November 8, 2013

VIA ELECTRONIC MAIL AND U.S. MAIL

A. Stanley Meiburg, PhD US EPA, Region 4

Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303

m eiburg.stan@e pa.gov carbonpollutioninput@epa.gov

Re: Carbon Pollution Standards for Existing Power Plants

Dr. Meiburg:

Conservation Voters of South Carolina (“CVSC”) is providing input to the U.S. Environmental Protection Agency (“EPA”) on the best Clean Air Act approach es to reducing carbon pollution from existing power plants. CVSC is an organization dedicated to making conservation and environmental issues a top priority among South Carolina ’ s elected leaders, political candidates, and voters. CVSC takes a great intere st in addressing actions that can encourage efficient and clean energy generation in South Carolina. We recognize the importance of the President’s Climate Plan and its potential impact on our State. CVSC supports EPA’s plans to limit carbon dioxide emissions from power plants. We offer the following suggestions.

1) EPA Should Encourage Energy Efficiency and Renewable Energy

Energy efficiency is South Carolina’s first fuel. CVSC and other groups in South Carolina are working at the state level to encourage energy efficiency and renewable energy, but we recognize that EPA regulations affect the energy mix nationally. EPA should allow for a flexible system in which power plants could use energy effici ency credits to offset carbon dioxide emissions. In its proposed emissions guidelines, which President Obama ordered EPA to issue no later than June 1,
2014, 1 EPA should follow the Clean Air Act and federal regulations and issue guidelines that would

1 President Obama to EPA, June 25, 2013, Presidential Memorandum

-- Power Sector Carbon Pollution Standards.

Available at ht tp://www.whitehouse.gov/the

- press

- office/2013/06/25/presidential

- memorandum

- power

- sector

carbon

- pollution

- standards

.Dr. Meiberg

November 8, 2013 Page 2

requi re sources to use the best system of emissions reductions. 2 Considering power plant
emissions, averaged at the company

- wide or state

- wide level , in crafting the best system of emissions reductions, allows for flexible, cost

- effective options.

Allo wing for the ability to credit energy efficiency and renewable energy would provide for a cost effective way to encourage reduction in carbon dioxide. In order to maximize the impact of the renewable energy credits, EPA should limit those credits to supply

- side and demand

- side energy efficiency programs and renewable energy sources such as wind and solar. EPA should ensure a diversity of resources are deployed to meet emissions reduction targets and avoid creating

incentives that could result in the existing and planned nuclear development in South Carolina to swamp potentially available credits for energy efficiency and renewable energy.

The Natural Resources Defense Council (“NRDC”) r oadmap for complying with the existing source requirements of the Clean Air Act included extensive cost anal ysis that demonstrated that providing credits for energy efficiency and renewable energy, as a part of a larger trading program, would have societal benefits as much as fifteen times greater than compliance costs. 3

Encouraging energy efficiency and renewable energy would also reduce the amount of natural gas replacing reduced coal generation. Increasing reliance on n atural gas plants, even efficien t combined cycle turbines, still presents a number of environmental and rate payer related challenges . These plants emit carbon dioxide and ozone

- forming oxides of nitroge n; t he historically volatile price of natural gas suggests that ratepa yers could face cost increases; and

EPA must consider the environmental i mpacts from accessing shale gas when creating programs

that c ould encourage natural gas use.

2) EPA Should Work Closely With Stakeholders to Implement the Standards

CVSC appreciates the EPA’s extensive and unprecedented early outreach before it even proposes the standards for existing power plants. The eleven public listening sessions allowed EPA to hear a wide variety of perspectives before the formal rulemaking process b egins. CVSC recommends that EPA continue this work, including outreach to environmental organizations

, and the states that will implement the standards for existing power plants. With the state plans due in June 2016, one year after EPA issues final standa rds, 4 EPA could help with these urgent state plans by providing

technical assistance to stakeholders. Open data on emissions inventories, webinars, and modeling

support would assist stakeholders with these vital plans.

2 42 U.S.C. § 7411(a)(1) (2006) and 40 C.F.R. § 60.22(b) (2011).

3 NRDC, March 2013, Closing the Power Plant Carbon Pollu tion Loophole: Smart Ways the Clean Air Act Can Clean Up America’s Biggest Climate Polluters, Available at http://www.nrdc.org/air/pollution

- standards/files/po llution

standards

- report.pdf

. 4 President Obama to EPA, June 25, 2013, Presidential Memorandum

-- Power Sector Carbon Pollution Standards.

Available at http://www.whitehouse.gov/the

- press

- office/2013/06/25/presidential

- memorandum

- power

- sector

carbon

- pollution

- standards

.Dr. Meiberg

November 8, 2013 Page 3

3) EPA Shoul d Provide Bounded Flexi bility for State Plans

The structure of Clean Air Act 111(d) provides for states to take the lead on implementation. Like with State Implementation Plans under Section 110 of the Clean Air Act , the state plans for carbon dioxide from existing power plants allow for differences in energy mixes and state energy usage.

EPA however has the responsibility to ensure that state plans comport with its emissions guideline

. 5 A patchwork of highly variabl e plans would be inefficient and cumbersome. CVSC recommends flexibility, within the bounds set by the EPA guidance document.

Recognizing the unique attributes of states, within EPA guidance, will allow for the most effective environmental protections. I n the case of South Carolina, unscrubbed coal plants have closed or will close in the next few years. Scrubbed coal plants, natural

- gas

- fired combined cycle turbines,

and nuclear plants will compose much of the baseline generation for South Carolina. Howev er offshore wind and solar are on the horizon, and EPA guidance should encourage the development

of these renewable resources.

CVSC appreciates EPA’s consideration of these comments, and we look forward to working with EPA on implementing climate plans in South Carolina. If you have any questions, please feel free to contact me by email at ann@cvsc.org or by telephone at (803) 799

- 0716.

Sincerely yours
,

Ann Timberlake

Executive Director

Conservation Voters of South Carolina

Hamilton Davis Coastal Conservation League

Ben Gregg

South Carolina Wildlife Federation

5 40 C.F.R. § 60.22(b) (5) (2011)

.