# 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 ofsouth-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, coa l and gas turbines. Our member owners expect and strive for affordable electricity produced in an environmenta lly acceptable manner. This rule effectively deletes an affordab le 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 wou ld have three options. The preferred option seem s to be to not use coal and switch to natural gas . Another would be to use supercritical boiler technology, a coal technology for the firs t 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 th i rd 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 subs tantial government subsidies, to use this technology on a commercial sca le. At this time, CCS is neith er economically viable nor commercia lly availab le. 3) According to the preamble, the NSPS as proposed would not apply to existing EGUs, in cluding existing EGUs that undertake modifications or are reconstructed. Although emission standards promulgated by EPA under section lll(b) traditionally have applied to modified and recon s tructed 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 mus t not apply to exis ting sources in connection with NSR/P SD applicability. 4) EPA must revise the rule as proposed to make it absolutely clea r 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
.

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. O. BOX 908 • BLOOMINGTON , I NDIANA 47402 - 0908 • PHONE : 812 - 876 - 202 1 • FAX : 812 - 8 7 6 - 34 7 65) 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 effective ly removing coal from our country's energy mix raises additional concerns due to the volatility that exists in the other energy markets. L osing 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
.