Testimony 

EPA's Proposed Rule 

"Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating 

Units" 

Docket Number EPA-HQ-OAR-2013-0602 

Presented by Theodore Robinson 

Citizen Power 

July 31, 2014 Public Hearing 

Pittsburgh, Pennsylvania 

Good afternoon and thank you for the opportunity to testify today. My name is Theodore 

Robinson and I am a staff attorney with Citizen Power, a nonprofit public policy, research, 

worked 

education, and advocacy organization based in Pittsburgh, Pennsylvania. Since 1996, we have 

toward ensuring that low-income consumers and environmental interests are 

represented in the operation of the electric generation industry. 

Citizen Power supports both the purpose and the general methodology of the EPA's proposed 

rule. It is imperative that our nation effectively regulates greenhouse gases. The four building 

would 

blocks approach under Section 111(d) is a reasonable and flexible step towards this goal. I 

like to emphasize, however, that we view this proposed rule as only part of the solution. 

Additional legislation is necessary in order to further reduce emissions. 

Although we generally support the proposed rule, our recommended changes to specific 

aspects of the rule will be addressed in our written comments. I would like to highlight three of 

these comments today. 

First, we believe that greater reductions than those proposed by the EPA are possible through 

the application of the "best system of emission reduction." For example, the use of a target of 8 

to 10 percent heat rate improvements for the existing fleet is supported by the existing 

literature and the low cost per ton of carbon dioxide. In addition, we believe that the EIA data 

supports an energy efficiency "ramp-up" level of .3% instead of the proposed .2%. 

Second, the proposed inclusion of new and preserved nuclear capacity as a substitute for 

carbon intensive generating capacity does not adequately reflect the future lifecycle 

greenhouse gas emissions of nuclear facilities. While wind generation has a consistently small 

greenhouse gas profile, the impact of nuclear facilities is dependent upon the uranium mining 
technologies used, the quality of the uranium ore, the enrichment method, and the carbon 

intensity ofthe electricity used for enrichment. The future quality of uranium ore, in particular, 

may degrade as higher quality mines are depleted, resulting in greater processing and higher 

emissions in the future. Additionally, the cost of disposing of nuclear waste as well as the cost 

associated with the potential of a nuclear accident needs to be taken into account when 

estimating the cost of reducing carbon emissions through increasing nuclear capacity. 

Third, the use of re-dispatching to substitute combined cycle natural gas for fossil fuel-fired 

steam generation has impacts not addressed in the proposed rule. Specifically, the standard of 

performance must take into account the environmental impacts of nonair quality health and 

environmental impacts. The impacts from fracking, which will be increased as a result of redispatching, such as impacts to water quality, should be addressed and quantified in the 

proposed rule. 

Thank you again for the opportunity to testify.