Testimony of 

Dr. Jay Apt 

Professor, Tepper School of Business 

and Department of Engineering & Public Policy 

Co-Director, Carnegie Mellon Electricity Industry Center 

Carnegie Mellon University 

412-268-3003 

apt@cmu.edu 

United States Environmental Protection Agency 

Public Hearing on 

Clean Power Plan Proposed Rule 

Docket ID No. EPA-HQ-OAR-2013-0602 

WilliamS. Moorhead Federal Building, Room 1310 

Pittsburgh, Pennsylvania 

July 31, 2014 

My testimony is based on research performed at Carnegie Mellon University, some of which is 

documented in 300 papers in peer-reviewed scientific journals, and some of which has been 

published in the books "Variable Renewable Energy and the Electricity Grid", published in 2014 

by Taylor & Francis and "Carbon Capture and Sequestration, published in 2012 by RFF Press. 

1 
At Carnegie Mellon University, I am a full professor in the Tepper School of 

Business and in the Engineering College. I am also co-director of the Carnegie 

Mellon Electricity Industry Center 1

• 

I commend the EPA for searching for flexible ways to reach the goals of reducing 

the atmospheric concentration of pollutants (including carbon dioxide), enhancing 

energy security, maintaining electric supply reliability, and controlling costs. The 

proposed rules are very likely to decrease forms of pollution that are even more 

immediate issues than greenhouse gas control. A recent peer-reviewed research 

paper in The New England Journal of Medicine shows that even well after the 

Clean Air Act of 1990, further reductions of particulate matter would greatly 

increase life expectancl. The National Academies reported3 that "The aggregate 

[human health] damages associated with emissions from coal-fired facilities in 

2005 were approximately $62 billion." Reducing these costs at the same time that 

greenhouse gasses are controlled is a great strength of the proposed rule. 

The flexibility in the rules is praiseworthy. Rather than mandating a particular 

technology, they allow the states to choose what is most appropriate for them, 

1 The opinions here are mine and do not necessarily reflect the views of Carnegie Mellon University, or any other 

institution. 

2 Pope CA lll, Ezzati M. Dockery DW. 2009. Fine-particulate air pollution and life expectancy in the United States. 

New England J of Med 360:376-386. 3 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use. 

Washington. DC: The National Academies Press, 2010. 

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whether it be nuclear, renewables, efficiency, or fossil fuels with greenhouse gas 

capture. 

I have spent much of the past decade studying renewable power. Wind currently 

provides about 4% of all the electric power in the USA. In my view, wind can 

certainly grow to provide 20%, before issues arising from land use are likely to 

restrict further wind plants. Solar may grow greatly, from its present 1/SOO'h of all 

power to perhaps 5%. 

Low-pollution nuclear power now supplies 20% of our electricity. That leaves a 

big gap between our needs and what nuclear and renewables can supply . 

It is simply not in the cards to generate enough power without using America's 

abundant coal and gas resources. But the issue with coal and natural gas is this: 

long before we run out of fossil fuels we will run out of atmosphere into which to 

dump their combustion products (like C02). Doomsday predictions of coal's 

demise are overblown. In fact, Bloomberg News reported July !61

h that US imports 

of coal will increase 26% in 2014 over 2013. The EPA's proposed rules allow the 

use of America's vast reserves of carbon-based fuels without emitting much carbon 

dioxide to the air. That is a big advantage. The proposal also allows the use of 

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uranium, transformed into energy by bright engineers like those at Westinghouse 

nuclear here in Pittsburgh. 

I teach in a business school; I believe in American industry's ability to innovate 

when there is a reason to do so. We did exactly that in response to the Clean Air 

Act of 1970. The number of patents filed for sulfur dioxide pollution control 

technologies increased by a factor of 20 after the regulations. And we profited by 

selling that technology around the world. 

120 

110 ., 100 :!! 

·- 90 

~ so 

;:; '0 

~ 60 '-

~ 50 ... ~0 

.;; "30 § cO z: 

10 

0 

Creation o fERDA 1975 

& Dept of Energy 1 977 ~--..-

+----------------------

C.S. Clean Air 

Actofl970 - _____ ._. __ 

ISSO 1890 1900 1910 19CO 1930 19~0 1950 1960 1910 1990 1990 cOOO 

Year Patent Filed 

US S02 control patent activity over time 4 

EPA's proposed rule will foster innovation and create jobs. Coal power plant C02 

pollution control is feasible, and the first plants are being constructed at scale now. 

Southern Company's 582 MW Kemper plant will be in operation in the next year, 

4 Source: Taylor, M.R., E.S. Rubin, and D.A. Hounshell, Regulation as the Mother oflnnovation: The Case ofS02 

Control. Law & Policy, 2005. 27(2): 348-378. 

4 
as will a 110 MW plant in Canada. Just this month NRG Energy announced that 

they are moving forward on their 240 MW coal plant with C02 capture in Texas. 

This proposed rule provides the proper incentives for low-pollution power, and the 

flexibility for states to reduce pollution in sensible ways. It should be adopted. 

Thank you. 

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