Testimony of the Rev. Jim Ball Before the Environmental Protection Agency Concerning the EPA's Clean Power Plan

Washington, DC July 29, 2014

My name is the Rev. Jim Ball, Ph.D., Executive Vice President of the Evangelical Environmental Network (EEN). EEN is a non-profit, non-partisan Christian network of individuals and organizations dedicated to the care of God's creation.

Thank you for the opportunity to testify before you today and for your service to our country.

Climate change is one of the great moral challenges of our age; but overcoming this challenge also represents one of the most strategic opportunities to create a better world that will come before us in our lifetimes.

We are grateful that President Obama has risen to meet this challenge. His Climate Action Plan will help overcome climate change in ways that could: (1) position America to lead the world in the coming clean energy revolution; (2) create good jobs here in America, (3) reduce pollution that fouls our air and makes our water impure, (4) protect the health of our children, and (5) build resiliency to the consequences of climate change both here and in vulnerable poor nations.

Like the President, we would much prefer that Congress had acted responsibly to address this challenge by seizing the opportunities it provides us. It is well past time for our country to make the investments necessary, not only to protect us from climate impacts, but to position our country to be the leader of the clean energy revolution that is coming. Climate deniers and fossil fuel interests want to cling to the past and try to hold back the tide of change; this only weakens our nation by delaying what is necessary and forfeiting a dominant position in the clean energy market to countries like China. Their fears and narrow self-interests are attempting to thwart what is in our nation's best interest: overcoming climate change and leading the clean energy revolution. Unfortunately, such fear and self-interest has influenced a minority faction in Congress, which has successfully blocked major climate legislation that would use market mechanisms to put a price on carbon.

Because Congress has thus far failed in its responsibility to protect our country from climate impacts, President Obama has stepped up with his Climate Action Plan to fill this leadership vacuum.A key part of President Obama's climate efforts is the Environmental Protection Agency's (EPA's) Clean Power Plan, which for the first time requires electric utilities to reduce carbon pollution from existing power plants.

When coupled with proper EPA regulation of inethane leaks in the oil and gas sector, 1the EPA's Clean Power Plan is an essential step, the most important one we will have made to date in overcoming climate change. More than anything this shows our nation's resolve, that we are finally getting serious, that ourjourney has now begun in earnest and there's no turning back. This by itself will spur innovation and investment in the marketplace.

The Plan itself should provide states with maximum flexibility to meet their carbon reduction goals. EEN's carbon reduction policy preference is to utilize market-based mechanisms to price carbon. We prefer market-based approaches because Christians are called to be good stewards not only of God's creation, but also of our financial resources; what markets do best is allocate scarce resources efficiently, and there is general agreement among economists that the most efficient, cost-effective way to reduce pollution is with a tax.

As such, we ask the EPA to include in the final rule explicit language assuring states that a carbon tax/pollution fee would be an acceptable way to meet its obligations if it chose to do so.

While the Clean Power Plan is essential, many more steps will be needed. To ensure it is America that leads the clean energy revolution, our country must make much bigger investments in basic Research and Development (R&D), not only in energy efficiency and clean energy technologies, but in how our thinking can be set free from the self-imposed silos we've created between energy research, and, say, information technology.

During the Cold War years our country spent 6% of GDP on national defense. Overcoming climate change and leading the clean energy revolution are arguably as important as winning the Cold War. We must be ready to spend Cold War-level funding if that's what it takes.

Due to our absence of focus and resolve (including appropriate R&D funding) we haven't even begun to scratch the surface of one of the greatest assets a free county like ours possesses: our own creativity. And it is our inquisitive, freedom-loving nature that should have us leading the way.Every single one of our ancestors — beginning at least 18,000 years ago when groups traversed a land bridge over the Bering Strait — came from somewhere else in search of a better life. It's literally in our DNA to look beyond the horizon, to sail oceans and ford rivers and climb mountains and even go to the moon. It's who we are as a people, as Americans.

We may be a nation of settlers, but we're not a nation of those who settle — for second-best, for the status quo; we're strivers who believe we can create a betterfuture.

We believe also that each person is created equal, that all should be free to use our God-given gifts and abilities and creativity to make a better life.

It is these qualities and values we share that make us the ones to lead the world in the clean energy revolution, a revolution that will benefit every single person, indeed every single creature, on this planet.

Overcoming climate change and leading the clean energy revolution is the next great cause of freedom. Efforts like the President's Climate Action Plan and the EPA's Clean Power Plan are therefore profound acts of patriotism.

' 1 note here that another part of President Obama's Climate Action Plan is integral to the ultimate effectiveness of the EPA's Clean Power Plan to actually reduce overall greenhouse gas or GHG emissions. I'm referring to the Climate Action Plan's proposed efforts to reduce methane emissions, especially methane leakage. This is quite important given how much the Clean Power Plan's emissions reductions from the electricity sector are projected to come from fuel switching from coal to natural gas. Studies have indicated that if the leakage isn't addressed, there isn't much difference between coal and gas from a climate perspective. We urge the EPA not to low-ball the leakage estimates and to take steps to regulate methane emissions from the oil and gas sector. Failure to do so could seriously undermine the ability of the Clean Power Plan to play its role in reducing overall emissions of GHGs. Simply put, to ensure the Clean Power Plan's ultimate success requires the EPA also to regulate methane
leaks.

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