Advocacy Submitted Comments on Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category

April 5, 2017

The U.S. Small Business Administration, Office of Advocacy (Advocacy), submits a regulatory petition to modify the final Steam Electric Power Plant Effluent Limitations Guidelines (ELG) which imposed technology-based standards to control wastewater under the Clean Water Act (CWA). Advocacy supports the petition to reopen the rulemaking for reconsideration filed by the Utility Water Act Group (UWAG), as it provides the opportunity for regulatory relief for small entities. Advocacy supplements that petition with specific recommendations to alleviate burdens on small entity owned power plants. Regulatory relief in this rulemaking should play a key role in the implementation of the recent Executive Order 13771 on Reducing Regulation and Controlling Regulatory Costs which requires agencies to eliminate unnecessary regulations, and reduce costs on regulated entities. These unduly stringent requirements are likely to force closures of a significant number of coal-fired utilities, and adversely affect mining and utility jobs and rural communities that depend on those plants, without concomitant environmental benefits. Advocacy believes that there are alternatives that would achieve important statutory goals while also providing regulatory burden relief for small entities.

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