ACSF regularly comments on U.S. government proposals that impact the electric power sector and associated air emissions. Comments have been filed with the Federal Energy Regulatory Commission (FERC); the Department of Energy’s Office of Energy Efficiency and Renewable Energy (EERE); and the Environmental Protection Agency (EPA).
Federal Energy Regulatory Commission (FERC)
On February 29, 2012, ACSF provided comments on FERC’s Staff White Paper on the Commission’s Role Regarding Environmental Protection Agency’s Mercury and Air Toxics Standards (MATS). ACSF suggested adjustments to EPA’s and FERC’s proposed MATS extension procedures to avoid unnecessary reliability problems, urging the adoption of an order (or orders) to require early, open and transparent planning that meaningfully involves state regulators and informed stakeholders.
On March 2, 2011, ACSF commented on a Notice of Proposed Rulemaking regarding Integration of Variable Energy Resources (VERs). ACSF’s response focused on the fair allocation of costs for the ancillary services needed to support more renewable energy. The Foundation also supported Chairman Wellinghoff’s goal of encouraging VERs and natural gas to partner as a means of creating a cleaner baseload system for electricity generation.
On May 13, 2010, ACSF responded to FERC’s request for comment on a proposal to pay market prices for energy demand response resources. In its submission, ACSF voiced concern over the unintended consequences for air emissions and the impact on cleaner supply side resources.
Environmental Protection Agency (EPA)
Transportation — Tailpipe Emission and Mileage Stardards
On August 28, 2012 ACSF and other alternative fuel champions won a significant victory when the Obama Administration decided to include both natural gas vehicle (NGV) and electric vehicle (EV) manufacturing incentives in groundbreaking new U.S. fuel economy and tailpipe emission standards. These new rules will cover tens of millions of cars and light-duty trucks produced for the 2017-2025 model years. The rules are designed to increase each manufacturer’s corporate average fuel economy (CAFE) to the equivalent of 54.5 mpg by 2025 and cut CO2 emissions by approximately 40 percent to 163 grams/mile.
Electric Power — Power Plant Rules
On January 7, 2013, ACSF submitted comments on EPA’s recent proposed rule that addresses, inter alia, the “Reconsideration of Certain New Source and Startup/Shutdown Issues: National Emissions Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units.”
On June 25, 2012, ACSF submitted comments to EPA to support their proposed standards for greenhouse gas emissions from new fossil fuel-fired power plants. The Foundation also suggested multiple approaches for EPA to strengthen the rule’s implementation.
On August 4, 2011, the Foundation filed comments supporting EPA’s proposed rules to reduce the emission of hazardous air pollutants (HAPs), such as mercury and acid gases, from power plants. ACSF urged the EPA to spell out how existing power plants could comply with the new rules by burning more natural gas which does not produce the same harmful pollutants. ACSF said substituting gas for more polluting fuels should qualify as one of the “maximum achievable control technology” (MACT) choices that would be mandated by the new EPA rules.
On October 1, 2010, ACSF provided comments to support EPA’s proposed Clean Air Transport Rule and explained how its emission allocation method and other components of the proposal could be improved.
On March 22, 2010, ACSF replied to the agency’s request for comment on its proposal to tighten National Ambient Air Quality Standards (NAAQS). ACSF urged EPA to move forward on its proposal and to explicitly recognize the major role natural gas can play in enabling regulated parties to comply with more stringent ozone standards in a cost-effective and timely way.
Department of Energy (DOE)
On April 11, 2012, ACSF submitted comments on DOE’s proposed “Petroleum Reduction and Alternative Fuel Consumption Requirements for Federal Fleets,” strongly supporting the Proposed Rule’s goals but explaining how it could better encourage consumption of alternative transportation fuels like natural gas.
On January 30, 2012, ACSF filed comments on DOE’s forthcoming transmission congestion study and urged DOE to take into account future increases in gas-fired generation. ACSF noted that gas-fired units can be located close to load and, thus, can provide a key means of alleviating transmission constraints. Congress has directed DOE to conduct a study every three years on electric transmission congestion and constraints, and ACSF similarly advised DOE to better consider the role of natural gas in complementing renewables, and as a cleaner alternative to coal for their 2009 study.
On October 29, 2010, the Foundation answered DOE’s request for comments on a proposal to modify the methods it uses to measure the energy use and emissions from consumer appliances. ACSF supported DOE’s adoption of full fuel-cycle measures for benchmarking the energy efficiency of appliances. The Foundation also urged more widespread use of fuel-cycle principles in DOE’s standards setting so as to provide the public more complete information in the greenhouse gas footprint of appliances.