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December 13, 2011
Brattle Principal Marc Chupka Submits Comments to the Federal Energy Regulatory Commission Suggesting an Alternative Approach to EPA Air Regulations

Brattle Principal Marc Chupka recently submitted comments to the Federal Energy Regulatory Commission (FERC), in which he suggests an alternative approach to the Environmental Protection Agency’s (EPA) impending Maximum Achievable Control Technology (MACT) regulation. In his comments, Mr. Chupka explains that MACT, which requires the entire coal- and oil-fired generation fleet to “comply or retire” at a specific date, will lead to a significant amount of generating unit retirements and planned outages in order to complete pollution control installations by the industry-wide compliance deadline. To preserve reliability of the power grid while making progress on emissions reductions, Mr. Chupka proposes keeping a firm compliance deadline for all units, but offering tradable credits for every unit that retires before the compliance deadline that can be used to keep other units operating beyond the deadline, a particularly valuable option for units that might take several years to complete retrofits. He suggests a MW-time credit, which would equal the MW capacity unit times the amount of time that the unit retired before the compliance date. Mr. Chupka explains that his proposal “could significantly reduce the risks of severe reliability problems, while assuring steady and perhaps accelerated environmental progress.” Mr. Chupka’s comments are available for download below.