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Comments to EPA on Request for Input on Reducing Greenhouse Gas Emissions from Existing Fossil-Fuel-Fired Stationary Combustion Turbines

In May 2024, the Environmental Protection Agency (EPA) issued a request for input on reducing greenhouse gas (GHG) emissions from existing fossil fuel-fired stationary combustion turbines. The Institute for Policy Integrity submitted comments to EPA, providing recommendations on key issues for the agency to consider as it develops new regulations.

Policy Integrity's comments make the following key points:

  • EPA should move forward expeditiously to regulate GHG emissions from existing gas turbines and regulate the fleet comprehensively to avoid creating perverse incentives for operators to extend the life of existing, less-efficient turbines.
  • EPA should carefully design the final rule and complementary regulatory programs to ensure that the use of hydrogen co-firing does not undermine the climate benefits of the rule.
  • EPA should offer guidance to states on the design of emissions trading and averaging mechanisms, ensuring that such programs prevent regulatory leakage and co-pollutant hotspots that disproportionately burden environmental justice communities.
  • EPA has the legal authority to include market-based mechanisms as part of the "best system of emission reduction" (BSER) in order to make costs more reasonable, and these mechanisms can still be used for implementation and compliance regardless of whether they are included in the BSER.
  • EPA should move forward with regulating existing gas turbines while coordinating with the entities primarily responsible for grid reliability as they leverage their expanding set of tools to address potential reliability concerns.