Principles for an Alternative to BART

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Principles for an Alternative to BART:

Principles for an Alternative to BART

Uncertainty :

Uncertainty Plant Emissions BART: NOx , PM, SO2 Others: Hg, Metals, Organics, CO2 Mine operations Local effects Plant and Mine Leases Land Leases Federal Approval Future of Jobs and Income Energy Supply Base load Plant ownership LADWP Water Costs CAP Tribal Non-tribal ag Settlement Fund

Opportunity:

Opportunity Movement toward renewable energy reduces more risks over the long run Planning of jobs and income Better predictions of energy and water costs Better environmental results by anticipating rather than reacting to the stream of anticipated rules or requirements Less administrative burden and litigation

Why Now?:

Why Now? LAWDP sale Opportunity for partnership in their need for cleaner energy Lease renewals Opportunity for less contentious process Federal energy goal Chance to establish a pathway to a secure source of power for water distribution and settlement funds

Considerations:

Considerations Costs of SCR is not even for all units Lower costs to meet BART and other rules Stronger “Better than BART” case Earlier, more protective multi-pollutant reductions Additional protections inform “better than BART” Federal trust responsibility Tribal ownership of DOI replacement power