department for Hoosier Energy Rural 

Electric Cooperative. Hoosier Energy is a non-for-profit generation and transmission cooperative serving 

18 distribution cooperatives in central and southern Indiana as well as a portion of south-eastern Illinois. 

I am speaking on behalf of our members. Our comments also reflect the concerns of the National Rural 

Electric Cooperative Association. Hoosier Energy produces electricity with an increasingly diverse range 

of energy sources. These sources include renewable energy such as landfill gas, hydro, wind, and 

traditional fuels - natural gas combined cycle, coal and gas turbines. Our member owners expect and 

strive for affordable electricity produced in an environmentally acceptable manner. This rule effectively 

deletes an affordable and abundant domestic fuel source from future use and innovation. 

Problematic aspects of the rule are: 

1) The rule effectively redefines the source by pegging the limits to an alternative fuel. The 

standard is based on the performance of natural gas combined cycle, which EPA has determined 

constitute the "best system of emission reduction" for the source category. The fact is that EPA 

is taking the unprecedented step of defining New Source Performance Standards for both coalfired power plants and natural gas power plants together by setting the standard for coal based 

on the performance of natural gas power plants. That is a doctrine called fuel switching or 

redefining a source. EPA in the past, as well as the courts, has said it doesn't have the authority 

to redefine a source. 

2) Basically a coal-fired power plant would have three options. The preferred option seems to be 

to not use coal and switch to natural gas. Another would be to use supercritical boiler 

technology, a coal technology for the first 10 years, but over 30 years, EPA's going to even hold 

you to a more stringent standard and expect you to phase that out. The third option is to use 

carbon capture and sequestration, which EPA says as of today is technically feasible. There is 

not any coal-fired power plant in the world that has been able, even with substantial 

government subsidies, to use this technology on a commercial scale. At this time, CCS is neither 

economically viable nor commercially available. 

3) According to the preamble, the NSPS as proposed would not apply to existing EGUs, including 

existing EGUs that undertake modifications or are reconstructed. Although emission standards 

promulgated by EPA under section lll(b) traditionally have applied to modified and 

reconstructed facilities, EPA states that it has insufficient data on which to base GHG emission 

standards for modified or reconstructed EGUs. However, in all cases, the BACT and LAER must 

be at least as strict as any existing NSPS for the source. The proposed NSPS limits for new 

sources must not apply to existing sources in connection with NSR/PSD applicability. 

4) EPA must revise the rule as proposed to make it absolutely clear that this rule does not apply to 

simple cycle combustion turbines. EPA has made public statements to this effect, but the rule as 

drafted would require combustion turbines to limit operation to 2900 hours or less which will 

have a major impact on system reliability. 

P. O. BOX 908 • BLOOMINGTON , I NDIANA 47402- 0908 • PHONE : 812- 876 - 202 1 • FAX : 812- 8 7 6 - 347 6 
5) Any future innovation to potentially help energy strategy and costs in the United States will not 

be targeted to coal, the United States most abundant, domestic energy source. Also, by 

effectively removing coal from our country's energy mix raises additional concerns due to the 

volatility that exists in the other energy markets. Losing the option to generate power from 

coal, which has historically stable costs compared to oil and gas, is a risk we should not be 

willing to take. The fact that the NSPS for GHG emissions from power plants will increase 

electricity costs for residential consumers and businesses in the U.S. is beyond dispute. These 

higher prices will, in turn, undermine both the U.S. economy and future progress to curb GHG 

emissions. Our charter states, as a Rural Electric Cooperative, to provide reliable, affordable 

electricity to our members.