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EEI Statement on EPA’s Proposed Guidelines for Greenhouse Gas Emissions from Existing Generation Sources
​Washington, DC (June 2, 2014) – Edison Electric Institute (EEI) President Tom Kuhn issued the following statement today on the Environmental Protection Agency’s (EPA’s) proposed guidelines for states to regulate greenhouse gas (GHG) emissions from existing electric generation units.

“As we do with any new EPA regulation, EEI is thoroughly reviewing the proposed guidelines issued today to assess whether they contain achievable compliance requirements and deadlines; recognize the wide range of actions our companies have taken to date that have reduced or avoided emissions; and preserve the fuel diversity and flexibility that ensure electricity remains reliable and affordable for all customers.

“It is important to remember that our industry has led the way in taking voluntary actions to reduce, avoid, or sequester GHG emissions. We also are investing more than $90 billion each year, on average, to transition to a cleaner generating fleet and to enhance the electric power grid to meet the needs of our 21st-century digital economy. EPA has acknowledged the industry’s ongoing progress, including our recent efforts under the Mercury and Air Toxics Standards and other federal and state environmental regulations.

“It is crucial that the baseline from which emission reductions are measured recognizes the significant voluntary actions and investments already taken by states and electric utilities to reduce GHG emissions, transition to a cleaner and enhanced generation fleet, and comply with other environmental regulations. While the 2030 reduction target is ambitious, it appears that utilities may be allowed to take advantage of some of their early actions.

“In any final guidelines, it is imperative that EPA provide the states with achievable targets, emission reduction goals, and compliance deadlines. The proposed timeline for states to submit plans to EPA recognizes that ample time is needed to develop and implement new emission reduction programs.

“While we are still assessing the overall proposal, EPA appears to have allowed for a range of compliance options to reflect the diversity of approaches that states and electric utilities have undertaken and may undertake to reduce GHG emissions. Flexible compliance is necessary to maintain a diverse portfolio of generating sources. However, there are some concerns about EPA’s broad approach to ‘best system of emissions reductions,’ and we will look at this issue carefully.

“We appreciate that EPA today also proposed separate standards for modified and reconstructed units. Units that are obligated to take actions to comply with other environmental regulations need clarity on the future regulatory framework.

“The 120-day comment period that EPA is allowing for both of these proposed guidelines and standards reflects the complexity and importance of these rulemakings. We will work with our member companies throughout these rulemaking processes to provide EPA with relevant information, data, and comments about the impact these proposals will have on our industry’s ability to provide reliable and affordable electricity to all customers.”
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