July 29, 2014 

Docket No. EPA-HQ-OAR-2013-0602 

Comments on Clean Power Plan for Existing Sources 

Thank you for allowing me to comment on the proposed Clean Power Plan. 

My name is Cliff Kotnik. My family has lived in the Colorado Springs community for 20 years. On June 

12th of last year we received a reverse 911 call telling us to evacuate our home immediately. The 

wildland fire now known as the Black Forest Fire was spreading out of control in the direction of our 

neighborhood. What followed was a very traumatic time for us and thousands of other evacuated 

residents. My family was one of the lucky ones. Our home was not damaged. However, nearly 500 

structures were destroyed and two people were killed. 

2013 had a very hot, dry spring. Colorado Springs enacted drought triggered mandatory watering 

restrictions (https://www.csu.org/Pages/news20130326.aspx). Temperatures soared above 100°F in 

Denver on June 11, the earliest it has ever reached triple digits. 

The recently published "National Climate Assessment Report" contains a relevant key message for the 

southwest region of the United States (http://nca2014.globalchange.gov/highlights/regions/southwest): 

"Increased heat, drought, and insect outbreaks, all linked to climate change, have increased 

wildfires." 

Just a year earlier, Colorado Springs experienced very similar conditions and saw the Waldo Canyon fire 

spread out of control, take two lives and destroy 346 homes. 

The Rocky Mountain Insurance Information Association estimates the total insured losses from these 

two fires at $875 million. (http://www.rmiia.orecatastrophes_and_statistics/catastrophes.asp) 

The Martin Drake power plant, in the heart of the downtown Colorado Springs, is a 50 year old coal fired 

power plant and part of Colorado Springs Utilities' portfolio. At the direction of the City Council, who 

serve as the board of directors for the Utility, an independent consultant conducted a study of various 

options for decommissioning the Martin Drake facility. The consultant issued their final report at the 

end of 2013 (http://draketaskforce.net/hdr_study). 

The study estimated the net present value of the direct financial costs for all of the Utilities' power 

generation over a 30 year time horizon for a dozen decommissioning scenarios. These costs were 

compared to a base case of continuing operation of Martin Drake for 20 years. The study also estimated 

net present value of the indirect social and environmental costs of the various decommissioning options 

over the same 30 year period. There were many components of these costs, but greenhouse gas and 

critical air contaminants were the two largest. 

The study concluded that, given the age of Martin Drake, it is not feasible to continue to operate it for 

20 more years. It was also determined that the indirect costs were almost as large as the direct financial 

costs. 

Two scenarios allowed decommissioning in 6 and 9 years, adding natural gas or a mix of wind and 

natural gas generation. These two scenarios increased direct cost by 4.8 to 5.4% while decreasing 
indirect costs by 14-19% - three to four times the direct cost increase. While these direct cost increases 

are not trivial, it must be realized that Colorado Springs Utilities prides itself on having electric rates 20% 

lower than comparable utilities along the Front Range. Hence, this aging coal plant could be 

decommissioned while still easily allowing the Utility to maintain below average rates. 

You would think that Colorado Springs City Council having just witnessed firsthand the trauma and 

destruction from two back to back wildland fires and seeing the results of this study would quickly move 

to create a decommissioning plan. However, it is obvious from public comments that direct financial 

costs far outweigh the indirect social and environmental costs for a majority of the council. Executives 

in the Utility state they can keep Martin Drake operating for another 30 years. 

Colorado Springs is just one of hundreds of communities across the country with similar scenarios 

playing out. Climate change impacts are becoming obvious and very costly. The cost to change the 

electric power generation mix is manageable. Yet without these proposed greenhouse gas regulations 

our power generation mix will remain dominated by coal because there is insufficient reason to 

change. Please proceed to finalize and enforce these regulations as quickly as possible. 

Thank you. 

Cliff Kotnik 

3550 Pitch Pl. 

Colorado Springs, CO 80908 

clkotnik@att.net