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  • When considering the lifespan of any changes to an energy supply fleet, the EPA must provide a practical timeline to allow states and utilities to make prudent decisions in order to comply with regulations.
  • The EPA should allow for flexibility and give states and utilities the ability to customize the methods used to meet clearly outlined emission limits.
  • The EPA must revisit its assumptions about coal-fired power plant operations, energy efficiency and the lack of technologies available to effectively and economically capture and store carbon dioxide on a commercial scale. The current models used to develop emission targets are flawed and would significantly impact utilities’ future use of coal-fired generation.