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# .. ILLINOIS CHAMBER OF COMMERCE 

## Testimony ofTom Wolf, Illinois Chamber ofCommerce USEP A GHG hearing 

### May 24, 2012 Thank you. My name is Tom Wolf and I'm the executive director of the Energy Council at the Illinois Chamber of Commerce. The council is made up of companies that generate, transmit and transport energy, or supply the energy marketplace
. We have voices from worlds of crude oil , coal , wind , solar, nuclear, waste-to-energy, natural gas, utility and transmission and engineering interests
. The Council 's goal is to make Illinois a better place for energy of all kinds because that creates economic opportunities of all kinds
. When it comes to regulatory oversight, businesses are looking for a few general goals:
• Predictability -what can and should they plan for? • A sweet spot where interests are protected but commerce can flourish • Benchmarks that are based on science and not wishful thinking • Diversity - avoiding relying too much on one form of energy if you can We believe the proposed regulations by the US EPA fall short of these goals
. Here are some reasons why:

The most recent regulations from the US EPA on allowable greenhouse gas emissions from future generation sets a limit which most natural gas generators can accommodate with today's technology- but that coal generation cannot. It seems a bit strange that this magic limit saves the planet andjust so happens to allow natural gas generation but not coal generation. I know everyone , including the Chamber, is excited about the new natural gas finds across the country, but it was a few short years ago that we were talking about importing natural gas. Things change in way we cannot predict- for good and sometimes for bad
.From our perspective these regulations are advocating for natural gas generation and creating a regulatory wet blanket on future coal production -- in essence, picking winners and losers
.
We understand there is a provision in the EPA regulations for coal companies to average their GHG emissions over 30 years , theoretically allowing them to build a new plant and retrofit it with sequestration technology when (and if) it becomes available and economical. The Administration claims that there is a 'path forward ' for coal in this rule
. However, the path seems to run through installation of carbon capture and storage - a technology that is still under development and too expensive for use today
. Given that, what company will be able to get financing for a new plant that is built on the hope that new technology will be available and affordable at some point in the future? We don 't believe investors will take that risk
. Three Let's take a moment to comment on how much cleanercoal production has gotten in the past three or four decades
. The Prairie State generation plant that's just about to become fully operational in southwestern Illinois produces 50% less regulated emissions and 15% less GHG emissions using best available control technology- a great step forward
. However, we believe if these proposed regulations come into place, the leap coal producers are asked to make in GHG emissions will be a roadblock to new innovation , not an incentive
. The leap being asked for could result in companies abandoning coal research and moving to other forms of energy - leaving us more vulnerable with fewer supply choices.

We agree with the Administration when it talks about the importance of inventing new alternative energy technologies here in America
. But we believe if these regulations are enacted , the cleaner coal technologies will be invented somewhere else, or they won 't be invented at all because other countries that rely on coal are making no efforts to minimize GHG emissions. We are a leader in cleaner coal technologies and could be going forward
. But asking for this leap of faith could squash our ability to lead the world
. Finally , the Chamber has a concern that is harder to address but is imperative under the concept of predictability
. Whatever regulations that come out of this proceeding , they should not serve as a precursor to regulating GHG from e xisting plants or provide a legal trap door for regulating existing plants when they are modified with new pollution controls to comply with other regulations
. The USEPA has clearly said that they would not treat modified sources as new and that they had no plans or timetable for proposing regulations for existing sources.

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We ask that you stay true to that commitment as there will be voices pushing you to backtrack on that promise
. In closing the Chamber believes all of the above should mean all ofthe above- We believe diversity in our energy portfolio is an important goal and we certainly have many options we couldn 't have dreamed of in past generations
. However, it seems these regu lations push coal aside instead offorward
. Therefore we're going to have to rely on eve rything but coal in our future baseload generation since it's hard to imagine anyone willing to invest in a power source that will be out of compliance before the first kilowatt is generated
. We have 25% of the world's coal reserves . Isn 't it worth trying a bit harder to make it part of the future energy mix? We're afraid these new regulations will thwart, not push , innovation and discourage rather than encourage a diverse portfolio of generation recourses . Since we adm it that we can't predict the future , we hope the government would create an environment where all sources of power have the chance to become more efficient and cleaner
. We believe coal should be an important part of that future and , if regu lations allow the industry to continually improve its production methods , it can provide opportun ities for continued advancements and economic opportunity at home and abroad
. We suggest taking a long , deep breath , and take a hard look at these new regulations and change them to allow new coal plants to be built, incentivized in a way that creates a market for the technological advances that will make coal cleaner and cleaner- and a viable option for a U
.S
. and global electricity users. Thank you .