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

• Good afternoon. My name is Doug Fulle, and I'mV.P. ofEnvironmental Affairs for Oglethorpe Power Corporation. Thank you forthis opportunity to comment on EPA's Clean Power Plan. Oglethorpe Power is one ofthe nation's largest power supply cooperatives, with approximately$9 billion in assets and serving 38 electric membership corporations, or EMCs, which collectively provide electricityto morethan 4.1 million Georgians. On behalfofthese citizens, I'd like to make the following four points:

• First, "underconstruction" nuclear should not be included in the calculation ofstate goals. EPA's inclusion of Vogtle 3&4 in setting Georgia's performance standard is inequitable and misguided. Ratherthan rewarding states and utilitiesthat are the early movers in permitting and constructing this importanttype of non-emitting generation, EPA's inclusion of "underconstruction" nuclear in calculating state goals serves instead as a penalty. Specifically, the electricity consumers ofGeorgia 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 powerwith zero C02 emissions. It's blatantly unfairand sends precisely the wrong message tothe business community.

• Second, Oglethorpe Powerdoes not believethe Clean Power Plan, as proposed, fairly spreads the burden of reducing C02 emissions amongthe states. While Georgia has already reduced its tons ofC02 emissions by around 30% between 2005 and 2012, the state is required to reduce its emission rate by another44% between 2012 and 2030, which is the 6th largest reduction ofall 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'revery concerned aboutthe potential impactthat EPA's Clean Power Plan will have on the cost of electricityto our Member Systems and theircustomers. Over the last several years, Oglethorpe Power has invested around $1 billion dollarson environmental control equipment at Plants Scherer & Wansley, which we co-own with several other utilities, in orderto complywithvarious EPA regulatory programs. If EPA's Clean Power Plan were to be finalized as currently proposed, these capital investments would need to be spread andrecovered over significantly fewer megawatt-hours, resulting in an increase in the cost ofthe electricity we generate. This increased cost would be borne by our Membersystems and theircustomers. Another significant concern relates to how heavily the cost ofcompliance depends on thefuture cost of natural gas, which has historically been extremelyvolatile. EPA's Building Block #2 assumes avery 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 tothis increase in demand is unknown atthis point, butwith the cost of compliance so heavily tied tothe future price ofthisfuel, this is a serious concern and one that we don'tfeel 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 ifyou're willing to spend the necessary money, but we question whetherthe C02 reductions assumed in the four Building Blocks are economically feasible. Forexample, EPA's renewable energy and energy efficiency assumptions for Building Blocks 3 

### & 4 rely heavily on assuming thatwhat's been done in one state is therefore "technicallyfeasible" and can reasonably be done in otherstates, a logic which we believe is seriouslyflawed. Just because a certain level ofenergy efficiency has been reached in one state does not mean it can be repeated in anotherstate with a different mix of residential, commercial and industrial electricity customers. EPA needsto develop the assumptions it uses to calculate state performance goals by evaluating what can reasonably be done in each state. EPA should not base thegoals on what afew states have done and assume they can be repeated either regionally in the case ofrenewables or nationally in the case ofenergy efficiency.
Again, ThankYou foryourtime.