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• • ~ 

I LLINOTS CHAMBER 

OF COMMERCE 

TOM WOlf 

Execuuve Directoo 

llllnoos Chambeo Eneogy Counc1l 

twolf@ilchamber.org 
.I. 

~ 

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.. 

ILLINOIS CHAMBER 

OF COMMERCE 

Testimony of Tom Wolf, Illinois Chamber of Commerce 

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 and just 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 cleaner coal 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 existing 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. 
- ,. 

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 of the 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 regulations push coal 

aside instead of forward. Therefore we're going to have to rely on everything 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 admit 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 regulations allow the industry 

to continually improve its production methods, it can provide opportunities 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.