Tag Archives: NODA

EPA’s Clean Power Plan: Potentially New and Improved?

On Tuesday, EPA issued a Notice of Data Availability, requesting further comment on some specific issues that have been raised since it published its draft Clean Power Plan in June.  My immediate reaction?  My head hurts.

I don’t mean to trivialize the implementation issues that would likely arise if Congress enacted either a cap-and-trade system or a carbon tax, but they’ve got to pale in comparison to the Rube Goldberg-like 2014-09-08-401kfeedisclosuresystem that’s going to be in place once EPA promulgates a final rule. … More

EPA Issues a § 316(b) Notice of Data Availability: Even Edison Electric Is Impressed

Late last week, EPA issued a Notice of Data Availability concerning its proposed rule for cooling water intake structures at existing facilities. The NODA stated that, since it had issued the proposed CWIS rule, it had received more than 80 studies providing additional data on CWIS structures at existing facilities. Those studies have led EPA to consider potential revisions to the rule prior to promulgation.

Some of the specific revisions now under consideration include:

  • The addition of site-specific impingement mortality controls
  • Compliance with impingement mortality limitations based on defined technologies such as closed cycle recirculating systems
  • Streamlined permitting for modified traveling screens
  • Clarification of credit for existing technologies
  • Potential limited exemptions for facilities with low impingement rates

In response,… More