Metro Atlanta Chamber 

Comments for the EPA's Public Hearing on 

Clean Power Plan Proposed Rule 

July 29, 2014 

Introduction 

Good afternoon. I'm Anup Shah, vice president of environmental affairs at the Metro 

Atlanta Chamber. 

First of all, I want to express Metro Atlanta Chamber's appreciation for this 

opportunity to come here and share our perspectives on the proposed Clean Power 

Plan rules. 

MAC History 

Metro Atlanta Chamber was established in 1860. Over the past 100+ years, we have 

convened businesses and nonprofit leaders to address some of the toughest 

challenges in the region. Today, MAC serves as a voice for over 3000 businesses and 

over 1million employees in the region. 

We are the economic development entity for the 29-County MSA. r 9_1 k 

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Importance of Curbing CO2 and difference in approach 6.; 

While curbing CO2 emissions is important, Metro Atlanta Chamber has significant 

issues with the approach EPA has taken through the proposed rules. 

Climate Change is a global phenomenon and it needs to be addressed globally. 

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Each CO2 molecule emitted in the atmosphere, whether from US, China or India, 

contributes equally to the Climate Change. 

Unique challenges of CO2 pollution and Global Climate Change 

Today, India and China are emitting more Carbon Dioxide than the US. 

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Energy policies in these countries call for several large scale coal-fired plants. 

Just yesterday, Australia approved a project by an Indian company to build one of 

the largest coal mines in the world. 

So, the US alone curbing CO2 emissions is not going to solve these issues. 

We must also think about the unintended consequences of the proposed rules. 

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Metro Atlanta Chamber 

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Energy price is a key factor in the economic development policy. 

EPA's proposed rules will cause under-utilization or abandonment of some of the 

domestic resources for electricity generation. It will force utilities to opt for energy 

sources outside of the economic dispatch. 

This will lead to higher energy prices in the United States. 

Higher energy prices in US will erode competitiveness of the domestic 

manufacturers in the global market. 

Over the last few years, we were noticing a manufacturing resurgence in the US. 

However, higher energy costs in the US will again move manufacturing overseas. To 

markets still relying on coal-based but low-cost energy. 

Imagine this -- if the same products are manufactured overseas using dirty power, it 

may actually increase world-wide CO2 emissions as a result. That is not the outcome 

EPA is looking for. 

Economic Development Policies within US 

On a domestic front, the proposed rule will create imbalance among various states 

and disrupt the economic development policies within US. 

Historically, Georgia has had lower than average electricity prices. We relied on a 

diverse generation mix to provide fuel flexibility and reliability to achieve consistent 

and reliable low prices. 

Simply by responding to market conditions and Public Service Commission directed 

adjustment in fuel-mix, Georgia has reduced its CO2 emissions by more than 33%. 

Georgia has been proactive in adopting nuclear and other renewable energy sources 

including one of the first nuclear plant expansions in the nation. 

In this state, we have invested tens of billions of dollars to expand Plant Vogtle 

Nuclear Plant to produce new carbon-free energy. 

However, the timeline chosen in the proposed rules does not appropriately credit 

Georgia for its proactive actions. 

Rather, EPA's guidelines would force Georgia to make further investments. 

It will make Georgia opt for energy sources that are outside of economic dispatch. 

And, increase energy prices in the State. 

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Metro Atlanta Chamber 

Businesses seek consistency and reliability 

Uncertainties regarding energy prices breed lack of confidence from businesses and 

manufacturers. It will impact further investment and job creation in the State. 

For businesses, reliable, cost-effective electricity is of utmost importance. Access to 

reliable and affordable energy supply is critical to Georgia's recovery and future 

economic growth. 

EPA has never set enforceable state-wide limits or justified reductions at an affected 

source based on outside-the-fence measures under Clean Air Act Section 111(d). 

Such approach from EPA is unprecedented. 

Rather than seeking parity in carbon-intensity across all states, we believe, EPA's 

current approach of outlining CO2 reduction goals for each state is random. 

The 2030 CO2 emission goal for many states is lower than the beginning baseline for 

several other states. 

Through this plan, EPA appears to be picking winning and losing states for economic 

development. Clearly, that should not be the objective and goal of the Clean Air Act 

or any actions to fight Climate Change. 

So, I urge EPA to withdraw and reconsider the proposed rules and look at it from a 

holistic approach. 

As I conclude, I wanted to draw attention to a recent development: 

On July 17th, Australian Government voted to repeal a decade-old "Carbon Tax" 

finally realizing that acting alone on this global fight is not sufficient. 

We don't need to repeat the mistakes others have committed. 

Let's learn from their experience and seek a comprehensive and Global solution. 

In today's global market place, any sweeping energy policy changes such as this 

proposed rule MUST keep a global perspective. 

We believe the rest of the world, including India and China, should adopt and adhere 

to similar CO2 reduction goals before implementing these rules domestically. 

Thank you again for your time and consideration, and for allowing me this 

opportunity to express Metro Atlanta Chamber's concerns with the proposed rules. 

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