# HOOSIERENERGY

R U R A L ELECTRIC C O O P E R A T I V E, I N C. A Touchstone Energy' Cooperative 

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July 30, 2014

Ms. Gina McCarthy US Environmental Protection Agency William Jefferson Clinton Federal Building 1200 Pennsylvania Avenue N.W. Washington, DC 20004 RE: Comments on Existing Pflwer Plants Carbon Regulations Docket Number EPA-HQ-OAR-2013-0602 Ms. McCarthy: My name is Michalene Reilly, Manager of Environmental Services for Hoosier Energy Rural Electric Cooperative, a Generation and Transmission Cooperative with members in 59 counties in central and southern Indiana and Southeastern Illinois. Being a member driven Cooperative, our mission is to provide reliable low cost power in a safe and environmentally acceptable manner. We appreciate this opportunity to provide comments on the proposed rule to regulate greenhouse gases from existing power plants. Hoosier Energy is concerned with many aspects of the rule. Today I will cover just one of those concerns: the four building blocks. More extensive comments will be filed by the end of the comment period Power Plant Energy Efficiency EPA's contention that power plants have the ability to decrease their heat rate and therefore improve plant efficiency by 6% is a concern. In talking to many utilities about this issue, we have not heard of a single plant that can achieve anything more than 1-2%, and at a tremendous cost. The efficiency increases that are cost effective have already been made. It should be noted that at a plant such as the Hoosier Energy Merom Generating station, approximately 56% of power for use at the site is for pollution control equipment. National Gas Combined Cycle Capacity As with many utilities, Haosier Energy has faund natural gas unavailable in times af extreme weather and under other conditions. This has happened both at combined cycle and peaking facilities. Unfortunately, setting a goal does not diminish the issue of inadequate pipelines and storage facilities. Electric utilities like Hoosier Energy have no control over the lack of natural gas infrastructure. EPA must examine these constraints and adjust the goal for states that cannot

P.O. Box 908 • BLOOMINGTON, INDIANA 47402-0908 • PHONE: 812-876-2021 • FAX: 812-876-3476be assured gas availability. Many combined cycle facilities were not built to run at such a high

capacity factor. The constraints of the units themselves need to be considered. Renewable Energy: Hoosier Energy is concerned with statements made by many top personnel from EPA that this rule is meant to be flexible, yet each speech seems to narrow the interpretation of what is included in the building blocks. EPA should be promoting every possible way of allowing any greenhouse emission reduction or offset to be included. The renewables portion should include all types of new renewables inclutling small hydro, landfill and cflal bed methane, as well as allowing for offsets. It has been proven that offsets such as increased forestry can utilize some of the CO2 being generated allowing for power plants to continue to operate for the remainder of their useful life. Demand Side Management and Energy Efficiency One way to reduce greenhouse gas emissions is to not generate them. However, demand side management and demand side energy efficiency take agreements on both sides of the equation, both the utility and the consumer. Hoosier offers many incentives both for demand side management and energy efficiency, without any mandate from the state. However, even with subsidies and incentives, you can not force horneowners to take advantage of these offers and raising power prices so high that people will be forced into it, is not equitable for low income rural communities or for commercial and industrial consumers served by our Members. In a not for profit cooperative, the costs of every incentive are spread across all of the Member consumers. EPA must look for other incentives that can work for low income retail consumers and not unfairly punish others. We would request that EPA work with us to develop cost effective ways to reduce carbon without causing significant economic harm to our rural communities. We look forward to working with you. You can contact me directly at (812)935-4712 or mreill &hevn.com

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### Sincerely,

, Michalene Reilly, CHMM 

# ~ Manager, Environmental Services