Notes for EPA Hearing: 

My name is Alex Blackmer and I am speaking as President of the Colorado 

Renewable Energy Society. I want to thank you for coming to Denver, and thank the 

EPA for taking this small but important step towards regulating carbon in our 

country. I say small, because it is only the very beginning of what is needed to 

prevent our planet from being overwhelmed by the impacts of global climate change 

caused by our uninhibited combustion of Fossil Fuels, and I say important because it 

shows leadership which in the past has been lacking nationally, both in facing the 

issue of human caused climate change and in acting to mitigate it's effects. While 

this is by no means a perfect proposal, it is a positive step towards reining in our 

species' inclination to soil the nest in which we have been raised. 

I would hold that contrary to what some of my colleagues in the electrical 

generation industry might believe, this is a very moderate proposal which at best 

will represent a baby step towards what the future of carbon regulation will look 

like. In fact, much of the 30% reduction in carbon produced by electrical generation 

from 2005 levels which these rules mandate has already been achieved by many 

states. According to the EPA's own documentation a combination of energy 

efficiency, renewable energy and gas power plant technology has already achieved a 

13% reduction from 2005 levels in current electrical based carbon emissions. This 

brings us nearly half of the way to achieving the proposed nationwide goals before 

we even begin. I believe that we can and will far outstrip the EPA goals in this 

proposal, much as many states including Colorado continue to surpass the goals they 

have outlined in their renewable energy standards due to the success that the 

renewable energy and energy efficiency industries have achieved by working in 

partnership with the electrical generation industries. 

In the US, power plants are the largest single source of greenhouse gas 

emissions, coming in at 38%, with 3/4 of that directly attributable to burning coal. The 

average age of their electrical generating fleet is 42 years old, with 11% of their 

plants being over 60. How many technologies from 60 or even 40 years ago remain 

viable today? The coal industry needs to be aware that their product is in danger of 

becoming as obsolete and outdated as the dinosaurs which in their dying created 

the fuel we burn today. The coal industry needs to either find a way to burn their 

product without massive amounts of damaging emissions, or work to find 

sequestration strategies that will safely transform their emissions into a non lethal 

by product. This EPA proposal is asking them to take a small step in that direction. If 
the coal industry cannot develop the technologies to effectively achieve this, they 

will and should become obsolete. 

Other economic and regulatory forces are clearly leading in the same direction. 

Wind Energy is already at parity or below the cost of coal in many instances, and 

solar energy is well on its way with cost decreases of over 40% in the last 3 years 

alone. This set of proposed rules from the EPA echoes the market trend away from 

the coal industry as it stands today, reinforcing the global movement away from 

fossil fuel consumption and towards cleaner and more sustainable renewable energy 

use. 

While the EPA rules may be seen by some as not going far enough, and are 

criticized by others for having no effect on the vast carbon emissions of China and 

India, I believe they are an important first step domestically and put the United 

States of America in a leadership role globally. While they are not as demanding as I 

or many others would like, they demonstrate a doable first step at home, and show 

other nations that we as a country are serious about taking steps to reduce the 

carbon emissions that are threatening our planet. For that reason I would like to 

endorse and support in any way possible this small but important step towards 

regulating an extremely dangerous pollutant. 

Alex Blackmer 

a.blackmer@cres-energy.org