On May 28, the New Jersey Environmental Justice Alliance and EJ partners across the country submitted comments to the EPA regarding the Power Plant Rules for Existing Natural Gas Plants. The comments reflected a unified effort from EJ organizations to call upon the EPA to address the cumulative impacts of pollution and the disproportionate burden of greenhouse gases and greenhouse gas co-pollutants in EJ communities.

In all, the comments addressed four key areas:

1. Recognizing that retrofitting for carbon capture and hydrogen co-firing must not qualify as a “BSER” (Best System of Emission Reduction) ;
2. Locating other operational mechanisms to increase efficiency, such as heat rate improvements;
3. Ensuring that the EPA provide effective oversight to state implementation of these rules;
4. Demonstrating that facilities sited in EJ communities will not cause or contribute to adverse cumulative impacts as a result of their compliance with the rules;
5. Incorporating a cumulative impacts framework into the rule.

For all questions and concerns regarding these comments, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.