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. 

## 9 

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

# r

.1t—t ■ ) Pc4, e--) (0( \-00 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. -\\„._ 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. 

## n,..44.144 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. 1Metro Atlanta Chamber 

### pri-t 42-5 - tA) 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. 2Metro 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. 3