December 20 , 201 3

Josh Tapp EPA Region 7 11201 Renner Boulevard Lenexa, KS 66219

To Whom It May Concern:

The Mid

- America Regional Council (MARC) Air Quality Forum, created in accordance with Section 174 of the Clean Air Act to coordinate the developm ent and implementation of air quality policy in the bi

- state Kansas City region, offers the following comments on the Environmental Protection Agency’s (EPA) request for comments on the document “Considerations in the Design of a Program to Reduce Carbon P ollution from Existing Power Plants

. ” The Missouri Department of Natural Resources A ir Pollution Control Program, the Kansas Department of Health and Environment
Bureau of Air and the Kansas Department of Transportation have chosen to abstain from the subm ittal of these

comments.

The Air Quality Forum (AQF) is generally supportive of reducing carbon pollution from existing power plants. In developing programs to do so, the EPA must provide both tools and resources to the states and regions responsible for developing plans to help meet any targets that are set. The necessary increase in workload to develop and implement plans in order to meet targets is not trivial and additional resources, financial and otherwise, will be critical to the success of the prog ram.

With regions beginning from different places in reducing carbon pollution from existing power plants, and acknowledging that geographic differences make for varying degrees of efficac y of renewable resources, the program must ensure a level playing field to the highest extent possible. The baselines will differ wildly from place to place, and an overly prescriptive fuel mix may hinder opportunities for progress in renewables and other possible additions to a regional fuel mix. For example, wind is a valuable resource in and near the Kansas City region; it would be ideal to be allowed to take full advantage of the resources made available based on geography. Technology solutions will be a major piece of the reductions; alternative solutions could inclu de fuel switching, reduced usage, natural sequestration through native plants and forestry and other non

- technological approaches. However, we also must take a systems

- level approach and ensure that fuel

- switching has the intended effect and does not induc e import of fuel s or other potentially neutralizing effects.

With rising energy costs affecting those least able to pay, demand

- side efficiency programs must be an allowable approach to meeting the targets. In Kansas City’s experience, local connections w ork best through facilitatedpartnerships with local governments and end users. Regardless of the level at which demand

- side efficiency programs are made available, demand reduction will be critical to the success of the program.

In determining the appro priate boundaries for plans to be developed, state boundaries may be the quickest and easiest approach. However, political boundaries may not ultimately be the most logical approach. While it may not be possible within the time frame of this proposal, bett er groupings may be by region, power pool or other type of grouping rather than traditional political or geographic boundaries.

Ultimately, the more flexibility left to the states in meeting the targets, the better. This should include the flexibility t o meet the targets from reductions at the source as well as “off

- footprint” options such as the demand

- side and other alternative measures listed above. Also included in the targets should be an allowable percentage for new ideas; innovation could help areas develop and implement more effective plans than if limited to existing technologies and approaches. However, although flexibility is important, the EPA must still provide clear guidance, review and approval processes to ensure performance standards are be i ng met. Providing such guidance will allow for a more seamless program with understood expectations and smoother implementation.

The Air Quality Forum appreciates t he opportunity to comment on this issue . If you have questions or need additional
informa tion, please contact Amanda Graor, MARC Air Quality Program Manager at 816.701.8333 or agraor@marc.org

.

Sincerely,

Ed Peterson Scott Burnett Kansas Co

- Chair, Air Quality Forum Missouri Co

- Chair, Air Quality Forum