Montana Public Service Commissioner Travis Kavulla told the House Energy and Power Subcommittee that the Western region is not prepared to predict how the proposal might affect reliability in time for an Oct. 16 deadline for comments. He said realities diverge from the goals the EPA believes states can achieve.

…The EPA essentially ignores the details of a  state’s situation, and instead applies a cookie-cutter formula that uses sweeping regional or  national assumptions about the degree to which each individual Building Block is achievable. The result is that any given state goal is predicated on a so-called Best System of Emission  Reduction that ignores the realities of commercial relationships, the way in which generators are  dispatched, the footprint of regional markets, the status of individual power plants, the robustness  of the electric and natural gas transmission system, and potential energy efficiency savings on  the ground.

See his full testimony here. Or look for the committee video here.

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