Memo to Docket

To:	Docket for Transport Rule

From:  	Jim Ketcham-Colwill

Office of Air and Radiation, Office of Policy Analysis and Review

Date:  	November 15, 2010

Regarding:  November 12, 2010, meeting with PPL representatives on
Transport Rule

PPL Attendees:		Paulette C. Pidcock

Vice President-Federal Government Relations

PPL 

900 Seventh Street, NW #510

Washington, DC 20001

Reid T. Clemmer

Environmental Supervisor

PPL Services Corp.

Arundhati Khanwalkar

Senior Director, Environmental Management

PPL

EPA OPAR Attendees:  	Rob Brenner, Director

Jim Ketcham-Colwill

Tamara Saltman

PPL representatives requested this meeting with the Office and Air and
Radiation.  PPL representatives expressed general support for the
proposed Transport Rule to replace the Clean Air Interstate Rule, but
expressed strong concern about allocation provisions.

PPL representatives indicated that the company has predominately been a
merchant power provider, (though it recently has acquired a regulated
utility in Kentucky), and that their comments reflect that perspective. 
They expressed concern about the allocation provisions on grounds that
the proposed approach (1) is unfair, (2) disadvantages companies that
have invested in controls previously under the market-based CAIR system
or for other reasons (e.g., in comparison to a heat-input-based
approach, the proposed approach will provide many millions of dollars
less in allowance value to companies plants that are already well
controlled), (3) is based on emissions projections that are not
reliable, and (4) may have negative environmental results because
cleaner plants that previously controlled and receive fewer allowances
may not be dispatched if less-well-controlled plants receive more
allowances and receive a cost advantage from allowance allocations.

