EPA Turbine Plan Flawed, NRECA Says
The Environmental Protection Agency could boost generation costs and force some combustion turbines into early retirement, if its planned changes to federal standards take effect, NRECA said.
NRECA joined with the American Public Power Association in asking EPA to back off its proposed revisions to New Source Performance Standards for stationary gas turbines and stationary combustion turbines.
The agency also is acting unlawfully in trying to make the standards—announced last August—retroactive to February 2005, the associations added.
“This position is clearly irrational and inequitable. Moreover, it would be unlawful to retroactively impose the prior applicability date on a dramatically revised NSPS,” they said.
The joint comments were submitted Dec. 28 by Rae Cronmiller, NRECA environmental counsel, with Theresa Pugh, director of environmental services for APPA.
The combustion turbine rule is complex but important, because co-op and municipal systems’ electric generation is increasingly originating from natural gas-based combined-cycle and simple-cycle combustion turbines.
In part, that is because of their lower fuel cost; the price of natural gas is at historically low levels, federal officials say.
Among other things, NRECA and APPA said EPA would adopt a radically narrow definition of a “combustion turbine” that’s used to determine whether “reconstruction” has been triggered under the NSPS clean air regulatory program.
NSPS reconstruction is based on replacement parts capital cost exceeding 50 percent of the cost of a comparable new combustion turbine. So the less structure that is included as part of the “combustion turbine” definition, the more NSPS reconstruction will be triggered with relatively periodic and standard parts change-outs that typically occur at the facilities.
The associations stated that EPA failed to provide any rationale for proposing such an unprecedented change in the NSPS turbine regulatory program.
“The reconstruction proposal could substantially drive up the costs of combustion turbine facilities. This would negate opportunities to utilize gas-fired combustion turbines as economically viable substitutes for higher-emitting electric generation,” according to NRECA and APPA.