Luminant Comments on EPA Clean Power Plan

Why the plan is legally and technically flawed and how it will threaten reliability and increase costs for consumers


In filing comments with the Environmental Protection Agency, Luminant wraps up a rigorous analysis of the Clean Power Plan that began after the agency announced the proposed rule in June.

Luminant spent countless hours drilling down in the data, tracking the methodology and uncovering how the EPA reached its emission guidelines. And we came to the conclusion succinctly described in the foreword – the “EPA’s plan is not a workable plan.”

You can read in the executive summary (page vii) and in detail deeper in the comments why we think the EPA proposal should be withdrawn because, “the fundamental assumptions underlying EPA’s methodology are flawed and do not hold for Texas’ competitive, intrastate electricity market.”

Throughout the more than 100 pages plus appendices, our comments lay out and back up why the Clean Power Plan is legally and technically flawed and how it will threaten reliability and lead to much higher costs for consumers.

There is a better way, though. As we conclude, the “EPA should withdraw its proposed plan and partner with state regulators and the power sector to implement a plan that works for all of us.”

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