~ CLEAN'AIR 

TASK FORCE 

Testimony of Jay Duffy, Clean Air Task Force 

EPA Public Hearing on Proposed Clean Power Plan under Clean 

Air Act Section 111W 

Washington, D.C. 

July 30, 2014 

On behalf of the Clean Air Task Force, I want to commend EPA for taking this important 

step to reduce carbon pollution from existing power plants, the nation's largest source of 

anthropogenic carbon dioxide. Issuing carbon dioxide standards for existing fossil fuel-fired 

power plants is clearly within EPA's authority under the Clean Air Act and indeed required by 

the statute in conjunction with EPA f+%i#0*V-W proposed new and modified source standards 

for carbon dioxide from this industry. The need to achieve greenhouse gas reductions is 

immediate, and we applaud you for taking this important step. 

Carbon dioxide contributes significantly to climate change and climate change-induced 

harms to public health and welfare: drought, and related adverse effects on our agriculture 

systems and water supplies; increases in serious insect-borne illnesses like Lyme disease; the 

increase in severe weather and weather-related events like wildfires and flooding; increased 

ground level ozone; and adverse effects on wildlife and ecosystems. 

The pollutant's characteristics highlight the pressing need to immediately reduce carbon 

dioxide emissions. Uncontrolled fossil fuel-fired electric generating plants emit carbon dioxide in 

large amounts and that are very long-lived — a significant percentage of each ton emitted remains 

aloft causing climate harm for thousands of years. That fact alone makes near term reductions 

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imperative in order to mitigate the effects of continuing dangerous rates of accumulation and 

associated damage. 

CATF, like others, is currently working through the details of this complex proposal. My 

comments today are based on our preliminary analysis of the Clean Power Plan and will be 

supplemented with written comments. 

The state goals EPA developed under the Plan are reasonable. That is true for the state 

goals based on EPA's four BSER building blocks and the state goals requiring nearer term 

reductions based only on BSER building blocks 1 and 2. Indeed, CATF has modeled an existing 

source performance standard approach that is similar to EPA's proposed BSER building blocks 1 

and 22 We found there is sufficient underutilized, existing, and efficient generation from natural 

gas plants to displace generation from high emission rate coal-fired power plants, achieving near 

term carbon dioxide reductions very cost effectively. Indeed, in many states we see the 

opportunity for greater average availability of underutilized natural gas generation than the 70 

percent ceiling proposed by EPA. 

On the implementation side, many states also have the option of retrofitting existing 

power plants with carbon capture utilization and storage technology either using enhanced oil 

recovery or saline sequestration. Retrofit CCUS technology is available and demonstrated and 

can provide significant carbon reductions. The Boundary Dam Power Plant retrofit project in 

Canada has now begun producing power, for example. This project and Southern Company's 

Kemper County CCS retrofit project in Mississippi are both nearing completion. The captured 

carbon dioxide from these projects will be used in ongoing EOR activity. States like Texas, 

Oklahoma, Louisiana, Mississippi and Kansas have existing power plants — both coal and gas- 

' CATF, Power Switch: An Effective, Affordable Approach to Reducing Carbon Pollution from Existing FossilFueled Power Plants, (Feb. 2014) available at: http://www.catf.us/resources/publications/files/Power_Switch.pdf. 
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fired --that may be candidates for retrofits and are located near EOR sequestration opportunities. 

For example, plans are moving forward to retrofit the W.A. Parish Plant in Houston, Texas and 

begin capturing COzemissions in 2016. Midwestern states also have existing plants that may be 

candidates for retrofits and are near saline sequestration opportunities. For example, the 

FutureGen 2.0 Project retrofit to an existing power plant in Illinois plans to come online in 2017. 

Finally, EPA must require states to achieve real, permanent, enforceable, and verifiable 

carbon dioxide reductions from existing sources in this industry. To that end, CATF supports 

mass-based compliance made easier for states by EPA issuing a"model rule" to allow the 

maximum number of states to take advantage of the efficiencies of broad interstate trading. A 

mass-based approach is an efficient and effective mechanism for achieving enforceable pollution 

reductions, and one with which most states already have experience. 

Thank you for the opportunity to comment on this critically important and historic rule. 

CATF looks forward to continuing its work with the Agency to ensure that the Clean Power Plan 

achieves meaningful carbon pollution reductions from the existing power fleet.