New Power Plants

Department Comments(opens in a new tab) (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(opens in a new tab) (PDF), 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 the proposed rule should be withdrawn and re-proposed after a significance threshold for GHG or another method of determining the applicability of the term 'major modification' has been proposed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 the publication of proposed guidelines, the department held listening sessions on December. 9 and 16, 2013. Statements were received from 10 environmental groups and general public participants on December. 9. On December 16, 12 participants from the regulated industry and organizations provided statements and comments for consideration. The department developed a Section 311(d) White Paper(opens in a new tab) (PDF) and held a webinar (MP4)(opens in a new tab) (WMV)(opens in a new tab) 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(opens in a new tab) (PDF) to the Pennsylvania Senate Environmental Resources and Energy Committee, and on July 31(opens in a new tab) (PDF) to the EPA.

A further listening session(opens in a new tab) (PDF) was held by the department on Sept. 25, 2014, before finalizing its 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(opens in a new tab) (PDF) 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 December 9, 2013, Listening Session

Statements presented at December 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