Comments on New Source Performance Standards and Emissions Guidelines for Existing Stationary Combustion Turbines

Clean Energy Group (CEG), along with its partner organizations (Slingshot, THE POINT CDC, New York City Environmental Justice Alliance, New York Lawyers for the Public Interest, and Berkshire Environmental Action Team), submitted comments in response to the Environmental Protection Agency (EPA)’s request for comments on key framing questions that will guide future rulemaking for existing natural gas turbines. CEG’s comments specifically address a proposed regulatory approach for power plants used for peaking purposes, also known as “peakers.” Peakers produce some of the highest levels of emissions and are disproportionately located in low-income communities and communities of color, causing these frontline communities to feel the brunt of the resulting pollution and health impacts. CEG and its partners recommend that battery energy storage charged from zero-emission sources or, at a minimum, from the grid when it is cleanest, be used as an add-on control to reduce emissions, as the technology is readily available, cost-effective, complies with existing regulations, and has already been successfully used for this purpose.