### • Oral Testimony ofAmelia Shenstone tothe EPA regarding Docket No. EPA-HQ-OAR2013-0602, the "Clean Power Plan," presentedJuly29, 2014 I would like to begin by commending EPA for publishingthis draft rule to responsibly and achievably limit carbon pollution. Keeping the rule at least as strong as it is now, in its final version, is essential to saving places and people I hold dear. The first time I heard aboutthe greenhouse effect and global warming was in my gth grade earth science class. We learned about itjust as we learned aboutthe hole in the ozone layer and acid rain. Since America had joined with the world totackle these problems, I expected we'd dothe same for carbon dioxide. Ididn't appreciate thevast political challenges atthe time.



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**\..)~'"** Yet the'laith I was raised in calls me to participate in making the world I live in a better place, so I've tried to do my part. I've lived in the shadow ofmountaintop removal in West Virginia, working to bring renewable energytothe coalfields. I've talked to thousands ofcoastal Louisianans aboutthe storm surge protection they're losing, as seas rise and marshes are cut away by oil and gas companies. Today, I'm an organizer with the Southern Alliance for Clean Energy, working to reduce our dependence on coal for electricity, and increase opportunitiesfor smart energy choices like efficiency, solar and wind, mainly in Georgia and Alabama. Now, I understand the political challenges a little better.Iwork on clean energy because it'sthe intersection ofenvironmentaljustice and economicjustice- wealth creation that can benefit everyone. It is essential to the most vulnerable among us- those who cannot relocate, for example, as their inland communities become high-rent beachfront real estate in Miami, orthose who need help tofix up old leaky homes so they're not payingto air condition the back yard, who then suffer even more as heat waves increase. These are often the people who have the least say in howenergy decisions are made. I am heretoday to urge EPA to not let utilitycompanies convince you oranyone else that consumers will necessarily pay moreto meet carbon emission limits. Ifcustomers pay more, it will likely be because utilities like Georgia Power and Alabama Power and theirfriendly regulators choose to prioritize profits over cost-saving benefits to billpayers. Some utilities, like TVA, are moving in the right direction, while others may need stronger guidance from EPA. I'd like to tell astoryabout one utility, Alabama Power, as an example. Between this year and 2018, Alabama Powerwill spend over a billion dollars to keep its old coal plants running, on top ofa couple billion they've already spent. 1The company earns a roughly 13.5% guaranteed profit- about 40% higher than the industryaverage ofaround 10% profit margin.



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1According to documents presented by Alabama Power to the Alabama Public Service commission on Dec 10, 2013. For more, see http://blog.cleanenergy.org/2013/12/12/alabama-power-distracts-from-realissues-at-informa1-hearing/

# • when it comes to future energy resources, they choose an expensive approach! Unfortunately, Alabama does not require atransparent comparison ofthe costs of energy generation choices, so there is virtually no check on this profit incentive. The lack of balance between profit and prudence is what really hurts ratepayers. Would rates be lowerfor Alabama Power customers ifthe companyfollowed the lead of many southeastern peers and let some coal capacity go, investing instead in cleaner sources, particularly energy efficiency programs? I believe the answer is yes, and EPA's own research confirms that prioritizing energy efficiency and renewables in effortsto comply with the Clean Power Plan will in fact lower rates overtime. We also knowthat energy efficiency lowers BILLS- and that is betterfor consumers, no question. The potential to create a comparison process that fairlyvalues energy efficiency and renewables as generation resources is one ofthe many benefits ofthis rule. But given the profit incentive ofthe status quo, we can expect utilitiesto protest, and the elected officials towhom they contribute, to remain in lock step. So when you feel pressure to back off, please remember whyyou chose to work in Environmental Protection, and stay strong forthe solutions we need to protect our planet AND the people. Help these utilities see thetremendous poweryou've given them to use creative, clean solutions. Give this countrythe strongfinal carbon pollution rule we've needed since Iwas a kid.