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API comments filed on March 18, 2019 re: the U.S. Environmental Protection Agency’s Proposed Amendments to the Standards of Performance for Greenhouse Gas Emissions from New, Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units

Although EPA is not proposing changes to the current NSPS for natural gas-fired electric utility generating units (“EGUs”), API believes it is important to provide these comments to describe the vital role of natural gas in power generation and to ensure that the administrative record reflects that natural gas is reliable, abundant, affordable, and environmentally beneficial. API also wants to ensure that the NSPS recognizes the importance of combined heat and power (“CHP”) units and simple cycle combustion turbines. We believe these units should be excluded from the applicability of the NSPS based on their importance to energy efficiency, the expansion of renewable energy, and reliability.



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