The administration has yet to formally propose the new standard, but a 2012 effort to regulate carbon emissions from power plants explored setting a single threshold of up to 1,100 pounds of carbon dioxide released per megawatt hour.
The utility association thinks that standard should be set for natural gas plants, but bumped up to 1,950 pounds per megawatt hour for coal facilities.
"No commercial [coal] plant can meet 1,100," the association said in the document.
The five officials also asked the EPA to resolve whether it considered carbon dioxide to be a pollutant under the Superfund law and how long emissions monitoring would be required after the power plant closed.
In recent weeks, multiple utilities, energy companies and environmentalists have decamped to the White House to make their voice heard on the upcoming emissions rules.