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ICAC Provides Comments on EPA‘s Proposed Clean Power Plan

Tuesday, December 02, 2014  
Posted by: Betsy Natz, Executive Director ICAC
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FOR IMMEDIATE RELEASE:

 

ICAC Provides Comments on EPA‘s Proposed Clean Power Plan

 

Washington, D.C., December 2, 2014:  The Institute of Clean Air Companies (ICAC) offers comments to the EPA on Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units.


ICAC commends the EPA for proposing regulations to obtain reductions in carbon dioxide from power plants in response to the President’s Climate Action Plan and supports the EPA’s effort to engage in extensive stakeholder outreach, transparency in developing the proposal, and offering the maximum flexibility to states to develop unique plans within the framework of the Clean Air Act.

 

ICAC urges the EPA to reconsider the section of the proposed regulation on heat rate improvement (Building Block One) because of technical issues with EPA’s analysis. The EPA did not properly account for capacity factor and cycling duty, cooling water temperatures’ impact on heat rate, the impact of fuel changes, and many other technical factors that should be considered in a statistical analysis of heat rate. ICAC also disagrees with the EPA’s proposal to increase the Natural Gas Combined Cycle capacity factor from 48% to 70% because this would result in a reduction in the coal fired units’ utilization and could harm the reliability of the grid. In addition, decreasing the utilization of the coal fired sector increases the aggregate heat rate of the coal fired sector which tends to net out any gain in Building Block One.

 

Since 1960, ICAC has promoted the air pollution control industry and encouraged the improvement of engineering and technical standards. members include over 80 companies who are leading manufacturers of equipment to control and monitor emissions of particulate matter (PM), volatile organic compounds (VOC), sulfur dioxide (SO2), nitrogen oxides (NOx), as well as mercury, acid gases, and other hazardous air pollutants (HAP). ICAC members are also on the forefront of developing controls for greenhouse gases (GHGs). ICAC is in a unique position to provide technical comments on this proposed rulemaking. ICAC’s collective technical expertise is, and will continue to be, an important voice in the ongoing debate on how to cost-effectively reduce CO2 emissions.

 

About ICAC


ICAC is the nonprofit association of companies that supply air pollution control technology and monitoring systems for stationary sources. Its mission is to be the voice of the stationary source air pollution control and monitoring industry by providing technical information relevant to flexible clean air policies based on practical, achievable and measurable emission limitations. For more information, please visit. www.icac.com.

 

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