Doug Fulle's Talking Points for EPA listening Session on lll(d) -July 29, 2014 

• Good afternoon. My name is Doug Fulle, and I'm V.P. of Environmental Affairs for Oglethorpe Power 

Corporation. Thank you for this opportunity to comment on EPA's Clean Power Plan. Oglethorpe Power is one 

of the nation's largest power supply cooperatives, with approximately $9 billion in assets and serving 38 electric 

membership corporations, or EMCs, which collectively provide electricity to more than 4.1 million Georgians. 

On behalf of these citizens, I'd like to make the following four points: 

• First, "under construction" nuclear should not be included in the calculation of state goals. EPA's inclusion of 

Vogtle 3&4 in setting Georgia's performance standard is inequitable and misguided. Rather than rewarding 

states and utilities that are the early movers in permitting and constructing this important type of non-emitting 

generation, EPA's inclusion of "under construction" nuclear in calculating state goals serves instead as a 

penalty. Specifically, the electricity consumers of Georgia should not be penalized for stepping up and spending 

over $14 billion dollars on Vogtle 3&4, which will provide the state 2,200 megawatts of power with zero C02 

emissions. It's blatantly unfair and sends precisely the wrong message to the business community. 

• Second, Oglethorpe Power does not believe the Clean Power Plan, as proposed, fairly spreads the burden of 

reducing C02 emissions among the states. While Georgia has already reduced its tons of C02 emissions by 

around 30% between 2005 and 2012, the state is required to reduce its emission rate by another 44% between 

2012 and 2030, which is the 6th largest reduction of all the states. Other states, which have been much less 

proactive than Georgia in the past, are being required to do much less than Georgia in the future. 

• Third, we're very concerned about the potential impact that EPA's Clean Power Plan will have on the cost of 

electricity to our Member Systems and their customers. Over the last several years, Oglethorpe Power has 

invested around $1 billion dollars on environmental control equipment at Plants Scherer & Wansley, which we 

co-own with several other utilities, in order to comply with various EPA regulatory programs. If EPA's Clean 

Power Plan were to be finalized as currently proposed, these capital investments would need to be spread and 
recovered over significantly fewer megawatt-hours, resulting in an increase in the cost of the electricity we 

generate. This increased cost would be borne by our Member systems and their customers. Another significant 

concern relates to how heavily the cost of compliance depends on the future cost of natural gas, which has 

historically been extremely volatile. EPA's Building Block #2 assumes a very large increase in generation from 

natural gas combined cycle facilities, which will significantly increase the demand for gas nationally. Exactly how 

much prices will rise in response to this increase in demand is unknown at this point, but with the cost of 

compliance so heavily tied to the future price of this fuel, this is a serious concern and one that we don't feel 

EPA has adequately addressed in this proposal. 

• And finally, Fourth, Oglethorpe Power has serious concerns related to the reasonableness and technical 

justification associated with the assumptions EPA used in developing the four Building Blocks used to 

calculate state interim and final goals. Almost anything is technically feasible if you're willing to spend the 

necessary money, but we question whether the C02 reductions assumed in the four Building Blocks are 

economically feasible. For example, EPA's renewable energy and energy efficiency assumptions for Building 

Blocks 3 & 4 rely heavily on assuming that what's been done in one state is therefore "technically feasible" and 

can reasonably be done in other states, a logic which we believe is seriously flawed. Just because a certain level 

of energy efficiency has been reached in one state does not mean it can be repeated in a not her state with a 

different mix of residential, commercial and industrial electricity customers. EPA needs to develop the 

assumptions it uses to calculate state performance goals by evaluating what can reasonably be done in each 

state. EPA should not base the goals on what a few states have done and assume they can be repeated either 

regionally in the case of renewables or nationally in the case of energy efficiency. 

Again, Thank You for your time.