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 ~ 

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: 812-876-3476 
be 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. 

Sincerely, 

, 

Michalene Reilly, CHMM ~ 

Manager, Environmental Services