• 

July 30, 2014 

Statement of 

Steven M. Jackson, Senior Vice President and Chief Operating Officer 

Municipal Electric Authority of Georgia (MEAG Power) 

Atlanta, Georgia 

Atlanta, Georgia Public Hearing on 

Proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: 

Electric Utility Generating Units 

79 Fed. Reg. 34830, June 18, 2014 

Docket EPA-HQ-OAR-2013-0602 

Good afternoon, I am Steven Jackson, Senior Vice President and Chief Operating Officer of the Municipal 

Electric Authority of Georgia commonly known as MEAG Power. 

MEAG Power was solely created for one purpose, to serve our 49 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 of the 

retail electricity consumers in these 49 communities. It is on behalf of the citizens of the 49 communities 

that I provide these comments today; for they are the ones that will bear the impact of these rules. 

The regulatory approach on this proposed rule goes well beyond the limits of Section lll(d) of the Clean 

Air Act and errs in its approach in many ways. The proposed rule infringes on state and local authority to 

regulate the electric utility business and on the utilities' ability to plan and operate the electricity supply 

system in a manner that considers cost and reliability. Specific issues include: 

• The proposed rule appears designed to achieve 30% national reduction in tons of carbon dioxide 

vs. 2005 for the power sector as a whole. 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 

"fence line" of affected 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 not an 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 member communities consists of over 1200 MWs of nuclear and 

hydroelectric power capacity. The result is that over SO% of the electricity supplied to the communities 

is produced while creating no emissions. This proposed rule provides little credit for these carbon free 

resources and instead would require these communities to 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 of their communities, our members have not only 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 improvements for our coal generating resources based on 

recent federal and state rules. This proposed carbon dioxide rule penalizes the communities for these 

investments by asking for more emission reductions from the State of Georgia, 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 of the units, which strands the cost of the recent environmental investments and 

again raises the cost of electricity to consumers in the communities. 

Each hour of the day MEAG Power manages the use of our diverse mix of generating resources in order 

to provide the lowest cost wholesale power for our 49 communities, which is essential to their growth 

and prosperity. This principle of economic dispatch is the foundation of power industry operation and 

allows for use of a diverse set of fuels and resources in a manner that ensures the citizens receive the 

benefit of their investment. Again this proposed rule goes well beyond what is allowed under the Clean 

Air Act and dictates the operation of the generating resources, preventing the economic dispatch of the 

system which would unnecessarily raise the cost to electric consumers. 

This proposal goes well beyond the requirements of Section lll(d) of the Clean Air Act and will create 

costs that will flow directly to the citizens in the communities we serve. Many of these 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 what the Clean Air Act actually requires and that 

States can implement under their current laws. 

Thank you for this opportunity to provide these comments. I appreciate your time today.