5.7. ERMUSR 03-13-2013 - Laserfiche WebLink

Home Browse Search

illAVISII11 iiiiivSeg • Minnesota Municipal Utilities Association energy sales. The increased energy Environmental Regulatory Timeline for Coal Units costs from these programs have resulted in multiple rate increases Ozone 502/NO2] CAIR Water on our customers. These costs come mm g 30.2 Ramry at an unprecedented time of reduced Rednd Cg1R Phase Bemnudrzl nMUC Effluent Guidelines P Seasonal Effluent GutMPnee OMO Nos Cep °ne Proposed Reel mbeepetled commercial and manufacturing MGa RM°B Ree'aaaeant Final CAIR G6 N6 Ozone m;m;nb Y. CHIC Rule Epenled Replsemen, 9evaNVY NM08 ReNtlpn activity, high unemployment, 'Vacated OA E.peeleo LAMBS „ ej CanpFnce EMwnl 31fi1d1 ontlask 11 Ne elrpeen rule reduced property values and tax R N6 a,de,nes eeponbd revenue in cities, and concerns about nd s Ns l �dl, economic vitality both locally and 0 0 0 0 0 0 0 0 0 0 nationally. The new EPA regulations will only multiply these rate I " PM 25 B gn PM2S Y P y Sips due e g LAIR " RU slPae So g gCAIR increases. The new EPA regulations m' Rule a NAAOS I °fit 9nefions°B A °tl CAP Phase g Annual^ SC Cap COBB IM o In CompIl a SD_8N0 Cops II Seasonal are, simply put, "too much, too soon." NO.Cap mgro I Bag NOS Cap Rpwmnenlsunder Complonce,m Proposed Fine]CCB Rub 6PIB Rub for CCBs Fns EPA (groundwater Replacement Rue The Clean Air Act— Me-timed Nonaranman' monl B doable rule eryecled Proposed CeYgnesoeo menden closure. the Wrong Tool dry ash conversion) PMZS Ash I I 1 i 1 rCt When Congress enacted the major provisions of the current Act, the main focus of the legislation was addressing MMUA Position improvements in the traditional criteria pollutants, such as soot or MMU A supports continuin continuing im p agricultural dust (particulate matter), smog and quality of the nation's air and believes that such other hazardous air pollutants. There is no record improvements can be made in a sensible fashion indicating that Congress anticipated these same without damaging the economy, so long as there regulatory structures would one day be used to is a full understanding of the cost of the proposed control a substance as ubiquitous as CO2, for which regulations. Credit for early adoption of measures no effective control technologies exist even today. already taken needs to be included in any new The recent court ruling to vacate the Cross State regulatory scheme. Air Pollution Rule (CASPR) is an example of how ill-suited the Act is for the broad purposes to which MMUA urges the Administration to recognize the EPA is applying it. One of the law's principal the cumulative impact of all EPA climate change authors, Rep. John Dingell (D-MI), famously said and air quality regulatory activity on jobs and that using the Clean Air Act to regulate greenhouse American economic competitiveness. In doing so, gases would result in a "glorious mess." Congress the Administration should draw on expertise not did not intend it to be used to require reductions or only from the EPA, but also from agencies having limitations on greenhouse gases blamed for global expertise in and responsibility for the economy and warming or climate change, which arises from the electric system. The Administration should global concentrations of GHGs, caused from sources Produce an objective cost-benefit analysis of all of around the world. Without a change in direction, EPA's current and planned regulation. EPA and the courts risk forcing untenable requirements on the electric industry at the same MMUA further urges the EPA, Congress, and the time the agency is already struggling to address White House not to impose any new air quality an extensive menu of costly air pollution problems. regulations until the impacts of current regulations The nature of the climate change issue demands a can be absorbed. lifferent response. 2013 Federal Position Statements/ 15