LPPC Comments on EPA's Proposed MATS Rule Amendments
LPPC’s Environmental Task Force submitted these comments to EPA supporting proposed amendments to the Mercury and Air Toxics Standards (MATS) that would restore compliance flexibility for coal- and oil-fired power plants. Specifically, LPPC endorses reinstating periodic stack testing and continuous parametric monitoring systems (CPMS) as alternatives to the more costly continuous emissions monitoring systems (PM CEMS) mandated in 2024; restoring the Low Emitting EGU (LEE) program that allows well-controlled, low-emitting units to test less frequently; and reverting to the 2012 MATS testing volume requirements, as the 2024 update’s expanded sample run times (over nine hours at full load) create serious operational and dispatch challenges for coal units increasingly operating under load-following conditions. LPPC provides detailed cost data from members showing PM CEMS installation and ongoing compliance costs can exceed ten times those of the alternatives, while arguing that stack testing and CPMS provide equivalent transparency and reliability.
