Bond explained the proposed rule will “impair the reliability and affordability of domestic energy supplies by severely diminishing the diversity of electricity generation sources” and will expose U.S. consumers and businesses “to less reliable, more expensive and more volatile electric generation sources.” At the heart of the EPA’s proposal is the unprecedented creation of a source category that unlawfully combines coal, oil and gas plants. The proposal further focuses on carbon capture and storage—technology not commercially available—for coal-based generation, while stipulating no technology requirements for other fuel sources.

Bond urged the agency to withdraw its proposed rule in favor of a “practical and achievable standard for coal- and natural gas-fired units that is in step with a true ‘All of the Above’ energy strategy.”