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.