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Controlling Carbon from Electric Generation

New Power Plants

Department Comments (PDF) to EPA on the proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units (Section 111b). The department submitted these comments on May 6, 2014.

Modified and Reconstructed Power Plants

On Oct. 16, 2014, the department submitted its official comments, dated Oct. 15, 2014, to the EPA docket concerning the proposed 111(b) Carbon Pollution Standards for Modified and Reconstructed Stationary Sources: Electric Utility Generating Units and concluded by saying "... the proposed rule should be withdrawn and re-proposed after a significance threshold for GHG or another method of determining the applicability of the term 'major modification' has been proposed and finalized. When re-proposed, DEP recommends that the Pennsylvania white paper and these comments be incorporated in order to create a viable and legally defensible rule."

Existing Power Plants

As part of a National climate action plan, the EPA was directed to issue standards, regulations, or guidelines that address carbon pollution from modified, reconstructed, and existing power plants under Section 111(d) of the federal Clean Air Act.

In anticipation of publication of proposed guidelines, the department held listening sessions on Dec. 9 and 16, 2013. Statements were received from 10 environmental groups and general public participants on Dec. 9th. On Dec. 16, 2013, 12 participants from the regulated industry and organizations provided statements and comments for consideration. The department developed a white paper (PDF) and held a webinar (MP4) (WMV) outlining it's position on the issue.

On June 18, 2014, the EPA proposed the Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (Clean Power Plan) under Section 111(d) of the Federal Clean Air Act. Comments are due to the EPA by Dec. 1, 2014.

On June 27, the department presented testimony (PDF) to the Pennsylvania Senate Environmental Resources and Energy committee, and on July 31 (PDF) to the EPA.

A further listening session (transcript - PDF) was held by the department on Sept. 25, 2014, prior to finalizing its own comments on the proposed plan. Statements were received from 14 participants from the regulated industry and organizations and 20 environmental groups and general public participants.

On Nov. 26, 2014, DEP submitted written comments to the U.S. EPA on the Proposed Rule: Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units.

Below are the commenters at the 111(d) listening sessions and their statements as provided to the department:

Statements presented at Dec. 9, 2013 Listening Session

Statements presented at Dec. 16, 2013 Listening Session

  • John Pippy, CEO
    Pennsylvania Coal Alliance
  • Tom Crooks
    R.G. Johnson

Statements Presented at Sept. 25, 2014 Listening Session

  • Kathleen Ann Robertson *No Written Copy*
    Environmental & Fuels Policy Manager, Federal Regulatory Affairs
    Exelon Corporation
  • Tom Crooks*No Written Copy*
    R G Johnson
  • Gretchen Dahlkemper-Alfonso *No Written Copy*
    National Field Manager
    Mom's Clean Air Force
  • Bob Potter *No Written Copy*

Written Comments Submitted