® 

American Association of Blacks in Energy® 

ATLANTA CHAPTER 

Comments regarding: 

Docket Number: EPA-HQ-QAR-2013-0602 (for the Clean Power Plan for 

Existing Sources) 

Docket Number: EPA-HQ-QAR-2013-0630 (for the Carbon Pollution 

Standard for Modified Sources) 
Docket No. EPA-HQ-OAR-2013-0602 (for the Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (for the Carbon Pollution Standard for Modified Sources) 

Thank you for holding these public hearings and for the opportunity to speak today. 

My name is Rodney J. Russell and I am the President for the Atlanta Chapter for the American 

Association of Blacks in Energy. Today, I am representing our chapter. AABE is a national 

association of energy professionals founded and dedicated to ensure that African Americans and 

other minorities has a voice in the development of energy policy and related environmental 

ISSUeS. 

While we are still in the process of analyzing the rule and the many technical support documents, 

AABE has some significant concerns about EPA's proposed clean power plan. We recognize 

that there is no simple solution for addressing the Climate Change issue with regard to 

Greenhouse Gas (GHG) emissions. However, we believe any approach must be balance, fair and 

take into consideration the impact to communities, economic development, health, jobs and the 

price of electricity. 

This proposed rule is very likely to significantly increase electric power costs across the country. 

It will do so, in part, by changing the way our nation's electric generation resources are utilized 

to meet demand. Currently, generating units are dispatched based primarily on economics to 

ensure that the most cost-effective generating units arc dispatched first. This rule appears to 

largely eliminate economic dispatch in favor of environmental dispatch, without regard to cost. 

For example, to develop the state-specific goals, EPA assumes that utilities will shift generation 

from coal-units to natural gas units, and EPA assumes natural gas units across the country will 

run at a 70% capacity factor or more. EPA must understand that if those natural gas units were 

the most cost-effective, they would already be running at higher levels. EPA also assumes that 

Comments from Atlanta Chapter I American Association of Blacks in Energy 
Docket No. EPA-HQ-OAR-2013-0602 (for the Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (for the Carbon Pollution Standard for Modified Sources) 

generation will be shifted to renewable energy - wind, solar, and possibly biomass. While 

AABE supports renewable energy, it must be cost-effective. 

Because it eliminates the focus on cost of energy resources, EPA's proposed carbon plan will, 

not only increase electricity prices, but also the price of natural gas. Natural gas is also used by 

industry, in transportation, and to heat our homes. Basic principles of supply and demand tell us 

that increased demand for natural gas in the electric sector will increase gas prices. Increasing 

the cost of electricity and natural gas will increase the costs of goods and services across the 

county and will drive more industry and manufacturing jobs overseas. 

The bottom line~ Higher electric bills, higher heating bills, more expensive goods and services, 

and fewer jobs. 

All of these have a disproportionate impact on those who are least able to manage those impacts. 

That is, our small business owners and families and individuals who are on a fixed income or 

low income. 

We need to make progress on our climate change goals and commitments, but we must find 

solutions that minimize the risk of cost increases and do not heap the costs on those least able to 

bear them. 

We support a holistic approach to meet the rising demand of electricity. In 2012, electricity 

accounted for 32 percent of the Total Greenhouse Gas emissions by economic sector.; Industry 

and Transportation, combined, accounted for 48% of the Total Greenhouse Gas emissions by 

economic sector. ii By focusing on electricity only, the ruling ignores other contributors to GHG 

emiSSIOnS. 

Comments from Atlanta Chapter I American Association of Blacks in Energy 
Docket No. EPA-HQ-OAR-2013-0602 (for the Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (for the Carbon Pollution Standard for Modified Sources) 

While it's not a silver bullet, broad deployment of energy efficiency measures will be important 

to reduce the impact of rising utility bills. AABE strongly supports energy efficiency and serves 

as a resource on this issue for energy consumers, especially in underserved communities. But 

we can't do it alone. Energy efficiency measures and education must be made available to small 

businesses and low and fixed income families and individuals because they are the ones that will 

benefit the most from the energy savings. 

We recognize that there is no simple solution for reducing GHG emissions. We believe the best 

strategy will strike a balance between cost-effective emission reductions and economic growth 

and prosperity for all Americans. This proposal does not strike that balance. 

Thank you for the opportunity to provide comments. 

1 Source: EPA 11 Source: EPA 

Comments from Atlanta Chapter I American Association of Blacks in Energy