                   Intermountain West and Pacific Northwest
                            Environmental Advocates



April 6, 2014 

The Honorable Janet McCabe
Assistant Administrator for Air and Radiation
US Environmental Protection Agency
1200 Pennsylvania Avenue, N.W. 
Washington, DC 20460

The Honorable Joseph Goffman
Senior Counsel to the Assistant Administrator for Air and Radiation
US Environmental Protection Agency
1200 Pennsylvania Avenue, N.W. 
Washington, DC 20460

The Honorable Shaun McGrath
EPA Region Eight Administrator
1595 Wynkoop St. 
Denver, CO 80202-1129

The Honorable Dennis McLerran
EPA Region Ten Administrator
1200 Sixth Avenue, Suite 900 
Seattle, WA 98101

Dear Madam and Sirs:
The undersigned organizations appreciate the challenges facing the President, EPA and State air and utility regulators in proposing to regulate and abate greenhouse gas emissions from existing power plants under Section 111(d) of the Clean Air Act.  
We share a strong interest in identifying a coordinated compliance pathway for the interconnected Pacific Northwest and Intermountain West states, and perhaps beyond.  Among the reasons for promoting coordination among states in our region is the particular architecture of our regional electrical power system, which involves sources in the Intermountain West exporting substantial quantities of power to loads in the Pacific Northwest. In addition, we seek an outcome that achieves the necessary steep reductions in power plant emissions, consistent with what climate science demands to urgently arrest and reverse the mounting and perilous quantities of greenhouse gases accumulating in the earth's atmosphere.  It is incumbent upon all of us to achieve those reductions in a cost-efficient manner for our region's consumers and communities.

Several different approaches are available to achieve these objectives. The attached White Paper, prepared for Natural Resources Defense Council, discusses how different approaches might function within our region.  The White Paper introduces the concept of "multilateral State-to-State agreements" as one approach to coordination across the states in our region.  While we remain open to a variety of different approaches, we encourage EPA to consider the approach that the White Paper presents and to reserve flexibility in the draft rule to accommodate such state-to-state agreements.
We are happy to continue discussing this and other concepts that will enable a rigorous, fair, economical and effective 111(d) rule.

Sincerely,


Climate Solutions
Environment Oregon
Environment Washington,
Idaho Conservation League
Montana Environmental Information Center
Natural Resources Defense Council
Northwest Energy Coalition
Oregon Environmental Council
Powder River Basin Resource Council
Renewable Northwest Project
Snake River Alliance
Utah Clean Energy
Washington Environmental Council
Western Resource Advocates


