On June 26th, the Comments Workgroup submitted comments to the docket. The proposed requirements, which are strictly limited to new sources, would require new fossil fuel-fired EGUs greater than 25 megawatt electric (MWe) to meet an output-based standard of 1,000 pounds of CO2 per megawatt-hour (lb CO2/MWh), based on the performance of widely used natural gas combined cycle (NGCC) technology. Instead, ICAC supported categorization of fossil units by fuel and subcategorization by coal-type within a coal-fired category. ICAC also disagreed with EPA’s basic premise of the commercial availability of carbon capture and storage (CCS) technology that would be required by new coal plants to meet the proposed standard.
For more information and a copy of the comments via PDF, please visit this website: