### Testimony EPA's Proposed Rule "Standards ofPerformance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units" Docket Number EPA-HQ-OAR-2011-0660

Presented by Mandy Warner Climate & AirPolicy Specialist

Environmental Defense Fund
May 24, 2012 Public Hearing Washington, D.C.

My name is Mandy Warnerand I am with Environmental Defense Fund (EDF). a non-partisan environmental organization with more than 750,000 members nationwide. EDF is dedicated to working towards innovative. cost-effective solutions to environmental problems. building on a foundation ofrigorous science, economics, and law.

Thank you for the opportunity to testify today. The proposed standards are an important step towards addressing the massive quantities ofclimate destabilizing pollution emitted from U.S. power plants. one ofthe largest sources ofgreenhouse gases (GHG) in the world. By halving the lifetime carbon emissions from new coal-fired powerplants relative to traditional coal plants, these historic clean air standards will provide long overdue and urgently needed protections for

our health and climate while strengthening our made-in-the-U.S.A. clean energy economy.



### Buckxround Climate change presents a clear and present danger now to the U.S. and to the world. The National Oceanic and Atmospheric Administration recently announced thatthe lJ.S. completed the single warmest 12-monthperiod on record.' Over the May 2011 to April2012 period all of the Mid-Atlantic states experiencedrecord warn1 or much above normal temperatures."

Leti unchecked. climate change will have severe impacts on Americans' health. our environment. and our economy. The U.S. Global Change Research Program has detern1ined that ifcarbon pollution is not reduced, it is likely that American communities will experience increasingly severe climate impacts. including: rising levels ofdangerous smog in cities-which will lead to an increased risk ofrespiratory infections. more asthma attacks. and more premature deaths: increased risk ofillness and death due to extreme heat: more intense huiTicanes and storm surges: increased frequency and severity offlooding; increases in insect pests and in the prevalence ofdiseases transmitted by food, water. and insects; reduced precipitation and runoffin the arid West: reduced crop yields and livestock productivity; and more wildfires and increasingly frequent and severe droughts in someregions.ill



### Greenhouse Gas Burdenji-om the U.S. Power Sector U.S. power plants fueled by coal and gas arc the single largest source ofcarbonpollution in our nation and one ofthe largest emitters ofclimate-destabili;.cing pollution in the world. The U.S. power sector is responsible for approximately

### 40'Yo ofall carbon pollution in the U.S and emits

more GIIGs than Russia. India, Japan. or Germany." Buildingjustone inefficient. emissionintensive plant today locks us into millions oftons offuture climatepollution-orthe expensive alter-the-fact shuttering orbuilt infrastructure that releases harmful pollution. We cannot effectively address climate-destabilizingemissions without addressing the pollution emitted by the power sector.


### U.S. Powet· Generation GHG Emissions Surpass Emissions from Most Countries (fv1i!lion Metric Tons CO? Equivalent;



# 1111111111111**~:cu1ce** UNFCCC -Sixth .:::omcllatiOF and syntr,esrs of 1n1ltd· :lat;cnalco-:cmun,cattor,st1or,' part1es nottnclv:!ed ,n Annex Ito :he convent1cn. ;;JrlC: Nallona'**Gr~r.house** Gas**:nv2r:tO~'' D~tA**  tor t',e o.eriod 19-:JC'- 201)9 :reiiKHng Ann-ex I counrr,es:



### InnovativeApproaches Fortunately, ournation has the innovative solutions and the know-how to meet this pressing challenge while strengthening our economy. Numerous states across the U.S. are already limiting carbonpollution from newpowerplants, like Minnesota, Montana. and Washington. Ten leaders ofstate environmental agencies also recently wrote to EPA expressing their support for the standard, including Connecticut. Delaware, Maryland. Massachusetts, Rhode Island, Vermont. and the District ofColumbia.' Furthermore, overtwo dozen states have policies in place to harness the economic and environmental benefits ofcleanerenergy. Twenty-four states have standards in place that will drive investmentin energy efficiency, saving Americanhomes and businesses money while reducing emissions. Many other states have developed policies to support innovation in clean, sustainable energy and to make their economies more efficient.These standards are aligned with market forces that are already driving utilities to develop cleanertechnologies. An April 

### 2012 World Resources Institute report explains that •·]ower natural gas prices. declining grovv1h in electricity demand, rising coal prices. and increased costcompetitivenessofrenewables" arc shapingbusiness decisions in the utility sector."

Leaders within the utility industry recognize the importance and achievability ofEPA'sproposed standards. Por instance. Ralph lzzo. CEO ofPublic Service Enterprise Group. issued the following statement after EPA releasedthe proposal:



### "'The Agency "s 

### action establishes a logical andmodest standardfornew electricpowerplants andprovides the industry with much neededregulatory certainty. The EPAprovides a .frameworkjiH'the industry to confront thisproblem in a cost effective manner.·

New clean airstandardsare a criticalstepin 

### the rightdirection Under EPA·s standards the nation's energy needs canbe met through a diverse, efficient mix of power sources. includingrenewable energy. efficientnatural gas power plants, combined heat and power. and improvements in the efficiency ofour energy use. The standards also provide a pathway for the development ofcarbon capture and sequestration for coal plants. The New Source Performance Standards for carbon pollution will provide power companies with regulatory certainty for prudent, long-term investments in cleaner. homegrown energy thatputs Americans to work. The technology we need is available today and the time has come when we
can no longer afford to build new. uncontrolled coal plants that discharge vast volumes ofGHG pollution for fifty years ormore, recklessly imperiling ourhealth, our environment and our prosperity. EPA's proposed limits on GHGpollution from fossil fuel powerplants are essential to address climate change. to drive innovation in clean energy solutions, to ensure a steady t1ow of cost-effective and cleaner electricity to poweroureconomy, and to protect the health and wellbeing ofAmericans, now and in the future.

EDF will also be submittingfurther technical comments onthe proposed rule. Thank you again for the opportunity to testify. I am happy to answer any questions you may have.

'National Oceanic and Atmospheric Administration. http://vvww.ncdc.noaa.gov/sotc/national/20 12/4. (accessed May 14. 2012).

11 National Oceanic and Atmospheric Administration. http://www.ncdc.noaa.gov/temp-andQIITi.Rlmaps.php?ts= 12&vear=2012&month=4&imgs[J=Statewidetrank&submitted:..:Submit. (accessed May 14. 2012). '"U.S. Global Change Research Program, http://www.globalchange.gov/. "Source: UNFCCC- Sixth compilation and synthesis ofinitial national communications from parties not included in Annex Ito the Convention. and National Greenhouse Gas Inventory· Data for the period \990- 2009 (reflecting Annex Icountries). "' Letter to Administrator Lisa Jackson. Re: Standards (?f"Perj(Jrmanccfor Greenhouse Gas Emissions for /'v'ert· StationmySources: Electric Utility Generating Units. May 9. 2012. '' World Resources Institute. Fact Sheet. "U.S. ELECTRICITY MARKETS INCREASINGLY 

### rAVOR ALTERNATIVESTO COAL."