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    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 (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 the proposed rule should be withdrawn and re-proposed after a significance threshold for GHG or another method of determining the applicability of the term 'major modification' has been proposed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 (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 (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 (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

    • Kevin Stewart (PDF)
      American Lung Association of the Mid-Atlantic
    • Emily Krafjack (PDF)
      President
      Connection for Oil, Gas & Environment in the Northern Tier, Inc.
    • Jackson Morris (PDF)
      Director of Strategic Engagement
      Pace Energy & Climate Center, Pace Law School
    • Thomas Au (PDF)
      Clean Air Board of Central PA
    • Elowyn Corby (PDF)
      PennEnvironment Global Warming and Clean Energy Associate
    • Susan Carty (PDF)
      The League of Women Voters of Pennsylvania 

    Statements presented at December 16, 2013, Listening Session

    • John Pippy, CEO
      Pennsylvania Coal Alliance
    • Bruce Alexander (PDF)
      Senior Manager, Strategic Environmental Analysis
      Exelon
    • Jake Smeltz (PDF)
      President
      Electric Power Generation Association
    • Martin Williams (PDF)
      Business Agent; Vice-President
      Boilermakers Local 13, Philadelphia
    • Megan Toomey (PDF)
      Project Manager, Environmental Management
      PPL
    • Michael Welsh (PDF)
      International Brotherhood of Electrical Workers
    • Shawn Good (PDF)
      PA Chamber of Business and Industry
    • Tom Crooks
      R.G. Johnson
    • Edward D. Yankovich (PDF)
      International District 2 Vice President
      United Mine Workers of America

    Statements Presented at Sept. 25, 2014 Listening Session

    • Kathleen Ann Robertson *No Written Copy*
      Environmental & Fuels Policy Manager, Federal Regulatory Affairs
      Exelon Corporation
    • Megan Toomey (PDF)
      Project Manager
      Environmental Management Department PPL
    • Tom Crooks*No Written Copy*
      R G Johnson
    • Eugene M. Trisko (PDF)
      United Mine Workers of America / International Brotherhood of Electrical Workers
    • Mike Catanzaro (PDF)
      Managing Director
      Global Energy and Natural Resources Sector
      F T I Consulting
    • Jackson Morris (PDF)
      Director, Eastern Energy
      Natural Resources Defense Council
    • Donald A. Brown (PDF)
      Sustainability Ethics and Law
      Widener University School of Law
    • Joy Bergey
      Federal Policy Director
      PennFuture (PDF)
    • Ed Perry (PDF)
      National Wildlife Federation
      Climate Change Campaign
    • Gretchen Dahlkemper-Alfonso *No Written Copy*
      National Field Manager
      Mom's Clean Air Force
    • Bob Potter *No Written Copy*
    • Karen Melton (PDF)
      Chester County Citizens for Climate Protection
    • Kevin M. Stewart (PDF)
      Director of Environmental Health
      American Lung Association of the Mid-Atlantic
    • Matt Walker (PDF)
      Community Outreach Director
      Clean Air Council

    Written Comments Submitted

    • Kevin Sunday (PDF)
      Pennsylvania Chamber of Business and Industry