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Testimony--EPA Carbon Hearings Docket No. EPA-HQ-OAR-2013-0602 (forthe Clean Power Plan for Existing Sources) Pittsburgh, PA August 1, 2014

Prior to retirement, I spent over 30 years in the electric utility and independent power producer industries here in Pennsylvania. I am, therefore, very familiar with most aspects ofthat energy sector, and I am quite knowledgeable about numerous power generation plants in PA, OH andWV. During thattime period, many technological changes occurred. For example, in the late 80's and 90's, great strides were made in the development of equipment and systemsthat now capture high levels ofparticulates, S02, NOX and mercury from the burning ofcoal. At that time, coal and power generation industry advocates argued vociferouslythat this would destroythe industry and be costprohibitive. Neither ofcourse was true. What caused the development ofthese technologies by private industrywith some financial incentives from the Federal Government? Necessity-truly the mother ofinvention. When Clean Air legislation passed, pollution reduction became necessary, and the energy industry realized that it could no longer stall the inevitable and it made plans to invest billions ofdollars in pollution control equipment. I strongly believe that ifadditional carbon reductions are mandated, the same will occur now with technology again providing cost-effective solutions to our energy needs. Many older coal plants have, ofcourse, shut down over the years and many more will close in the future. Generally, these plants are mid-size in terms ofpower generation capacity and they are well beyond their expected plant design life. The plant owners therefore, chose to invest only the minimum amount ofcapital dollars in these plants for manyyears. Indeed, ifyou spoke with the plantworkforces, in many cases they wouldtell you thatthey believe the plants' safety has been compromised due to lack ofadequate maintenance.
While coal currently represents a significant portion ofUS powergeneration, it cannot and will not last. But for now it can and should be made cleaner with technology investment. Natural gas is not a so-called "bridge fuel" when you considerthe entire life cycle pollution ofthat fossil fuel. And, ofcourse nuclear is clearly not a long-term energy solution.
Renewable energy is the only feasible answer to our longterm energy needs, and other nations are doing far better in moving towards this solution to climate change and associated environmental and health problems. Norway, Sweden and even Germany, for example, have veryhigh utilization ofrenewable energy for their power generation in terms ofthe percentage oftotal required energy. Most Americans are ashamed ofthe lack ofsuch energy leadership in the U.S. Afew U.S. companies get it. One ofthe largest independent power producers, that has a huge fleet ofcoal-fired plants, is also investing heavily in existing and new solar and wind plant capacity. Others are likely to do the same.
I am sympathetic to the ultimate loss ofcoal producingjobs. But, renewable forms of energy, such as solar and wind power, are increasingly creating jobs and have the potential to create many more. As fossil fuels become increasingly difficult and expensive to extract, renewables become more cost effective by comparison. Large portions ofcertain energy grids both in the United States and around the world are being supplied by renewables, and
a shift to these industries represents many stable and long-termjobs for Pennsylvanians



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and otherAmericans. EPA should develop a rule that reduces carbon dioxide emissions not only by forcing existing fossil-fueled powerplants to emitless, butalso byencouraginga shiftto renewable energy and development ofeffective energy efficiency programs. The EPA and DOE must continue to financially supportthe developmentofcost-effective renewable forms ofenergy. Such supportmustbe significantand at least equal to the "clean coal" initiatives and all other forms of energy.
Thankyou for the opportunityto provide**th~s** testimony. jack W. Milburn 114 Mountain Road Ligonier, PA 15658 (724) 238-4968

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