December 1, 2014

The Honorable Gina McCarthy

Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460

Re: Docket ID No. EPA

- HQ

- OAR

- 2013

- 0602

Dear Administrator McCarthy:

The United States Conference of Mayors and the National League of Cities strongly support the

U.S. Env ironmental Protection Agency’s (EPA) Clean Power Plan Proposed Rule on Carbon Pollution Emission Guidelines for Existing Stationary Sour c es: Electric Utility Generating

Units

. We appreciate the opportunity to submit comments as the agency develops a national policy to reduce greenhouse gas emissions.

The Need The National Climate Assessment released earlier this year show ed that all parts of the country are currently experiencing impacts of climate change, such as extreme weather events, changes in precipitation, higher temperatures, sea level rise, wildfires, droughts and flooding. As the nation’s two preeminent organizat ions representing U.S. cities and towns, we are deeply

concerned about the se growing negative impacts of climate change upon our cities , which represent a clear, imminent and real danger to our communities.

According to the International Panel on Climate Change Fifth Assessment Report, if we act now to limit greenhouse gas emissions, the world has a 66 percent chance of avoiding the critical

threshold of a 2 degree C elsius warming of the planet

. Delaying action will result in technical, economic, social and institutional challenges for the 21 st Century that may be extremely diff icult and expensive to overcome

. Moreover, the costs of inaction will greatly outweigh the costs of taking action today.

Given these findi ngs, our country cannot afford to avoid action on limitin g g reenhouse g as emissions. T his is no longer just a national and global issue ; it is a local one that will determine

the future of our communities and their economies. Beyond moving quickly to finalize a nat ional plan for reducing greenhouse gas emissions, w e encourage EPA, other federal agencies , andCongress to provide additional incentives to states, local governments, and utilities to help them

move as quickly as possible in implement ing their greenhouse gas reduction actions.

Overall Response to the Clean Power Plan We applaud EPA’s recognition and acknowledgement in the Clean Power Plan that a “one size fits all” model will not promote the creative and innovative thinking necessary to dramatically reduce greenhouse gas emissions. We support the flexible approach that the Clean Power Plan

outlines that would allow states to determine the ir own best method for meeting the emissions reduction targets. Utilities should be encouraged to work with their states, local governments, and businesses to implement strategies that work in their region.

As the proposed rule allow s , utilities should be encouraged to not only invest in more renewable

energy sources
, but also to recognize the value of “outside the fence” plans that promote a more compreh ensive and sustainable approach to emissions reductions, such as energy conservation strategies

. As proven in California, utility efforts to fund i ncreased energy efficiency in new and existing buildings and homes has yield ed significant lower rates of energy usage.

In addition, EPA should ensure that local governments are afforded sufficient opportunity for input into the development of state impl ementation plans in order to promote cooperative

initiatives

, but also to avoid the shifting of cost burdens to local governments through unfunded

mandates.

Specific Co mments

W e agree with EPA that emission limitations are to be measureable (quantifiable) and verifiable in terms of real reductions in GHG emissions from existing generating units. While we applaud and support flexibility in meeting such reductions through the four “building blocks ” as proposed ( make fossil fuel plants more eff icient, use low

- emitting power sources, use zero

- and low

emitting power sources, and use electricity more efficiently ) , the rule must ensure that such

reductions are rea l and absolute in value

. For example, b ecause it is likely that much of the

emission reductions will be the result of fuel switching from coal to natural gas, we believe

utilities should be required to take into account additional emissions of greenhouse gases ( i.e. methane) from the extraction and transport of natura l gas in their calculations of net emission

reductions.

We also expect that the rule, when adopted, will bring institutional focus and cooperation to the

task of GHG reductions. State Implementation Plans should include strong commitments and actions from utilities to the broad range of energy efficiency and renewable energy development, as long as such efforts meet stringent tests of measurement and verifiability. The utility sector, in the end, represent s the strongest institutional entities to re

- shape the nation’s energy system in ways that are innovative, cost

- efficient, and in the long

- run significantly less reliant on GHG emitting fuels.

We also agree with EPA that if reductions are to be counted i n State Implementation Plans

, utilities should provide evidence of long

- term sustainable funding to ensure that such reductions are properly implemented over time.In addition to the options outlined in the proposed rule , we strongly encourage EPA to recognize

that the energy that is produced from reusing Municipal Solid Waste , which diverts waste from landfills, should be considered a renewable energy source

. According to EPA ’s own studies

,

m ethane “is the second most prevalent greenhouse gas emitted in the United States from human activities” with landfills accounting for 18 percent. It is imperative that if we are to meet our greenhouse gas emission goals, we need to look comprehensively at the options that are before

us , inclu ding w aste

- to

- e nergy facilities

.

In closing, w e thank EPA for its leadership on this issue and for putting forth this proposal. It is vitally important that we waste no further time on debating the importance of this issue

, but

rather act swiftly and move forward in a comprehensive manner. T hank you for this opportunity to offer our support and comments . If you have any questions, please do not hesitate to contact

our staff : Judy Sheahan, The U.S. Conference of Mayors ( jsheahan@usmayors.org or 202

- 861

- 6775) and Carolyn Berndt, National League of Cities ( Berndt@nlc.org or 202

- 626

- 3101)

.

Sincerely,

Tom Cochran Clarence Anthony

CEO and Executive Director CEO and Executive Director The U.S. Conference of Mayors National League of Cities