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Framing the Issues

Framing the Issues. Scott H. Segal Bracewell & Giuliani, L.L.P. Electric Reliability Coordinating Council Presentation for Workshop on Power Sector Environmental Regulations October 22, 2010 scott.segal@bgllp.com 202-828-5845. Our Perspective. Who we represent What is ERCC?

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Framing the Issues

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  1. Framing the Issues Scott H. Segal Bracewell & Giuliani, L.L.P. Electric Reliability Coordinating Council Presentation for Workshop on Power Sector Environmental Regulations October 22, 2010 scott.segal@bgllp.com 202-828-5845

  2. Our Perspective • Who we represent • What is ERCC? • Why reliability and affordability?

  3. Simultaneous Implementation of Regs • Coal ash • Utility MACT • Transport • New PSD for Carbon • Ongoing NSR/PSD Enforcement • 1-Hour SO2 • CO2 NSPS • Ozone NAAQS • PM2.5 NAAQS • Regional Haze in SIPs • Other Rules Outside Sector: Boiler MACT & PC MACT

  4. What Could Happen on January 2, 2010? • Regulation of carbon dioxide • Effective construction moratorium • Ongoing litigation • Are the States ready?

  5. Why Rosy Reliability Estimates Are Suspect • Market assumptions • Technological assumptions • Timing • Mitigation • Modeling of fuel prices

  6. Why Should We Care? • Effects of power outages • An anti-industrial policy? • Cost impacts -- regressive features -- minority and elderly communities -- regional differences -- hospitals and schools

  7. What Can Be Done? • EPA should consider overlapping cost estimates • Interagency and administrative process should be more robust • Onset of carbon regulation should be delayed pending legislative treatment of issue • Congressional Review Act should be reformed • Enforcement initiatives should not retard efficiency improvements

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