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Testimony--EPA Carbon Hearings 

Docket No. EPA-HQ-OAR-2013-0602 (for the 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 

of that energy sector, and I am quite knowledgeable about numerous power generation 

plants in PA, OH and WV. During that time 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 systems that now capture high levels of particulates, S02, NOX and mercury 

from the burning of coal. At that time, coal and power generation industry advocates 

argued vociferously that this would destroy the industry and be cost prohibitive. 

Neither of course was true. What caused the development of these technologies by private 

industry with some financial incentives from the Federal Government? Necessity-truly 

the mother of invention. 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 of dollars in pollution control equipment. I strongly believe 

that if additional 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, of course, shut down over the years and many more will close 

in the future. Generally, these plants are mid-size in terms of power generation capacity 

and they are well beyond their expected plant design life. The plant owners therefore, 

chose to invest only the minimum amount of capital dollars in these plants for many years. 

Indeed, if you spoke with the plant workforces, in many cases they would tell you that they 

believe the plants' safety has been compromised due to lack of adequate maintenance. 

While coal currently represents a significant portion of US power generation, 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 consider the entire life cycle pollution 

of that fossil fuel. And, of course nuclear is clearly not a long-term energy solution. 

Renewable energy is the only feasible answer to our long term 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 very high utilization of renewable energy for their power generation in 

terms of the percentage of total required energy. Most Americans are ashamed of the lack 

of such energy leadership in the U.S. A few U.S. companies get it. One of the largest 

independent power producers, that has a huge fleet of coal-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 of coal producing jobs. 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 of certain 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-term jobs for Pennsylvanians 

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and other Americans. EPA should develop a rule that reduces carbon dioxide 

emissions not only by forcing existing fossil-fueled power plants to emit less, but also 

by encouraging a shift to renewable energy and development of effective energy 

efficiency programs. The EPA and DOE must continue to financially support the 

development of cost-effective renewable forms of energy. Such support must be 

significant and at least equal to the "clean coal" initiatives and all other forms of 

energy. 

Thank you for the opportunity to provide th~s testimony. 

jack W. Milburn 

114 Mountain Road 

Ligonier, PA 15658 

(724) 238-4968 

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