Coalition Comments on EPA's Mercury and Air Toxics Standards (MATS)

March 27, 2019

Dear Assistant Administrator Wehrum:

The Environmental Protection Agency (EPA or Agency) has proposed a Reconsideration of Supplemental Finding for National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-fired Electric Utility Steam Generating Units. EPA has also proposed a Residual Risk and Technology Review (RTR) concurrently with its reconsideration. 84 Fed. Reg. 2,670 (Feb. 7, 2019). EPA’s 2016 Supplemental Finding followed the Supreme Court’s decision in Michigan v. EPA, which held that EPA must consider costs in evaluating whether it is appropriate and necessary to regulate EGUs.

Driven by several factors—including customer demands, technology developments, and federal and state regulatory obligations—the electric power industry is undergoing a transition of its electric generating fleet that will continue over the next decade and beyond. Concurrent with this transition, electric companies, public power utilities, and electric cooperatives are making significant investments to make the energy grid smarter, cleaner, more dynamic, more flexible, and more secure in order to integrate and deliver a balanced mix of central and distributed energy resources.