## Testimony of Dr. JayApt Professor, Tepper School ofBusiness and Department ofEngineering & Public Policy Co-Director, Carnegie Mellon Electricity Industry Center Carnegie Mellon University 412-268-3003 apt@cmu.edu 

## United StatesEnvironmentalProtection Agency Public Hearing on Clean PowerPlan ProposedRule DocketID No. EPA-HQ-OAR-2013-0602 WilliamS. Moorhead Federal Building, Room 1310 Pittsburgh, Pennsylvania 

## July 31, 2014
My testimony is based onresearch performed at Carnegie Mellon University, some ofwhich is documented in 300 papers in peer-reviewed scientificjournals, and some ofwhich 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.

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### At Carnegie MellonUniversity, I am a full professor in the Tepper School of Business and in the Engineering College. I am also co-director ofthe Carnegie Mellon Electricity Industry Center 1•


### I commend the EPA for searching for flexible ways to reach the goals ofreducing the atmospheric concentration ofpollutants (including carbon dioxide), enhancing energy security, maintaining electric supply reliability, and controlling costs. The proposed rules are very likely to decrease forms ofpollution that are even more immediate issues than greenhouse gas control. A recentpeer-reviewed research paper in The NewEngland Journal ofMedicine shows that even well after the Clean Air Act of 1990, further reductions ofparticulate 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 ofthe proposed rule.
The flexibility in the rules is praiseworthy. Rather than mandating aparticular 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 ofCarnegie 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 JofMed 360:376-386. 3 National Research Council. Hidden Costs ofEnergy: Unpriced Consequences ofEnergy Production and Use. Washington. DC: The National Academies Press, 2010. 2

### whether it be nuclear, renewables, efficiency, or fossil fuels with greenhouse gas capture.
I have spent much ofthe past decade studying renewable power. Wind currently provides about 4% ofall 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 windplants. Solar may grow greatly, from its present 1/SOO'h 

### ofall powerto perhaps 5%. Low-pollution nuclearpowernow supplies 20% ofour electricity. That leaves a big gap between ourneeds 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. Butthe issue with coal and natural gas is this: long before we run out offossil fuels we will run out ofatmosphere into whichto dump their combustionproducts (like C02). 

### Doomsday predictions ofcoal's demise are overblown. In fact, Bloomberg News reported July !61 h 

### that US imports ofcoal will increase 26% in 2014 over 2013. The EPA's proposed rules allowthe use ofAmerica's vast reserves ofcarbon-based fuels without emitting much carbon dioxide to the air. That is a big advantage. The proposal also allows the use of 3uranium, 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 ofpatents filed for sulfur dioxide pollution control technologies increased by a factor of20 after the regulations. And we profited by selling that technology around the world.
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**19~0** 1950 1960 1910 1990 1990 cOOO Year PatentFiled US S02 controlpatentactivity over time4 EPA's proposed rule will foster innovation and createjobs. Coal power plant C02 pollution control is feasible, and the first plants are being constructed at scale now. Southern Company's 582 MWKemperplantwill 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. 4as will a 110 MWplant in Canada. Justthis month NRGEnergy announcedthat they are moving forward on their 240 MW coal plant with C02 capture in Texas.
This proposedrule provides the proper incentives for low-pollution power, and the flexibility for states to reduce pollution in sensibleways. It should be adopted.
Thank you.

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