LPPC Comments on EPA’s Proposed Revisions to the Effluent Limitations Guidelines Rule
The Environmental Regulations Task Force submitted these detailed comments to EPA supporting proposed revisions to the Clean Water Act Effluent Limitations Guidelines (ELG) for coal-fired power plants. LPPC endorses extending the Notice of Planned Participation (NOPP) election deadline to 2031 and the zero-liquid discharge (ZLD) compliance deadline to 2034, citing grid reliability concerns, supply chain disruptions, and inadequate amortization periods as justification. LPPC also supports the proposed site-specific flexibility mechanism allowing plant-by-plant compliance adjustments. In the second half of the comments, LPPC provides substantial technical and cost data, anchored by Santee Cooper’s experience at its Cross Generating Station, challenging the feasibility of ZLD technologies, demonstrating that EPA’s cost model underestimates actual compliance costs by a factor of 25 or more, and arguing that the marginal environmental benefit of eliminating wastewater that already meets Safe Drinking Water Act standards does not justify costs exceeding $248 million per facility.
