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W/15HVNGl`ON, [)C 20510 -2309 

May 2$, 2014 

"I'hc Honorable Barack Obama 

President of the United States 

The White House 

1600 Pennsylvania Avenue, NW 

Washington, DC 20500 

Dear President Obama: 

As you know, the Clean Air Act requires the Environmental Protection Agency (EPA) to 

regulate air emissions, including greei-diouse gases (GI1G), from various sources. Ainong these 

sources are more than 500 coal-fired power plants (CFPPs) that supply about 40 percent of the 

nation's electricity, but are also large sources of GHG emissions. While section 1 I 1(d) of the 

Clean Air Act requires regulating existing CFPPs, it also allows for the EPA to give states 

tlexibility on how to implement regulations. As your Adtninistration works to create GHG 

performance standards for existing CFPPs, 1 respectfully request that these regulations allow 

CI, PP compliance tivough improved energy efticiency and renewable energy expansion, and that 

you consider flexible implementation and accountability at the regional level. 

Many ernission reduction oppoi-tunities exist at the point of the end user of energy. Recent 

analysis by the American Couneil for an Energy-Efficient Economy shows that investments in 

energy efficiency, through retrofits atid other niechanisms, cati reduce U.S. energy consumption 

by up to 60 percent by 2050. It is therefore imperative that the EPA regulations allow states the 

flexibility to count improved energy efficicncy by end users toward compliance. Without such 

flexibility, the cost of compliance on electricity providers and consumers could be higher, 

without any additional environmental gains. 

Reducing GHG emissions through renewable generation is an additional toot that could be 

utilized for effective I 1 I(d) implenlentation. GHGs released from power plants can be negated, 

on a tict basis, by inereasing renewable generation. Existing programs for clean renewable 

generation (including biomass), as well as the flexibility for new programs, should be allowed. 

These programs would provide additional flexibility in rneeting 111(d) requirements while still 

decreasing net GHG emissions. 

Furthe.rmore, any .regulations under 111(d) should allow sufficient flexibility for the regional 

utilities that already set•ve customers. Many utilities operate power generation, transinission, and 

distribution systems spannirig multiple states. Rather than encouraging a patchwork oi'different 

regulations for each state withiil the region, the EPA should allow compliance through existing 

networks at the regional level. "T'his flexibility will achieve the goals of t:he C'lean Air Act without 

putting an undue burden on utilities.
Providing for flexibility in the implementation ot' 111(d) will create local jobs in retrotitting and 

energy efficiency technologies; the renewable sector; and othcr areas of the economy. Flexibility 

will also help protect ratepayers from unnecessary increases in the cost of electricity while 

sirnultaneously fulfilling the goals of the Clean Air Act. 

Thank you for your attention to this important matter. 

Sincerely,