BCSE Statement: Proposed Carbon Pollution Standard for New Power Plants May 24, 2012 Thank you forthe opportunityto participate in this public hearing. My name is Lisa Jacobson and I am the President ofthe Business Council for Sustainable Energy. The Council is a coalition of companies and trade associations from the energy efficiency, natural gas and renewable energy sectors. Ourcoalition also includes independent electric power producers, investor-owned utilities, public power, commercial end-users and project developers and service providersfor environmental markets. The Council was founded in 

### 1992 and advocates for policies that increase the use of commercially-available clean energytechno:ogies, products and services. Our diverse business membership is united around the revitalization ofour economy and the creation ofa secure and sustainable energyfuture forAmerica. Iwantto communicate five things to you this afternoon: First, BCSE believes that energy efficiency, renewable energy, and natural gas will be ableto help our nation reduce emissions, growthe economy, createjobs and strengthen our energy system

-- in addition to being cost-effective compliance options. Second, we supportthe science underpinning the greenhouse gas endangerment finding and EPA's continued use ofsection 

### 111 ofthe Clean AirActto regulate greenhouse gas em1ssions. That said, we believe the optimal policyfor regulating greenhouse gas emissions is for Congress to enact a comprehensive market-based program that allows forflexibility and cost-effective emissions reductions, including carbon offsets. Third, in evaluating EPA's proposal, we applaud the Agencyforadopting an outputbased approach. As we communicated to EPA in past comments, the Council has long supported the developmentand use ofoutput-based emissions regulations as effective ways to enhance air quality and encourage cost-effective and efficient emissions reductions. The bestwayto limit emissions and to drive technological innovation is to ask facilities to produce more useful output per unit ofpollution. Fourth, building on this positive step for energy efficiency, EPA has an opportunity in the carbon pollution standa1·d to encourage clean and efficient combined heat and power

1620 Eye Street NW Suite G0"1 VVashington, DC 20006 p: 202.785.0507**~** f: 202.785.0514**~** http://www.bcse.organd waste heat recovery. The proposal asks for comments specifically on CHP. Weare working with our members to suggestways EPA could better accountfor and encourage useful heatoutputfrom CHP units to help complywith the proposed 

### 1000 pounds ofC02 per megawatt hour standard. There are also possibilitiesto credit onsite use ofCHP-generated electricity with avoided line losses, which can be quite high at times ofpeak demand. Today, in EPA Public Hearing in Chicago on this proposed standard, BCSE Board member Recycled Energy Development is speaking on these exact issues and we urge you to take its recommendations into consideration. Finally, overthe pasttwo years, there have been discussions on how EPA might guide the states in regulating existing sources through this NSPS. BCSE urges you to keep this in mind in finalizing the Carbon Pollution Standard for new sources and devising the federal guidelinesthat states mustfollow in their plans to cover existing power plants, undersection 

### 111(d). BCSE supports an approach that allows states and tribes to show achievement of equivalencewith prospective federal Clean AirAct Section 

### 111(d) requirements through theirown and cooperative regional climate, clean energy, and energy efficiency programs and policies. Tothat end, EPA should establish the minimum stringency states must meet but allow statesthe flexibilityto achieve greater reductions. For example, flexible market-based programsthat allow for carbon offsets and emissions trading can drive down emissions at lower cost and encourage over performance with reduction targets. This is a complicated issue, but it's essential that facilities notface double regulation and that existing programsthatwork are allowed to continue achieving emissions reductions at low costwhile spurring clean energy development. Again, thank you for this opportunityto speakwith you today. The Council will work with its members in the coming month to submit full written comments on the proposed standards and we lookforward to submitting them to you for yourfull consideration.