Testimony of George Wilson before the Environmental Protection Agency regarding the Clean Power Plan Denver, Colorado July 30, 2014 Good morning. My name is George Wilson. I am Senior Assistant Business Manager for the International Brotherhood of Electrical Workers Local 111. Local 111 is located in Denver, Colorado but I work out of our satellite office in Craig, on the Western Slope. Local 111's approximately 3,500members are employed in many classifications of work by electric and gas utilities in Colorado with many of our members working for co-ops. Myself and other members of Local 111 are very worried about the effects of EPA's proposed Clean Power Plan on electricity prices, reliability, and jobs. Here in Colorado we have been made painfully aware of what happens when an electricity provider moves away from inexpensive coal-generated power too quickly. Our experience is a real-live test case and I urge EPA to pay attention. As a result of Colorado's Renewable Portfolio Standard, the state has been moving away from coal and towards natural gas and renewables. Some parts of the state, Pueblo in particular, have seen electricity prices rise 26 percent. That may not be a problem in wealthier parts of the state but in Pueblo, where the poverty rate is 18.1 percent, the pain is very real. An article that appeared just last week in the Washington Post titled "How Not to Shut Down Coal Plants" speaks to the pain of Sharon Garcia, a single mother in Pueblo who operates a day care out of her home. Her electricity provider, Black Hills Energy, choose to replace nearly all its inexpensive coal generation with natural gas over a short period of time — the result was a 26 percent increase in electricity rates with more to come with the addition of another gas peeking unit to be built. Local 111 is not the only group who is worried about the high-cost of switching to mostly one fuel. Last week, IHS incorporated; an industry data, custom software, and consulting services company, released a study called "The Value of U.S. Power Supply Diversity." In a nutshell, the report said it is not prudent to put all your eggs in one basket and that the least expensive, most reliable electricity delivery system is one that uses a diverse mixture of fuels. Unfortunately, the Clean Power Plan openly calls for the use of more natural gas generation at the expense of coal. EPA would be wise to read this 56 page report and consider the advice from IHS. So how much coal generation will the Clean Power Plan close? EPA's own numbers state 41 to 49 thousand Megawatts of coal will be closed. Also The Mercury and Air Toxic Standard (MATS) is expected to close approximately 56 thousand Megawatts of coal generation. Combined, the Clean Power Plan and MATS will close approximately 40 percent of today's coal fleet, leading to a loss of fuel diversity, massive increases to consumer prices, less reliability and security of the electrical grid, and the loss of approximately 400,000 jobs.So for all this trouble — the loss of jobs, loss of fuel diversity, increase in prices, and the

pain felt by people like Sharon Garcia — you would think the Clean Power Plan will result in a meaningful reduction in U.S. CO2 emissions. Unfortunately, our members and other Coloradans will be very disappointed, for the Clean Power Plan will have almost no impact on the CO2 emissions that contribute to global climate change. As the graph included with my testimony shows, the problem is not with the United States, whose CO2 emissions have been flat since1990 but rather, with the rest of the world where CO2 emissions have risen approximately 44 percent in 24 years. It is not possible for the United States to solve the world's global warming problem on its own. Any meaningful attempt to address global greenhouse gas emissions must incorporate America's trading partners; China and India in particular. The EPA and the administration should return to the drawing board to rethink its Clean Power Plan. The United States cannot afford the loss of fuel diversity, increased prices, the threat to reliability of the electric grid, or the job losses that will be caused by the Clean Power Plan. Thank You.45,000
40,000
35,000

30.

25,
20,000

15.000

10.000

5.000 •

2020 2030

1990 2010

—40—Total Global CO2 Emissions --4,—Non-U.S. CO2 Emissions —.—U.S. CO2 Emissions with EPA Rule —40—Total Global CO2 Emissions with EPA Rule U.S. CO2 Emissions 

# U.S. and Global Carbon Emissions Projections (million metric tons)

SOM.' EPA Carbon Regulation Proposal pg 547-543, and va.m.ela.gov/forecasts /table21.cfni