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<br />Minnesota Municipa/ Uti/ities Association <br />Air Quality <br />Position Statement <br />The Clean Air Act (CAA) was passed in 1970 to achieve and maintain healthy air quality <br />in the United States. As amended, CAA addresses control standards for new generating <br />plants, protection of visibility in pristine areas, and control of acid rain precursor <br />emissions. <br />CAA currently includes multiple programs designed to reduce the emissions of certain <br />pollutants for power plants. The large number of programs, their conflicting compliance <br />deadlines, and the cost of pollution control technologies have increased the costs <br />associated with generating electric power from fossil fuel plants. To address this <br />patchwork of regulatory programs, the passage ofmulti-pollutant control legislation that <br />amends and updates CAA is an important issue for the power generation sector. <br />As Congress considers clean air reforms, any legislation to alter the current <br />regulatory scheme for power plants should include the following concepts to achieve <br />a proper balance of economic, energy and environmental goals: <br />N • Limit only the emissions of sulfur dioxide (SOZ~, nitrogen oxides (NOx), and <br /> mercury (Hg). Some members of Congress support legislation that would limit <br /> emissions of carbon dioxide (C02), which would be extremely costly and could <br /> impair the security of the nation's electricity supply. A COz program involving <br />o continued research on climate change and voluntary reduction offers a better <br />o approach to dealing with this concern. <br />N • Allow plant modifications that improve efficiency without increasing <br />o emissions. The continuing uncertainty over when New Source Performance <br /> Standards apply to plant modifications must be resolved. New Source Review <br />Z (NSR) should not be used to prevent plant owners from making modifications that <br /> <br />T would increase plant efficiency and output without increasing emissions. <br /> • Rely on regulation or legislation that provides innovative and flexible <br />°' mechanisms for achieving emissions goals. Using market-based programs <br /> similar to the cap and trade system for limiting S02 emissions is a more effective <br /> way to deal with controlling multiple air pollutants than the current, often <br />`° redundant approach to reaching air quality standards. <br /> • Base legislation and regulatory reform on science and cost-effectiveness, <br /> taking into account the impact on energy reliability and security. <br /> Environmental goals are best achieved when those goals are grounded in good <br /> science, supported by the public, and addressed in the most cost-effective mariner. <br /> • Recognize existing "clean plants" and "clean utilities." Ironically, some <br /> proposals would require clean plants to further reduce pollution emissions at the <br /> same reduction rate as dirty plants, forcing customers to pay even higher costs for <br /> incremental improvements with diminishing returns. <br />Minnesota Municipal Utilities Association <br />February 2006 <br />