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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 (forthe Carbon Pollution Standard for Modified Sources)Docket No. EPA-HQ-OAR-2013-0602 (forthe Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (forthe Carbon Pollution Standard for Modified Sources) Thank you for holding these public hearings and for the opportunityto speaktoday. Myname 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 ofenergy 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 ofanalyzing the rule and the manytechnical 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 mustbe balance, fair and take into consideration the impact to communities, economic development, health,jobs and the price ofelectricity. This proposedrule is verylikelyto significantlyincrease electric powercosts across the country. It will do so, in part, bychanging 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 largelyeliminateeconomic dispatchin favor ofenvironmental dispatch, withoutregardto 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 ormore. EPA must understand that ifthose natural gas units were the most cost-effective, they would already be running at higher levels. EPA also assumes that Commentsfrom Atlanta Chapter

### IAmerican Association of Blacks in EnergyDocket No. EPA-HQ-OAR-2013-0602 (forthe Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (forthe Carbon Pollution Standard for Modified Sources) generation will be shifted to renewable energy - wind, solar, and possibly biomass. While AABE supportsrenewableenergy, it mustbe cost-effective. Because it eliminates the focus on cost of energy resources, EPA's proposed carbon plan will, not onlyincrease electricity prices, but also the price ofnatural gas. Natural gas is also used by industry, in transportation, and to heat our homes. Basic principles ofsupply 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 countyand will drive more industry and manufacturingjobsoverseas. The bottom**line~** Higher electric bills, higher heating bills, more expensive goods and services, and fewerjobs. All ofthese have a disproportionate impacton 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 ofcost increases and do not heap the costs on those least able to bearthem. We support a holistic approach to meet the rising demand of electricity. In 2012, electricity accounted for 32 percent ofthe Total Greenhouse Gas emissions by economic sector.; Industry and Transportation, combined, accounted for 48% of the Total Greenhouse Gas emissions by economic sector. ii Byfocusing on electricity only, the ruling ignores othercontributors to GHG emiSSIOnS. Comments from Atlanta Chapter

### I American Association of Blacks in EnergyDocket No. EPA-HQ-OAR-2013-0602 (forthe Clean Power Plan for Existing Sources) and EPA-HQ-OAR2013-0630 (fortheCarbon Pollution Standardfor Modified Sources) While it's not a silverbullet, broad deployment ofenergy efficiency measures will be important to reduce the impact ofrising 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. Energyefficiencymeasures andeducation mustbe made availableto small businesses and low and fixed income families and individuals because they are the ones thatwill benefitthe mostfromthe 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 andprosperityfor all Americans. This proposal does not strike thatbalance. Thank you for the opportunity to providecomments.

1 Source: EPA 11 Source: EPA

Commentsfrom Atlanta Chapter

### IAmerican Association ofBlacks in Energy