Protecting Wildlife {or our childrenkfuture 

W ILDLIFE 

Formal Comments Submitted to: 

U.S. Environmental Protection Agency 

Denver Hearing: July 30, 2014 

RE: Clean Power Plan 

My name is David Ellenberger and I'm a regional outreach e-(ix -hrlter with the National Wildlife t 

Federation's Rocky Mountain Regional Center in Boulder, CO. 

For over 75 years we have been advocating for solutions to our nation's largest conservation challenges. 

And for the past decade, National Wildlife Federation (with its 4 million members and supporters, and 47 

states affiliates) has been on the front lines of documenting the profound impact of climate change on our 

natural resources, and the people and wildlife that depend on them. We have been on the cusp of turning 

the tide on the climate crisis, being stalwart advocates for a future that embraces clean energy to power 

our homes and cars, and where wildlife and our lands are protected from carbon-intensive energy 

sources. To be successful in addressing the climate crisis, however, we have a long road ahead. 

EPA Can Achieve Greater Reductions: 

• EPA's proposed targets can and should be strengthened. The pollution reductions could be greater 

at a reasonable cost. Our initial analysis indicates emissions can be reduced beyond those 

projected by EPA. The goal of this plan should be to reduce emissions 35 to 40 percent below 2005 

emissions by 2020. 

• Primarily, the formula used by EPA to establish the emissions target/standard in each state needs 

to be adjusted to reflect the fact that additional available clean, renewable generation and energy 

efficiency resources would replace generation from the dirtiest fossil fuels sources and at a faster 

pace, yielding greater emissions reductions than EPA assumed. 

Energy Efficiency: 

• EPA has rightly recognized that energy efficiency is the most cost-effective resource to reduce 

emissions and that the many successful state programs adequately demonstrate the potential for 

efficiency across the country. However, more cost-effective efficiency is available more quickly 

and at lower cost than EPA assumed in the proposal. State programs have demonstrated the 

ability to ramp up more quickly than EPA's proposal would require and to use a wider variety of 

effective efficiency tools than EPA considered. 
Renewables: 

• Clean renewable energy has been growing at an astonishing rate. In 2012, wind energy and solar 

were two of the fastest growing electric generation technologies in the United States: cumulative 

installed wind energy capacity increased by nearly 28% and cumulative installed solar 

photovoltaic capacity grew more than 83% from the previous year. EPA rightly includes these 

resources in setting the state targets, but the availability and quantity of RE opportunities 

assumed is too low. By setting assumptions about renewable energy potential far too low, EPA left 

substantial, achievable reductions off the table. 

• EPA should analyze resource availability and costs on a state and regional basis rather than 

limiting the assessment of potential development to mandated renewables in state renewable 

portfolio standards. The agency should remove any artificial limits on renewable energy growth 

and use an annual RE growth factor for each state that reflects the renewable potential for states 

and regions. EPA also needs to adjust its analysis to include the full potential of a wider variety of 

renewable resources that are currently excluded from consideration, such as distributed solar and 

off-shore wind. 

Natural Gas: 

• In establishing each state's target, EPA should fully account for planned and anticipated fossil fuel 

plant retirements and the current rate of change from coal to lower emitting resources, including 

natural gas. In other words, EPA must ensure that its approach to natural gas as lower emitting 

source will drive emission reductions that would not already have occurred. 

• EPA should also be concerned about life-cycle emissions from natural gas production, and move 

forward with parallel, additional regulations to ensure methane pollution does not erase the 

climate benefits of increased reliance on natural gas over coal. 

Western States - COLORADO 

• The West has tremendous renewable energy potential. Vast quantities of onshore wind exist 

across the West, particularly in the plains where onshore wind potential is unmatched in the 

Nation. The Southwest has the Nation's highest sun potential and much of the rest of the West is 

close behind. 

• The West has some of the most aggressive state renewable energy portfolio standards in the 

country, with Colorado out in front at a 30% requirement by 2020. This is in part because of the 

vast renewable potential in this region. Rather than using a formula that expects that these states 

will do little to nothing in terms of developing renewables further, EPA should factor in the great 

potential for even greater renewable energy development in the West to develop targets that will 

achieve significantly greater reductions. 

• Colorado can far outpace the assumed growth in renewable energy generation that EPA 

relied on to set the state target - EPA's standard for Colorado should be strengthened to 

reflect this. 

• Colorado can and should comply with the Clean Power Plan through continued emphasis on 

wildlife-friendly renewable energy and energy efficiency. With strong state plans and a 

burgeoning renewable energy industry in our state, Colorado has great potential to expand 
solar and wind power across the state. In fact, Colorado is ranked 4th in the nation for solar 

energy potential.