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Oral Testimony of Amelia Shenstone to the EPA regarding Docket No. EPA-HQ-OAR2013-0602, the "Clean Power Plan," presented July 29, 2014 

I would like to begin by commending EPA for publishing this 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 about the greenhouse effect and global warming was in my gth 

grade earth science class. We learned about it just as we learned about the hole in the 

ozone layer and acid rain. Since America had joined with the world to tackle these 

problems, I expected we'd do the same for carbon dioxide. I didn't appreciate the vast 

political challenges at the time. 

~0~"' \ ~t' I ~(\.\ , ·•ti>q.J.\ v \..)~'" 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 of mountaintop removal in 

West Virginia, working to bring renewable energy to the coalfields. I've talked to 

thousands of coastal Louisianans about the 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 opportunities for smart energy choices like efficiency, solar 

and wind, mainly in Georgia and Alabama. Now, I understand the political challenges a 

little better. 
I work on clean energy because it's the intersection of environmental justice and 

economic justice- 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 beach front real estate in Miami, or those who need help 

to fix up old leaky homes so they're not paying to 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 how energy decisions are made. 

I am here today to urge EPA to not let utility companies convince you or anyone else 

that consumers will necessarily pay more to meet carbon emission limits. If customers 

pay more, it will likely be because utilities like Georgia Power and Alabama Power and 

their friendly 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 a story about one utility, Alabama Power, as an example. Between this 

year and 2018, Alabama Power will spend over a billion dollars to keep its old coal plants 

running, on top of a couple billion they've already spent. 1 The company earns a roughly 

13.5% guaranteed profit- about 40% higher than the industry average of around 10% 

profit margin. Basically,~e more they spend, the more they make, so it's no wonder 

1 According 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 -inform a 1-hearing/ 
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when it comes to future energy resources, they choose an expensive approach! 

Unfortunately, Alabama does not require a transparent comparison of the 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 lower for Alabama Power customers if the company followed 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 efforts to 

comply with the Clean Power Plan will in fact lower rates over time. We also know that 

energy efficiency lowers BILLS- and that is better for consumers, no question. 

The potential to create a comparison process that fairly values energy efficiency and 

renewables as generation resources is one of the many benefits of this rule. But given 

the profit incentive of the status quo, we can expect utilities to protest, and the elected 

officials to whom they contribute, to remain in lock step. 

So when you feel pressure to back off, please remember why you chose to work in 

Environmental Protection, and stay strong for the solutions we need to protect our 

planet AND the people. Help these utilities see the tremendous power you've given 

them to use creative, clean solutions. Give this country the strong final carbon pollution 

rule we've needed since I was a kid.