December 20, 2013

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 development 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 Pollution from Existing Power Plants.” The Missouri 

Department of Natural Resources Air 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 submittal 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 program. 

With regions beginning from different places in reducing carbon pollution from existing power plants, and 

acknowledging that geographic differences make for varying degrees of efficacy 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 include 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 induce import of fuels 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 work best through facilitated 
partnerships 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 appropriate 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, better 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 to 

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 being met. Providing such guidance will allow for a more seamless 

program with understood expectations and smoother implementation.

The Air Quality Forum appreciates the opportunity to comment on this issue. If you have questions or need additional 

information, 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