As part of the Bush National Energy Plan, EPA was instructed to undertake a "90 Day Review" of New Source Review (NSR) regulations and report to the President on August 17, 2001 on "how NSR is affecting the energy industry."  One month later, it will make more specific recommendations as to possible changes that could be made to NSR.

While EPA's review includes long-term options like complete legislative overhaul of the Clean Air Act, it is likely that it will consider many of the more short term options available to it under existing regulatory/administrative authority. 

In the process of developing its recommendations, EPA published a "Background Paper" and opened a docket soliciting public comment on a broad range of issues pertaining to NSR.  EPA has also held public hearings and numerous stakeholder meetings.  Enron participated in stakeholder meetings, and also submitted written comments -- as part of several organizations (EPSA, Clean Power Group, INGAA) and individually.  

The attached Enron comments, submitted last Friday, July 27,  reflect input from numerous commercial sources.  NSR impacts a number of commercial interests, including:  
development, siting and finance of new power plants;
origination activities with customers seeking to upgrade, expand or modify power facilities;
trading/risk management for power, gas, coal, emissions allowances;
finance/deployment of emissions control technologies;
industrial markets such as forest products, steel, refining/chemicals
power generation and natural gas pipeline operations

We will continue to have opportunities to provide input into the process through EPA and the Administration, and would welcome further comments or examples of impact on our businesses.  Please let me know if you have any questions, or would like additional background information.  I will keep you posted on the progress of this issue as developments occur.

 

Jeffrey Keeler
Director, Environmental Strategies
Enron
Washington DC office - (202) 466-9157
Cell Phone (203) 464-1541