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July 30, 2014 Statement of Steven M. Jackson, Senior Vice President and Chief Operating Officer Municipal Electric Authority ofGeorgia (MEAG Power) Atlanta, Georgia Atlanta, Georgia Public Hearing on Proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric UtilityGenerating Units 79 Fed. Reg. 34830, June 18, 2014

Docket EPA-HQ-OAR-2013-0602
Good afternoon, Iam Steven Jackson, SeniorVice President and ChiefOperating Officerofthe Municipal Electric Authority of Georgia commonly known as MEAG Power. MEAG Powerwas solely created forone purpose, to serve our49 member public power communities in Georgia with reliable and affordable wholesale electric power. We operate without profit and have no shareholders. Our costs incurred for supply of power are directly reflected in the electric bills ofthe retail electricity consumers in these 49 communities. It is on behalfofthe citizens ofthe 49 communities that I providethese comments today; for they are the ones that will bear the impact ofthese rules. The regulatory approach on this proposed rule goes well beyond the limits of Section lll(d) ofthe Clean Air Act and errs in its approach in manyways. The proposed rule infringes on state and local authorityto regulate the electric utility business and on the utilities' abilityto plan and operate the electricity supply system in a mannerthat considers cost and reliability. Specific issues include:

• The proposed rule appears designed to achieve 30% national reduction in tons ofcarbon dioxide vs. 2005 forthe powersector as awhole. This is not what Section lll(d) requires. Section lll(d) only authorizes standards of performance on individual affected sources.

• The proposed rule mandates state "goals" that go far beyond setting standards on the affected sources, employing a "Best System of Emission Reduction" extending its reach beyond the "fenceline" ofaffected sources.

• The 6% emission rate reduction goal-setting for coal units is applied everywhere, but is not achievable at most units.

• The NGCC 70% capacity factor re-dispatch for goal-setting is notan emissions standard. It increases NGCC emissions and does not consider reliability, cost, or ownership.

• Including under-construction new nuclear and "at-risk" existing nuclear in goal-setting is outside Section lll(d) authority.

• Including renewables and energy efficiency in goal-setting infringes on state and local authority.The current supply to our 49 membercommunities consists ofover 1200 MWs ofnuclearand hydroelectric powercapacity. The result is that over SO% ofthe electricity supplied to the communities is produced while creating no emissions. This proposed rule provides little credit forthese carbon free resources and instead would require these communitiesto fund new, unneeded renewable energy resources and new energy efficiency programs which raise the cost to electric consumers in the communities unnecessarily. Looking to invest in the future oftheir communities, our members have notonly committed to the construction of new non-emitting resources in Vogtle Units 3 and 4, but have also funded Y, billion dollars in state- of-the-art emission control improvementsforour coal generating resources based on recent federal and state rules. This proposed carbon dioxide rule penalizes the communitiesforthese investments by asking for more emission reductions from the State ofGeorgia, which has seen substantial reductions in carbon dioxide emissions since 2005. The proposal approach does not consider our nuclear investments. The proposal would also require reduced coal unit operation, potentially even requiring shutdown ofthe units, which strands the cost ofthe recent environmental investments and again raises the cost ofelectricity to consumers in the communities. Each hourofthe day MEAG Power manages the use ofour diverse mix ofgenerating resources in order to provide the lowest cost wholesale powerfor our49 communities,which is essential to their growth and prosperity. This principle ofeconomic dispatch is the foundation of power industry operation and allowsfor use ofa diverse set offuels and resources in a mannerthat ensures the citizens receive the benefit oftheir investment. Again this proposed rule goes well beyond what is allowed underthe Clean Air Act and dictatesthe operation ofthe generating resources, preventingthe economic dispatch ofthe system which would unnecessarily raise the cost to electric consumers. This proposal goes well beyond the requirements ofSection lll(d) ofthe Clean Air Act and will create costs that will flow directlyto the citizens in the communities we serve. Manyofthese citizens are low and fixed income and can least afford an increase in their electricity costs. This proposal should be withdrawn and replaced with a proposal based on whatthe Clean Air Act actually requires and that States can implement undertheir current laws. Thank you for this opportunityto provide these comments. I appreciate yourtime today.