111(d) Testimony to be Presented by IDEM Commissioner Easterly 7/30/14 

Good morning, my name is Thomas Easterly and I am the Commissioner of the 

Indiana Department of Environmental Management, also known as IDEM. I also 

bring you greetings from Governor Pence of Indiana. Indiana will be significantly 

impacted by the proposed 111(d) regulations for fossil fueled Electrical 

Generation Units because we are the most manufacturing intensive state in the 

U.S. with over 80% of our electricity currently produced by coal, and we have a 

300 year supply of coal in our State. 

IDEM's mission is to protect Hoosiers and our environment. In examining how 

the proposed 111(d) regulations further our mission, I have come to the 

conclusion that this proposal will cause significant harm to Hoosiers (and rnost 

residents of the U.S.), without providing any measurable offsetting benefits. For 

these reasons, as well as the questionable legal basis of the proposal, I request 

that U.S. EPA withdraw this proposal and work with us and other energy 

producing states to develop a balanced regulation that uses all of our fuels in the 

most efficient manner. In the long run, a program focusing on the most efficient 

use of all of our sources of energy, including coal, will provide the most cost 

effective worldwide reductions in greenhouse gas emissions, allow people 

around the world to approach our standard of living and allow development of an 

understanding of why the climate models have not predicted the over 15 year 

long pause in significant warming that is currently being observed. It is clear that 

global carbon dioxide concentrations are increasing and that urban areas and 

irrigation both increase measured average temperatures above those measured 

in similarly situated undeveloped natural areas. What needs to be improved is 

the understanding of the relative role of carbon dioxide concentrations in this 

puzzle. 

Chapter five of the 2011 National Academy of Sciences report: America's 

Climate Choices, lays out the four goals driving the development of the proposed 

regulation: 

1. Limiting Global Mean Temperature Increase (by) 

2. Limiting Global Atmospheric GHG Concentrations (by) 

3. Limiting Global GHG Emissions (including) 

4. Limiting U.S. GHG Emissions. 
The report, while recommending that work to reduce emissions should 

commence, also identifies the following unanswered questions about the goals: 

1. What is a`safe' amount of climate change? Depends on the risks 

associated with given temperature targets, and decisions about willingness 

to tolerate these risks. 

2. How does GHG concentration translate into global temperature change 

and other impacts? Depends on climate sensitivity and the strength of 

other forcing factors (e.g., aeroso/s). 

3. How does a given level of emissions translate into an atmospheric GHG 

concentration? Depends on carbon cycle dynamics and the timing of 

emission reductions. 

4. What is a reasonable share of U.S. emission reductions relative to the 

global targets? Depends on political, economic, and ethical judgments. 

It is prudent to take "no regrets" actions to avoid potential future problems. 

However, this proposal is not a"no regrets" proposal. U.S. EPA predicts that this 

proposal will increase the cost of natural gas and the per KWHr cost of 

residential electricity by around 10% in the next 6 years. Our country already has 

too many completely preventable deaths from hypothermia and heat exhaustion 

every year because people cannot afford to pay their utility bills and eventually 

lose service. This serious human health problem will be exacerbated by the cost 

increases driven by the proposed regulations. 

The most ironic impact of the proposed regulations is that they are likely to 

increase worldwide greenhouse gas emissions by decreasing the international 

competitiveness of U.S. businesses due to increased energy costs. Competitive 

businesses have been investing in cost effective energy savings activities for 

decades. Under this proposal the total cost of the products produced in the U.S. 

will need to increase eroding our international competitiveness and resulting in 

the loss of U.S. manufacturing jobs. When these businesses close, U.S. 

emissions will decrease, but worldwide greenhouse gas emissions will increase 

as our businesses move to areas with less efficient and more carbon intensive 

energy supplies. 

I applaud U.S. EPA for trying to make the most workable regulation to implement 

this misguided policy. But, the fact that this misguided policy will harm Hoosiers 

and other people in our country while actually increasing the worldwide level of 

th,e very emissions it is designed to decrease compels me to ask you to withdraw 

this proposal. 

Thank you.