Remarks Submitted on behalf of the Pennsylvania Chamber of Business and Industry



### DEP Listening Session on EPA’s Pr oposed CO2 Emissions Rule for Modified, Reconstructed, and Existing Power Plants

Presented by: Shawn Good Director, Government Affairs

Harrisburg, PA December 16, 2013

417 Walnut Street Harrisburg, PA 17101-1902 717.720.5443 phone http://www.pachamber.org2 Good afternoon. My name is Shawn Good, Director of Government A ffairs for the Pennsylvania Chamber of Business and I ndustry, the largest broad-based business advocacy association in Pennsylvania. The Pennsylvania Chamber represents thousands of businesses from all industry sectors and of all sizes, from sole proprietorships to Fortune 100 corporations. The Pennsylvania Chamber would like to thank the DEP for inviting us to provide re marks to this listening session on the EPA’s proposed standards, regulations, or guidelines that addre ss carbon emissions from modified, reconstructed, and existing power plants under Section 111(d) of the federal Clean Air Act. Even though the Pennsylvania Chamber be lieves that the issue of carbon emissions needs to be addressed more globally--especia lly given that more and more of the world’s emissions of carbon dioxide are co ming from developing countries and fewer are coming from developed countries, includi ng the United States--we understand that reality dictates that the current EPA has every intention of proceeding with this proposed rule on power plants next year and in to the foreseeable future, and we truly thank the DEP for being proactive in its out reach to the regulated community regarding

this matter. With that in mind, I would like to convey the following points and ask that they be incorporated into the DEP’s vetting and analysis of the proposed CO2 emissions regulation on modified, recons tructed, and existing power plants. First, we ask that the DEP seriously and thoroughly consider the economic impact of this proposed regulation on electr ic generation units. We w ould ask that you evaluate this impact in the context of current marketplace conditions of Pennsylvania’s electric generation industry and the existi ng regulations and mandates to which this industry is3 subjected. In addition, the DEP should ta ke into account the emissions reductions already achieved by the electr ic generation industry in sulfur dioxide, nitrous oxide, particulate matter, and, of course, carbon di oxide. Projected CO 2 emissions reductions by the industry in the near future under cu rrent federal and state environmental rules

should be also considered. Second, we ask that you consider t he financial impact on manufacturing, industrial, and commercial users of electricity. There is a very strong likelihood that this proposed regulation will translate into higher electricity rate s for our members who use electricity—from large industrial users to small businesses. So, we ask that the likely costs of this proposed regul ation to the end users be cons idered seriously by the DEP during the development of it s Section 111(d) State Plan. Third, as alluded to earlier, the P ennsylvania Chamber has not come here today to

debate whether there s hould be a CO2 emissions regulati on for existing power plants. However, we are concerned that requiring ou r state’s power plants to comply with an additional regulation, especially in light of the recently announced closings of coal-fired power plants in the state, may make it more difficult for them to generate the amount of electricity that is necessary to ensure grid re liability, which, of course, is very important to our members both big and small. So, we ask that you consider this proposed regulation’s impact on the reliability and su stainability of our electricity grid. Fourth, we ask that the DEP work with the EPA to ensure that this proposed regulation provides for enough flexibility in terms of compliance and that the technologies, practices, and methods requi red are truly achievable, practical, and commercially viable. In addition, we woul d ask that the science used in the proposed4 rule be sound, verifiable, and inclusive of a variety of sources, including those that may counter the scientific findings of the EPA as they relate to this proposed regulation. In closing, I woul d like to stress that abundant, re liable, and competitively priced energy production and delivery are critica lly important components of a healthy and robust economy. A lack of these com ponents would significantly hamper the Commonwealth of Pennsylvania’s ability to attr act and retain businesses. We ask that you keep this fact in mind as well as the need to balance environm ental protection with economic development as you are developing y our State Plan. Again, I want to thank the DEP for soliciting input from the regul ated community on this proposed regulation well in advance of it being issued by the EPA in June 2014, and I welcome any questions that you may have.