A number of major environmental groups, including the Natural Resources Defense Council, have filed a joint comment with three utilities (em Public Service Electric and Gas Co., Atlantic Electric Co., and The United Illuminating Co. (em concerning the FERC's environmental impact statement (EIS) in its open-access electric transmission Notice of Proposed Rulemaking (NOPR). (At its July 12 meeting, the FERC had announced that it would add an EIS to its previously announced NOPR.)The joint comment requests the FERC to use the EPA-approved, photochemical Urban Airshed Model (IV or V) to measure ozone impacts and compare alternative mitigation strategies. It further asks that the EIS offer a review of environmental impacts, including 1) quantifying increased emissions of nitrogen oxide (NOx) and other pollutants resulting from
redispatch under open access, 2) estimating increases in ozone levels in each nonattainment area,
3) identifying the economic burdens of additional pollution-control measures to offset increased ozone levels in each nonattainment area, and 4) providing a full analytical assessment of alternative mitigation strategies. Such strategies involve:
s Wheeling. Applicants for wheeling and interconnection should demonstrate that granting requests will not increase NOx or ozone in downwind states.
s Exports. Any generator intending to sell power outside its original service area should certify that its emissions are equal to or less than limits imposed on similar operations in any downwind jurisdiction that may be affected.