Declaration on Effluent Limitation Guidelines
Synapse provided an expert declaration from Devi Glick to support the Sierra Club and other environmental parties in responding to a motion from the Southwestern Electric Power Company (SWEPCO), along with other utilities and state petitioners, who were seeking to halt (stay) the United States Environmental Protection Agency (EPA) implementation of the Effluent Limitation Guidelines (ELG). Synapse’s declaration focused specifically on the issues of:
- Whether compliance with the rule will require significant incremental resource planning modeling and analysis beyond the standard practices of the utilities involved;
- Whether the timeline for compliance is sufficient for these utilities to install necessary technologies or retire/convert their existing coal plants to gas;
- The magnitude of the cost of compliance relative to the value of the utilities seeking the stay.
The declaration supported the respondents' position that the effort required to model compliance with the ELG rules, and any other new or proposed regulation, should not be substantial or require particular effort beyond the routine programming of specific regulations into the model. It also indicated that the timeline for compliance was sufficient and that the cost of compliance is minimal relative to the total value of the utilities involved