Testimony of Thomas D Schuster on behalf of Sierra Club 

Clean Power Plan Proposed Rule 

Docket ID # EPA-HQ-OAR-2013-0602 

Thursday, July 31, 2014 

Pittsburgh Hearing 

Good afternoon. My name is Tom Schuster, and I live at 605 23'd Street in 

Windber, PA. I represent the Sierra Club, which has over 24,000 members in 

Pennsylvania. I also represent my wife and especially my three-year-old 

daughter, who is still too young to speak for herself, but who will have to deal 

with the consequences of the decisions the grown-ups will make over the next 

several years, for better or worse. 

We fully support the proposal by the EPA to limit carbon pollution from existing 

power plants for the first time in history. The costs of failing to adequately deal 

with climate disruption, caused mainly by carbon pollution, are immense. By the 

end of the century, the northeast as a region is expected to see an additional 57 

days per year (nearly 2 more full months) of temperatures over 95 degrees. 1 This 

will have severe consequences on our health, our economy, and the 

infrastructure and natural systems on which we all depend. 

Higher average temperature leads to worse air quality, and in turn more hospital 

admissions and premature deaths, particularly among children. It leads to the 

spread of insect borne diseases that were once only problems in the tropics. It 

leads to more frequent intense storms, which can damage our homes and 

threaten our lives with high winds and flooding. It also threatens our economy. A 

10-year flood in Allegheny County costs over $8 billion to clean up, and that is 

money that can't be invested in growing our regional economy. These will only 

become more severe. Agriculture currently employs more people in Pennsylvania 

than extraction of coal, oil, and gas combined. 2 It is projected to suffer from 

extreme heat, droughts and storms, and could shed many thousands of jobs. 

1 http :I I riskyb u sines s.o rgl repo rtl overview I regi onslno rtheast 2 US Bureau of Economic Analysis, 2012 statistics 
These are just some examples of the severe and permanent consequences of 

inaction, which would dwarf any transitional impacts of cleaning up carbon 

pollution. Fortunately though, the transition does not need to be difficult. In fact, 

Pennsylvania is already well on its way to meeting the proposed target. We have 

energy efficiency requirements and clean energy requirements that are already 

on the books and being implemented that will get us over 1/3 of the way to our 

proposed target. When we add in coal plant retirements that have already taken 

place since 2012 and additional retirements or conversions to gas that have 

already been announced, we will be more than halfway there. 

But there is much more we can do to implement clean energy and efficiency in 

Pennsylvania. Our current annual efficiency targets are half of what many leading 

states are achieving. Our current Tier I clean energy target is only 8%, compared 

to 20% for Maryland, 22% for New Jersey, and 25% for Delaware. If we simply 

match the commitments of other leading states by doubling our commitment to 

efficiency and achieving 20% renewable energy by 2030, we will meet over 96% of 

our target. That's before we even start talking about upgrades to the power 

plants themselves. 

Energy efficiency saves us money. Through the first four years of our energy 

efficiency program, ratepayers in Pennsylvania saw savings of nearly $4.2 billion, 

equal to $2.40 saved for every dollar invested. 3 And we've only scratched the 

surface. Efficiency investments create jobs directly, but also boost the broader 

economy by putting more spending money in families' pockets. 

Investing in renewable energy also saves us money. Earlier this year, a study was 

conducted by PJM, the regional grid operator, on the impacts of integrating up to 

30% renewable energy by 2026. 4 It found that by using 30% solar and wind we 

would save up to $16 billion per year on electricity production, because it would 

replace the least efficient and most expensive power plants. It also found that 

there would be no significant reliability issues from phasing in this level of 

3 Act 129 Statewide Evaluator final report, March 2014. 4 PJM Renewable Integration Study, Executive Summary Report, Revision 05, March 31, 2014. 
renewable energy. Wind and solar also create more jobs than natural gas and 

coal per dollar invested, per MW of capacity, and per MWh or generation. 

Nationally, there are already more jobs in the wind and solar industry than in coal 

mining and coal power generation, so the potential is enormous. By one 

estimate, Pennsylvania could create 500,000 40-year jobs by transitioning to 

100% renewable energy by 2050, which would be over 10 times more jobs than 

the coal industry in the state currently supports. 5 

If we act to limit our carbon pollution, the coal mining sector will certainly be 

impacted. But if we don't act, all other sectors will be impacted. That does not 

mean that we can neglect mineworkers, their families, and communities like my 

hometown. We need to commit to helping them transition just as we have 

helped tobacco farming and logging communities transition in the past. I am very 

confident that we can do this, but we cannot leave it to chance. Fortunately, this 

plan provides for a great deal of flexibility in how states meet their targets, and 

sufficient planning time for transition. 

What we simply cannot afford to do, however, is wait any longer to address 

climate change. The longer we wait, the harder the transition will be, and the 

worse off we all will be due to climate disruption. But if we begin now, we can 

still achieve a cleaner, healthier, and more prosperous future. Thank you for your 

time. 

5 http:/ /thesolutionsproject.org/infographic/#pa