### Testimony of Keith Schue, for Sustainable Otsego,

on the EPA Clean Power Plan Proposed Rule dated June 2, 2014

Washington, D.C., July 30, 2014
My name is Keith Schue, and I am here today on behalf of Sustainable Otsego, an organization in upstate New York dedicated to healthy communities and renewable energy. We look forward to the day when our nation and our planet is no longer dependent on a dwindling supply of fossil fuels that require extreme means of extraction—blowing up mountains for coal or shattering bedrock for gas. We would love to tell you that we think this "Clean Power Plan" is a bold initiative with strong measures to tackle the serious problem of climate change. Unfortunately, we can't do that. Its advertised 30% goal falls far short of the President's Copenhagen pledge for a 42% reduction in U.S. emissions by 2030, and 83% by 2050. The rule looks backwards to 2005 to take credit for reductions caused by a weak economy and greater dependence on fracked gas (which I'11 get to in a moment). And it sets lukewarm targets for states, going easy on those with the greatest emissions and exempting power plants in territories and reservations completely (including, for example, the Four Corners plant in New Mexico which is among the worst polluting). Disturbingly, the rule ignores the greatest opportunity for tackling climate change and creating jobs by essentially leaving renewables like wind and solar on the shelf. Rather than challenging states to do better than existing renewable portfolio standards, it lowers the bar, suggesting goals for some states that are actually less than what they have already achieved today. With this testimony, I'm submitting a chart by Climate Action Tracker which shows that this plan does not even come close to achieving America's share of greenhouse gas reductions required to remain under the 2 degree Celsius temperature rise necessary to avoid the worst impacts of climate change. l

8,000

7,000 n N 6,000 O u

~ 5,000 c 0 4,000 N

a E 3,000

~ x 2 2,000 m i. 0 1 - 1,000 —Historic emissions, excL LULUCf

—2013 Current Policy projections

—Updated Current Policy projections including US Clean Power Plan Pledge pathway

O "t_ 1T1_' . , ' 1
1990 1995 2000 2005 2010 2015 2020 2025 2030

' Bill Hare, Marie Lindberg, et al. Below 2 degrees C or 1.5 degrees C depends on rapid action from both Annex I and NonAnnex I countries, Climate Action Tracker, Policy Brief, June 4, 2014-revised June 7, 2014. http://climateactiontracker.or assets/publications/briefing_papers/CAT Bonn policy updateJun2014-final revised.pdf

Page 1 of 3Another problem is that reduction targets for each state are measured per unit of energy (meaning

pounds of CO2/MWh). Like a diet that limits calories per cookie, but not the number of cookies, this won't work in the long run because it allows emissions to rise as the demand for power goes up (for example as populations grow or economic development leads to more manufacturing). Targets must be based on the total amount of greenhouse gas entering the atmosphere. We are also concerned about implementation. Lacking clear regulatory requirements, the rule relies on states to interpret targets, invent their own programs, and enforce them—including states which are dominated by the absurd politics of climate change denial. Thus the rule invites weak targets to be further watered down, or simply ignored. Despite these shortcomings, we understand that it may be desirable—especially in today's political climate—to at least think of this rule as a"good start" (maybe a baby step, but at least one in the right direction.) We too would prefer to look at it that way. But honestly we can't. And the reason we can't is because this proposed rule injects adrenalin into the fundamentally flawed notion that natural gas is a"clean" source of energy. Right now in New York, concerned families, doctors, nurses, and scientists are engaged in an epic battle against an industry that wants to frack our state and build the infrastructure for long-term dependency on fracked gas. We have seen our friends in neighboring Pennsylvania get sick; we have read the reports of contaminated wells and air pollution; and we have witnessed the damage to roads, property, and communities caused by the ruinous boom-bust cycle of this industry. We also know that when you consider lifecycle emissions--not just carbon dioxide, but also methane lost during production, processing, and transmission—natural gas is NOT any better than coal from the standpoint of climate change. 2 As explicitly stated in Building Block #2 of the rule and also allowed for in #3, the effect and intent of this plan is to accelerate the use of fracked gas and facilitate the development of gas-fired power plants. That's a huge problem. Real-world measurements, including by the National Oceanic and Atmospheric Administration, indicate that at least 3% and potentially more than 7% of natural gas is lost to the atmosphere—far higher than EPA estimates. In addition, federal agencies continue to underestimate the global warming potential of methane, which according to the Intergovernmental Panel on Climate Change is 86 times more potent as a greenhouse gas than carbon dioxide over 20 years—the most critical timeframe affecting the future of our planet due to impending tipping-point thresholds. Even if the EPA eventually considers separate rules for methane, this plan for power plants—scheduled to be adopted next year—is defective because it would have states and utilities make decisions about electricity generation based on one thing only: carbon dioxide emissions from combustion. And that will lead to bad decisions, as seen in the plan's own Regulatory Impact Analysis. Contrary to how it's been advertised, the plan is predicted to increase the amount of electricity generation from fracked gas in

z Robert W. Howarth, A Bridge to Nowhere: Methane Emissions and the Greenhouse Gas Footprint of Natural Gas, Eneygy Science & Engineering, April 2014. http://onlirnelibrary.wiley.com/doi/10.10o2/ese3.35/pdf
Page 2 of 32020 by nearly ten times the meager boost given to renewables, and it would have almost no effect on

the amount of renewables in the country by 2030. Perhaps most damaging, by accelerating investments in fracked gas right now, the plan could tip the scales toward fossil fuels for decades to come. Once new gas-fired plants are in operation, there will be less incentive for utilities to reinvest in renewables since the massive capital outlay for gas infrastructure will have already occurred. For the record, I am submitting a recently assembled compendium of fully-cited reports, studies, and articles compiled by Concerned Health Professionals of New York, which describe the risks and harms of fracking, including its impact on climate change. 3 Simply put, juggling between fossil fuels will not achieve the big changes necessary to save ourselves from climate catastrophe. Switching from coal to gas is, at best, a move sideways at a time when we urgently need to move forward. The good news is that significant advancements have been made in renewable technology, and in storage. So instead of adopting a plan that seeks to replace one dirty fossil fuel with another, we urge the EPA to replace this rule with one that sets aggressive targets for the advancement of zero-emission sources of energy, including renewables powered by wind, water, and sunlight. The bottom line is that we will not be able to solve the climate crisis as long as most of our energy still comes from fossil fuels. We have the ingenuity, and we have the moral imperative to do right by future generations who will inherit this Earth. What we need now is leadership. Thank you.

Respectfully submitted,

Keith Schue 9 Maple Avenue Cherry Valley, NY 13320 607-264-5024 (home/office) 407-470-9433 (cell)

3 Compendium of Scientific, Medical, and Media Findings Demonstrating Risks and Harms of Fracking (Unconventional Gas and Oil Extraction), Concerned Kealth Professionals of New York, July 10, 2014. http://concernedhealthny.or compendium/

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