Scott H. Segal Bracewell & Giuliani, L.L.P. Electric Reliability Coordinating Council Presentation for Workshop on Power Sector Environmental Regulations October 22,

 Who we represent  What is ERCC?  Why reliability and affordability?

 Coal ash  Utility MACT  Transport  New PSD for Carbon  Ongoing NSR/PSD Enforcement  1-Hour SO2  CO2 NSPS  Ozone NAAQS  PM2.5 NAAQS  Regional Haze in SIPs  Other Rules Outside Sector: Boiler MACT & PC MACT

 Regulation of carbon dioxide  Effective construction moratorium  Ongoing litigation  Are the States ready?

 Market assumptions  Technological assumptions  Timing  Mitigation  Modeling of fuel prices

 Effects of power outages  An anti-industrial policy?  Cost impacts -- regressive features -- minority and elderly communities -- regional differences -- hospitals and schools

 EPA should consider overlapping cost estimates  Interagency and administrative process should be more robust  Onset of carbon regulation should be delayed pending legislative treatment of issue  Congressional Review Act should be reformed  Enforcement initiatives should not retard efficiency improvements