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

t My name is David Ellenberger and I'm a regional outreach e- ( ix

- hrlter with the National Wildlife 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 expandsolar and wind power across the state. In fact, Colorado is ranked 4th in the nation for solar

energy potential.