1 From: Mike Anderson [manderson@nelbro.com] Sent: Wednesday, November 27, 2013 1:06 PM To: Carbon Pollution Input Subject: New EPA Ruless for the Coal Industry

Some thoughts to consider:

• This rule will have a massive economic impact, not just in the electric sector but into the rest of the economy

as well.

• These EPA rules will have no discernible impact on global warming—even though that is the rationale

b ehind them. The rest of the world continues to aggressively pursue affordable fossil fuel-based fuel

sources.

If the EPA must act, here are some of our suggestions:

• Ensure that their regulations don’t harm American jobs and the economy while being reasonable and

t echnologically achievable.

• Their regulations must be flexible enough to take into account the diverse needs of many distinct

g eographical areas while respecting the States rights to retain primary responsibility for developing
performance standards.

• Any regulation must undergo a thorough cost-benefit analysis and be tailored to impose the least burden on

i ndividuals and businesses as possible. The analysis should also take into account the cumulative impact of
interconnected industries and regulations and report on potential employment losses.

• The EPA should also seek input from States like North Dakota that have successfully demonstrated how to

h arness the benefits of coal based electricity in an environmentally sound manner. The EPA should hold at
least one listening session in North Dakota.
Sincerely,

M ichael T. Anderson
Safe ty & Compliance Manager Office: (307) 687-0776 Mobile: (307) 660-4526

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Please notify us via telephone at 205-414-2900 and return this e-mail by forwarding it to postmaster@nelbro.com or via US Mail to Nelson Brothers, Inc., Attn: IS Department, 820 Shades Creek Parkway, Suite 2000, Birmingham, AL 35209.2 From: Doug Drake [ddrake@maconelectric.com] Sent: Friday, November 08, 2013 1:54 PM To: Carbon Pollution Input Subject: Carbon Pollution Standards

To whom it may concern,

A ffordable electricity is absolutely essential to the people and businesses that buy electricity from my cooperative. Adopting a regulatory strategy that will deliberately eliminate one of the most affordable and reliable sources of electricity for my members can have only one outcome- their electric rates will go up and cause small businesses to fail. Please do not finalize a rule that removes affordable clean coal from our sources of electricity.

If coal is eliminated, tens of thousands of rural Missouri families as well as those in other states will be forced to decide if they are going to buy food, medicine, or electricity but they will NOT be able to afford all three. Electric cooperatives in Missouri serve some of the most economically disadvantaged Americans. Our latest survey shows that half of our members are seniors 55 years old or older, with 35 percent over the age of 65. One third of these senior members earn less than $25,000 a year, and one third are retired and living on a fixed income. On the other end of the spectrum, younger people just getting started with families and careers also earn less than $25,000 a year.

Please consider how the daily lives of these people will change if their electricity costs escalate due to unreasonable EPA regulations. But, this does not have to happen. EPA can and should develop regulations which ensure that ALL consumers have ALL potential sources of affordable electricity available, particularly the affordable electricity generated from clean coal plants that also provide hundreds of jobs for local workers.

I respectfully ask the EPA to recognize and respect the fact that the electric cooperatives in Missouri followed every law and every regulation when we constructed our power plants and we cannot afford to lose any option for affordable electricity. Please develop a final rule that will allow us to continue to provide safe, affordable, reliable non-profit electric power to our members from all sources, including coal.

Sincerely, Doug Drake

Doug Drake, General Manager

31571 Business Route 36, P.O. Box 157 Macon, MO 63552-0157 Telephone: 660-385-3157

Fax: 660-385-3334
www.maconelectric.com

OUR MISSION: “To provide excellent service to our members in the most efficient manner possible.”3 From: Gibler, Nancy [NGibler@cepc.net] Sent: Friday, November 08, 2013 9:15 AM To: Carbon Pollution Input Subject: Comment: Carbon Pollution Input



### Good morning.

M y name is Nancy Gibler and I am the Business Development Director for Central Electric Power Cooperative

- a not-for-profit

rural electric generation and transmission utility headquartered in Jefferson City Mo. Central is owned by 8 not-for-profit electric distribution cooperatives that serve 177,000 member-owners in central
Missouri.

Electric cooperatives were created for the express purpose of providing AFFORDABLE NON-PROFIT electric

g eneration and transmission facilities to their member-owners. Over 80% percent of the not-for-profit, affordable electricity that Central provides comes from coal fired plants and another 10% comes from natural gas. The balance of the energy we provide comes from hydro and wind resources.

Affordable electricity is absolutely essential to the people that buy their electricity from my cooperative.
A dopting a regulatory strategy that will deliberately eliminate one of the most affordable sources of electricity for my members can have only one outcome - their electric rates will go up. Please do not finalize a rule that removes affordable clean coal from our sources of electricity.

If coal is eliminated, tens of thousands of rural Missouri families as well as those in other states will be forced to decide if they are going to buy food, medicine, or electricity but they will NOT be able to afford all three. Just imagine the harm to children and the elderly under a regulation that removes their largest source of affordable energy that they depend upon and forces them to choose whether to buy their medicine, food or pay their electric bill. Please consider how the daily lives of these people will change if their electricity costs escalate due to unreasonable EPA regulations.

But, this does not have to happen. EPA can and should develop regulations which ensure that ALL consumers have ALL potential sources of affordable electricity available, particularly the affordable electricity generated from clean coal plants that also provide hundreds of jobs for local workers.

I respectfully ask the EPA to recognize and respect the fact that the electric cooperatives in Missouri followed

e very law and every regulation when we constructed our power plants and we cannot afford to lose any option for affordable electricity. Please develop a final rule that will allow us to continue to provide safe, affordable, reliable non-profit electric power to our members from all sources, including coal.

Sincerely,

Nancy Gibler

Nancy A. Gibler Director of Business Development Central Electric Power Cooperative 2106 Jefferson St, PO Box 269 Jefferson City, MO 65102-0269 (573) 634-2454 (573) 761-2882 (DID and FAX)45 From: Scott For Colorado [scottforcolorado@gmail.com] Sent: Wednesday, October 30, 2013 12:45 PM To: Carbon Pollution Input Subject: Regulations



### C oal is Western Colorado's most abundant and least expensive fuel. EPA's proposed regulations will affect the wallets of all Coloradoans, and especially those families who earn less than $30,000 a year and already spend 20 percent of their finances on energy.

Coal supports thousands of jobs right here in Western Colorado. Coal also supports U.S. energy independence. The U.S. has one quarter of the world's coal reserves, and half our states - including Colorado - have coal resources, which can help meet domestic demand for approximately 250 years.

Please tread very lightly on any changes that may effect citizens of this country. The economic recovery has been slow and additional overreaching regulations will cause further issues for all American's.

Representative Ray Scott HD55
970-765-8683 www.rayscottforcolorado.com6 From: Tom Klein [tklein@norco-inc.com] Sent: Monday, October 28, 2013 12:36 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

I understand that the EPA is planning to issue carbon dioxide regulations that will severely impact existing coal-fueled

p ower plants. I work for a key supplier to the coal mining industry and see these actions a direct threat to my employment and to those who work with me. These actions will raise electricity bills, hurt small business and erode our country’s competitive advantage driven by low energy costs. I believe this would be devastating to an economy that still struggles to get it’s head above water. Please take this into consideration and avoid triggering another economic
disaster. Thanks you for your consideration.

Tom Klein Industrial Store Manager Gillette, Wy
Office 307-685-5046
Cell 307-680-9889 tklein@norco-inc.com

Note: This message is confidential, intended only for the named recipient(s) and may contain information that is privileged or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive this message in error, or are not the named recipient(s), please notify the sender at either the e-mail address or telephone number listed above and destroy this document. Thank you.7 From: Strine, Lora Sent: Thursday, December 19, 2013 1:33 PM To: Holly Rachel Smith Cc: Carbon Pollution Input; Goffman, Joseph; McCabe, Janet; Charles Gray Subject: RE: NARUC letter to Administrator McCarthy regarding regulating carbon from existing power plants

Thank you I will make sure it gets to the right people.

From: Holly Rachel Smith [ mailto:hsmith@naruc.org ]
Sent: Thursday, December 19, 2013 12:17 PM
To: Strine, Lora Cc: Carbon Pollution Input; Goffman, Joseph; McCabe, Janet; Charles Gray Subject: NARUC letter to Administrator McCarthy regarding regulating carbon from existing power plants

D ear Lora: attached please find a letter from NARUC Executive Director Charles Gray to EPA Administrator McCarthy.
Attached to the letter is NARUC’s Resolution on Increased Flexibility with Regard to the EPA’s Regulation of Greenhouse Gas Emissions from Existing Power Plants

.

Thank you.



## HRS
Holly Rachel Smith, Esq.
A ssistant General Counsel National Association of Regulatory Utility Commissioners 1101 Vermont Ave, NW Suite 200 Washington, DC 20005 (202) 898-1350 hsmith@naruc.org

http://www.hilton.com/en/groups/personalized/media/images/user/BWICCHH-RE3-20121106-image1.jpg

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*********************** ATTACHMENT NOT DELIVERED ***********************9 From: drupal_admin@epa.gov on behalf of Jason Bohrer [jasonbohrer@lignite.com] Sent: Tuesday, December 03, 2013 5:54 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Tue, 12/03/2013 - 17:54
S ubmitted values are:

Name: Jason Bohrer
Email: jasonbohrer@lignite.com
Comments: December 2, 2013
Laura Farris EPA Region 8 Climate Change Coordinator US EPA, Region 8 1595 Wynkoop Street Denver, CO 80202-1129 Subject: Comments On Developing Guidelines Under Section 111(d) Of The Clean Air Act For CO2 Emissions From Existing Power Plants Dear Ms. Farris: As you know, last June, the President directed the U.S. Environmen tal Protection Agency (EPA) to develop rules for regulating CO2 emissions from existing fossil-fueled power plants. EPA is directed to propose rules by June 1 of 2014, and to issue final rules one year later.
Each State must then submit a State Implementation Plan to the EPA by June 30 of 2016. The EPA has subsequently engaged in listening sessions to receive input from stakeholders on the design and development of the proposed regulations. Sec. 111(d) of the Clean Air Act (CAA) restricts the EPA to est ablishing “procedures” for the States to submit their plans for the establishment and implementation of performance standards for the emission of CO2 from existing fossil-fueled power plants. In turn, States have the responsibility to develop plans that fits their individual state needs. With that background, the Lignite Energy Council (LEC) submits the following comments forconsideration by the EPA when drafting its procedure and guidelines for existing fossilfueled power plants. 1. Each State must be allowed to have sufficient latitude for determining the stringency of their individual plans, including the ability to promulgate “less stringent emission standards or longer compliance schedules” to particular facilities if the adoption of the guidelines would be unreasonably costly, physically impossible, or have other factors that make a less stringent standard more reasonable. 40 CFR 60.24(f)(1)-(3). This includes an appropriate timeline for compliance based upon, among other factors, the remaining useful life of an individual facility. 2. The guidelines must be based only upon technologies that have been adequately demonstrated and are commercially available to reduce/limit CO2 emissions from a facility. As no carbon capture and storage systems are commercially available or economically feasible, the guidelines should be based upon what efficiency improvements can be reasonably and economically achieved at an individual plant. The guidelines should not specify percent reductions and/or specific CO2 emission levels, as these parameters are properly determined by the State on a case-by-case basis for each source. Additionally, the guidelines must not rely on fuel switching, co-firing, or other extreme options that would have substantial economic implications. 3. States must be given the autonomy to consider all relevant plant specific factors including but not limited to the remaining useful life of the facility, the fuel type, energy requirements, costs, non-air quality related health and environmental impacts, size of the unit, combustion technology, among other things, when determining the potential reductions for a given unit.10 4. States must be afforded the appropriate flexibility to develop equivalent
emission reductions to what could be achieved at a n individual source by other means that may be outside the individual source, should the State choose to do so. Should a State choose to allow compliance on an “equivalent basis”, States should be able to use a regional approach, in which energy production may occur in a State other than where it is consumed, to achieve compliance with their SIPs. 5. EPA guidelines should clearly state that efficiency improvements accomplished at a source in accordance with a State approved plan are not Major
Modificati ons, and thus not subject to New Source Review, regardless of an increase in annual
emissions or an extension of a unit’s life. The LEC is a regional, non-profit organization whose primary mission is to promote the continued development and use of lignite coal as an energy resource. The LEC’s membership includes: (1) producers of lignite coal; (2) users of lignite who operate lignite-fired electric generating plants and the nation’s only commercial scale “synfuels” plant that converts lignite into pipeline-quality natural gas; and (3) suppliers of goods and services to the lignite coal industry. The North Dakota lignite industry creates thousands of jobs, currently employing more than 4,300 people directly and another 24,000 indirectly. We create an annual economic impact of $3 billion in North Dakota, and generate nearly $100 million in state taxes each year. Should you have any questions concerning the above comments, please contact me at 701-258-
7117 or at jasonbohrer@lignite.com

. Sincerely,

Jason Bohrer President and CEO, Lignite Energy Council
1016 E. Owens Ave. Bismarck, ND 58502

Web Area: Carbon Pollution Standards11 From: drupal_admin@epa.gov on behalf of Heather Navarro [hnavarro@moenviron.org] Sent: Saturday, November 23, 2013 9:32 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Sat, 11/23/2013 - 09:31
S ubmitted values are:

Name: Heather Navarro Email: hnavarro@moenviron.org
Comments: I am Heather Navarro, the Executive Director of the Missouri Coalition for the Environment, a 44 year old environmental advocacy organization working throughout Missouri to protect and
restore our natural environment.

I’m also the mother of two children living in the City of St. Louis. And It is in their best interest, and the in the interest of their children and the generations of children to comethat I am here today, urging you to regulate greenhouse gas emissions from existing coalfired power plants.

Just last week I heard a Missouri state legislator say that the reason this state is so heavily invested in coal is because it’s the cheapest thing we’ve got. You’re going to hear a lot about cost from representatives of the coal industry but I would urge you to think about the cost of not regulating these plants – the costs to our children and our grandchildren.

In Missouri, we are already paying higher prices for coal, but we’re paying them with our children’s health, in medical care costs, and by sacrificing our crops, our food supply and our property.
37.75

A. Coal is expensive. We pay for it in our quality of living and in our
medical costs.

For the 134,000 children living with asthma, coal is costing them their childhoods, their ability to play after school sports, to enjoy recess, and to develop strong, healthy bodies.

Five counties in Missouri, all in the St. Louis region, fail to meet ozone standards and federal standards for small particulate pollution. The lead producer of small particulate matter pollution is coal and Missouri is leading the Midwest in global warming emissions. The American Lung Association ranks St. Louis among the 20 most ozone-polluted cities and asthma rates in children in St. Louis are staggering, especially among African-American children. Breathing in emissions from coal equals missed days at school and at work, which cost our entire community.

For the communities living near these plants, coal is costing them in the threat to their drinking water and in the degradation of rivers and streams.

Heat waves

Heat waves from increased greenhouse gases send the elderly and those already living with asthma and other respiratory illnesses to emergency rooms. Heat waves already kill more people in the U.S. each year than hurricanes, tornadoes, floods, and lighting combined (CDC).12 Increased heat brings draught and flood risks, endangering Missouri’s thriving agricultural economy that includes over 100,000 farms and comprises 66% of Missouri’s total land area (USDA 2009). Higher temperatures mean heat stress for crops and livestock and an expansion of the geographic and seasonal range for crop pests. That translates to lost crops and even a loss in the types of crops we can grow here in Missouri. More pesticides and herbicides will be needed to address these issues in the meantime and that means more pollution running off into our rivers and streams, endangering aquatic life and destroying the rivers where we fish
and float.

Flooding

We can also expect heavy downpours, which are already twice as frequent as they were 100 years ago. In 2008, all but 5 Missouri counties were the subject of storm or flood related disasters that led to $180 million in federal disaster assistance.

In 2011, 180 people died in Missouri and another 1,897 more were injured in extreme weather events. The total cost to property and crop damage was around $3.26 billion. In the Meramec watershed alone, 40,000 people were displaced by flooding.

Heavy rains have led to raw sewage overflows in St. Louis right into our rivers, threatening drinking water and health.

While we can’t connect any one death to climate change, we know that these events have been
on the rise and will continue to increase as the climate warms.

Sure, coal is cheap if we don’t look at the other side of the equation, which is all of the costs to our health and our planet that we will be paying for generations to come as greenhouse gases jeopardize our entire planet.

The Missouri Coalition for the Environment supports an energy picture that puts public health above corporate profits. The people of Missouri deserve better. We all deserve better. If it’s too expensive for coal to do business without altering the climate, poisoning our air and our water, then why in the world would we ask our children to bear those costs?

I appla ud the work the EPA is doing in drafting these regulations and implore you to act with a sense of urgency and to never lose sight that these regulations are part of a larger energy picture that this country needs you to embrace, one that prioritizes long-term human and
environmental health. The voters in the State of Missouri passed a renewable energy standard with 66% of the vote in 2008. This was a clear signal that Missourians are concerned about climate change and we want action now. We have a moral obligation to protect our children from the effects of climate change and we need the EPA to act. We need you to keep our eyes on the future and to remember that our goal isn’t finding the cheapest energy source available, regardless of the costs to human health, but on growing a healthy next generation. That’s what we all want and it won’t happen without clean energy and without your work to curb greenhouse gases.

Thank you.

Web Area: Carbon Pollution Standards13 From: drupal_admin@epa.gov on behalf of Jeff Mays [jmays@illinoisbusinessroundtable.com] Sent: Monday, November 11, 2013 2:00 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Mon, 11/11/2013 - 13:59
S ubmitted values are:

Name: Jeff Mays Email: jmays@illinoisbusinessroundtable.com
Comments: On behalf of the members of the Illinois Business Roundtable, I want to thank you for seeking public comment to guide your deliberations for cost-effective guidelines to reduce carbon pollution from existing power plants.

Too often, more regulatory guidelines mean higher costs on both the utility generator and the consumer to make the current non-carbon based higher cost alternative energy sources “more competitive”. As consumers of energy, both homeowners and industry have borne these increased government-directed costs, the “benefits” of which to too many are obscure.

We would like to suggest an alternative, based on the experience that we’ve had in Illinois.
Give it a break. Let the market take its turn.

First, the energy grid is source neutral. When consumers flip on their light switches, consumers want reliable and affordable energy and they get it currently through a mix of
sources. This is true whether the consumer is a manufacturer or a homeowner.

Second, those states like Illinois that have thrown open their markets to competition have seen a surge in supply and reduction in consumer costs. Since 1997, Illinois has developed one of the nation’s most competitive wholesale and retail electricity and gas markets in the country. The results have included:

• Moving Illinois from prices consistently above the national average to a position among the ten least expensive in the U.S. (6th lowest in August, 8th lowest for 2013 so far.) A reasonable calculation of the savings of this change in position is $36 billion since 1999 •
All non- renewables are on a level playing field and renewables have substantial subsidies and preferences. Although about half of Illinois electricity comes from coal, the market share of nuclear, gas and renewables has grown over the past decade and half. • The proposed EPA rules will interfere with this open market environment and may raise prices by creating a regulatory disadvantage for coal.

A key problem with the proposal is that the calculation of the value of the benefits of the proposed rule needs careful scrutiny before any such rule is promulgated. The calculation is suspect and “cost effective” is in the eye of the beholder.

Maybe EPA should let the market take its course.

Web Area: Carbon Pollution Standards14 From: Lynne Breyer [breyer.7244@gmail.com] Sent: Saturday, November 09, 2013 10:22 PM To: Carbon Pollution Input Subject: Docket ID: EPA-HQ-OAR-2013-0495 & RE: EPA-R09-OAR-2013-0009

Air and Radiation Docket and Information Center, Environmental Protection Agency, Mail Code: 2822T, 1200 Pennsylvania Ave., NW, Washington, DC, 20460

Docket ID: EPA-HQ-OAR-2013-0495 & RE: EPA-R09-OAR-2013-0009

To Whom it May Concern at EPA,

We have lived in Arizona since 1983. Because we live in Navajo County part time, we are concerned about the EPA’s proposed rules regarding carbon regulations in areas surrounding the Navajo Generating Station in northern Arizona, and other coal fired power plants in Arizona.

Just a few years ago, the EPA forced SRP to spend millions of dollars to add scrubbers to their clean coal-fired plant. Consequently, residents cannot detect in any way any pollutants surrounding this plant. The forest service and others have tested for pollutants and the amount is so very small that they are virtually not existent. The Clean Air Act gives both EPA and states a role in reducing air pollution from power plants that are already in operation and that has been done at the Navajo Station. The law directs EPA to establish guidelines, which states use to design their own programs to reduce emissions.

We object to the Carbon regulation proposed for existing coal fired power plants that do not take into account the costs involved in different geographies. The real costs are loss of jobs, loss of much needed services to much of Arizona, loss of taxes to support other important services just to name a few.

AZ has no oil wells to pump CO2 into which makes it unfeasible in the state.

AZ has no natural gas supplies and new carbon regulations that force the replacement of coal with Natural Gas plants only work in states that have Natural Gas. AZ has no such option.

The States implementation plan is the best solution for long term transition to less carbon, and the 10 th Amendment

r equires the EPA to use the State Plan in these regulations.

We are opposed to the stacking of regulations on power plants that force them to close, switch to Natural Gas or join a Carbon CAP and TAX marketplace.

Because the EPA's proposed rules are unworkable on several levels at NGS, we urge the EPA to adopt the TWG BART Proposal as the final rule for NGS. We also urge the EPA to give exclusions to the rules that damage tribal and state economies. We have no Gas no Oil no choice in AZ.

Sincerely,



### Lynne & Richard Breyer Navajo County Residents15 From: Stephen Cain [Stephen.Cain@aecc.com] Sent: Friday, November 08, 2013 6:00 PM To: Carbon Pollution Input Cc: Sandra Byrd; Carmie Henry; Jonathan Oliver; Curtis Warner; Stephen Cain Subject: AECC Comments on Existing Source Performance Standards Under CAA Section 111(d)



### Below are Arkansas Electric Cooperative Corporation’s (AECC) comments regarding development of carbon

e mission standards for existing power plants. Specifically, AECC’s comments answer the questions posed in EPA’s document entitled, “Considerations in the Design of a Program to Reduce Carbon Pollution from Existing
Power Plants.”

EPA’s document contains discussion on four primary questions. AECC’s comments focus on the “Questions for further discussion” at the end of each primary question discussion.

AECC’s goal is to provide reliable and affordable electricity to our members in a responsible manner. As a notfor-profit cooperative, we are motivated by service to our members, not stockholders. We serve about 62% of the geographic area of Arkansas – including some of the lowest income households in the country – so any new EPA rule that threatens reliable and affordable energy is a tremendous concern to us.

As a general overall comment, AECC believes that carbon emission standards should be developed through legislation rather than regulation. The legislative approach would involve representatives for all citizens andentities that would be impacted by this action, and it would establish a much more suitable and legallydefensible standard.

Primary Question 1 : What is state and stakeholder experience with programs that reduce CO2 emissions in the electric power sector?

Question 1.1 : What actions are states, utilities, and power plants taking today that reduce CO2 emissions from the electric power system? How might these be relevant under Section 111(d)?

One action is installation of renewable energy. AECC is an Arkansas leader in renewable energy. Almost 10% of AECC’s energy comes from renewables. We own and operate three hydropower facilities and have power purchase agreements for both landfill gas and wind energy. And we recently signed an agreement for another 150 MW of wind energy that will begin at the end of 2014. We are also proactively looking into community solar projects for our members.

A second action is high power plant efficiency. AECC is also a leader in efficiency. We own and operate the Magnet Cove Generating Station – the most efficient natural gas-fired plant in Arkansas. Also, we own a portion of the newest, most efficient coal-fired plant in the country – one that uses ultra-supercritical technology – the John W. Turk Power Plant.

A third action is demand-side management. AECC and the 17 distribution cooperatives we serve promote several energy efficiency programs including the use of geothermal heat pump systems – the most energy efficient method to heat and cool homes. Also, AECC and its members have been involved in demand-side management and irrigation load-control programs for decades.16 

### All of the things mentioned above voluntarily reduce carbon emissions from the electric power sector. No federal or state mandate required AECC to implement these things; AECC is simply meeting the needs of its
members.

How the actions listed above are relevant under Section 111(d) depends on how the language in the Clean Air Act is interpreted. AECC believes that Section 111(d) limits EPA to only “within the fence” measures to define Best System of Emission Reductions (BSER).

Question 1.2 : What systems do states and power plants have in place to measure and verify CO2 emissions
and reductions?

AECC has measured and reported CO2 emissions from its power plants since the mid-1990s using continuous emissions monitoring systems. This is a mandatory requirement for sources subject to EPA’s Acid Rain Program monitoring standards. The quality assured emission data is submitted to EPA quarterly, and that data is publically available.

Future year emissions can be compared to present year emissions to verify emission reductions.

Question 1.3 : How do state programs and measures affect electricity generation and emissions at a regional level? How are interstate effects accounted for when measuring the progress of a state program? For example, are the multi-state effects of state renewable portfolio standards, end-use energy efficiency resource standards, emissions performance standards, and emissions budget trading programs currently accounted for by the state, and if so, how?

As a state develops its plan, it will be responsible for accounting for and verifying reductions that an entity makes at locations outside of the state’s jurisdiction. And the state must do so in a federally enforceable

manner.

Primary Question 2 : How should EPA set the performance standard for state plans?

Question 2.1 : Which approaches to reducing CO2 emissions from power plants should be included in the evaluation of the “best system of emission reduction” that is used to determine the performance level(s) that state plans must achieve? Should the reduction requirement be source- or system-based?

AECC believes that the reduction requirements should be source-based and not system-based. In fact, AECC believes that Section 111(d) allows EPA only the source-based option.

EPA has been tasked with regulating carbon emissions from existing electricity generating units, and the plan is to do so under Section 111(d) of the Clean Air Act. This section requires EPA to develop guidance for states to implement their carbon emission reduction plans. However, Section 111(d) defines BSER to include only those measures that have been “adequately demonstrated and achievable” by affected electricity generating units. In other words, from a federal perspective, Section 111(d) limits BSER to those performance improvements achievable using “within the fence” measures. In doing so, EPA must recognize that BSER
standards cannot:

• require technologies that are not commercially demon strated (such as carbon capture and storage – or CCS);

• require a fundamental change in the source (such as fuel switching);17



### • require a revised dispatch of the generating fleet; nor

• mandate energy efficiency or other programs that dep end on “outside the fence” actions.

Achievable standards should be developed for existing, modified and reconstructed units at the same time – and the standards should be the same. These units should be exempt from New Source Review if modifications are required to meet existing unit standards. Also, these units should never be subject to EPA’s proposed new source performance standards for electricity generating units as those are standards that existing, modified, and reconstructed units cannot achieve.

Question 2.2 : How does the amount of flexibility that states are given to include different types of programs in their state plans relate to the “best system of emission s reduction” that is used to set the performance bar for state plans? For example, if state standards to improve end-use energy efficienc y were included in state plans, should EPA consider potential improvements in end-use energy efficiency in setting the performance target for states?

Section 111(d) limits EPA to requiring carbon emission reductions “within the fence” of a facility. The example in Question 2.2 is end-use energy efficiency which is “outside the fence” of a facility; therefore, EPA cannot require that using Section 111(d).

Though AECC does not believe that “outside the fence” carbon emission reduction projects should be requirements, they should be a voluntary option for complying with the standards. This way, the standard can be met using the most cost-effective measures available.

Question 2.3 : What should be the form and specificity of the performance level(s) in EPA guidelines? (Ratebased or mass-based? Separate levels for each subcategory of sources, or one level for the covered sources in the state? A uniform national level, or different levels by state/region based on an established evaluation process?)

AECC believes that the specificity of the performance levels can be either rate-based or mass-based, but AECC reserves the right to re-evaluate this belief dependent on what EPA proposes.

AECC believes that there should be separate levels for each subcategory of sources. EPA has a history of setting different performance standards for different subcategories of a given source. That history should
continue with this standard.

AECC believes that levels should be state/region-based. A state or region is generally limited by its resources. An across-the-board standard may be a benefit for one state/region and a detriment to another. For instance, solar power is more viable in southern California and Arizona due to the high amount of daily sun received in that part of the country relative to a lower amount in a state like Arkansas. The same can be said about wind power in the western parts of Texas, Oklahoma, and Kansas relative to Arkansas.

Primary Question 3 : What requirements should state plans meet, and what flexibility should be provided to states in developing their plans?

Question 3.1: What level of flexibility should be provided to states in meeting the required level of performance for affected EGUs contained in the emission guidelines?18 

### After EPA has established the proper procedure under which a state is to submit a plan and has provided “an emission guideline that reflects the application of the best system of emission reduction (BSER)... that has been adequately demonstrated for designated facilities,” each state should have the authority to determine the level of BSER for each source in its state on a case-by-case basis taking the following into account: unit age, size, technology, fuel type, physical limitations, and other plant-specific characteristics. The standardswould be based on a determination of what reductions could be achieved with commercially available, costeffective technology. AECC believes that EPA’s performance guidelines should also allow the states to take into account any efficiency improvements and other carbon emission reduction activities already undertaken “within the fence” of a facility subject to the standards.

After the level of BSER is established, each state should have absolute flexibility to meet those emission reduction requirements by any means it chooses based on its own economics, situation, resources, and state legal authority. Each state should be allowed to consider any combination of technologies – either “inside” or
“outside” the fence – that meets that level of reductions in a cost-effective manner.

States should be responsible for setting timelines for achievement of their own prescribed emission reductions. Due to the varying nature of possible reduction methods, states should be allowed to develop different timelines for compliance as needed.

Accordingly, EPA’s only acceptance criterion of a state plan is whether the plan meets the minimum prescribed level of emissions required by the state’s determination of BSER – regardless of how a state
chooses to do so.

Question 3.2 : Can a state plan include requirements that apply to entities other than the affected EGUs? For example, must states placed all of the responsibility to meet the emission performance requirements on the owners or operators of affected EGUs, or do states have flexibility to take on some (or all) of the responsibility to achieve the required level of emission performance themselves or assign it to others (e.g., to require an increase in the use of renewable energy or require end-use energy efficiency improvements, which will result in emission reductions from affected EGUs)?

Electric utilities like AECC have made substantial carbon reductions in the last 6 years. In fact we are already close to many of the reduction targets that have been proposed in the past. Accordingly, we believe any future mandated reductions should include all sectors of the economy and reflect an equitable and proportionate
share of each sector’s contribution.

Question 3.3 : What components should a state plan have, and what should be the criteria for approvability?

The states should be required to consult with utilities, regional power pools, regional transmission organizations, and other affected parties to assure that electricity reliability is maintained. Documentation of such consultation should be included in each state’s plan.

Also, states should include an overall economic impact evaluation in its plan. The state should be able to demonstrate that the requirements in the plan are justified on cost-effectiveness.

Questions 3.4 : Can a state plan include programs that rely on a different mix of emission reduction methods than assumed in EPA’s analysis of the “best system of emission reduction” that is used to set the performance standard for state plans?19 

### Yes. Each state should have absolute flexibility to meet emission reduction requirements by any means it chooses based on its own economics, situation, resources, and state legal authority. Each state should be allowed to consider any combination of technologies – either “inside” or “outside” the fence – that meets that
level of reductions in a cost-effective manner.

Question 3.5 : What should be the process for demonstrating that a state plan will achieve a level of emission performance comparable to the level of performance in the EPA emission guidelines?

As a state develops its plan there must be a system of accounting for and verifying reductions that an entity makes. And the state must do so in a federally enforceable manner.

Question 3.6 : What enforceability, measurement, and verification issues might arise, depending on the types of state measures and programs that states include in their plans? For example, what issues are raised by actions that have indirect affects on EGU emissions, such as end-use energy efficiency resource standards, renewable portfolio standards, financial assistance programs to encourage end-use energy efficiency, building energy codes, etc.)?

EPA has only to approve each state’s plan. It should be the responsibility of each state to enforce its own plan.

Primary Question 4: What can EPA do to facilitate state plan development and implementation?

Question 4.1 : What types and amount of guidance and implementation support should be provided to
states?

AECC believes it is imperative that EPA allow the states ample time and flexibility to design programs that are Section 111(d) compliant but also ensure electric reliability and minimize costs to ratepayers. Generally, a state would have nine months after publication of a final EPA guidance document to submit a plan; however, we note per the Act that EPA can extend this deadline “whenever [it] determines necessary.”

Due to the wide range of options available to the states that need to be considered to determine the most cost-effective methods to meet their emission obligations, AECC does not believe nine months will provide sufficient time. Since AECC believes coordination with utilities, power pools and regional transmission operators is also needed to address reliability, this is further reason to afford states additional time to prepare their plans. A period of at least fifteen months seems more appropriate.

Question 4.2 : Are there benefits for coordination among neighboring states in the development and submittal of state plans? Should EPA facilitate the coordination of multi-state plan submittals?

We note that EPA believes some states may wish to develop coordinated approaches on a more regional basis. The additional six month period proposed above would allow more time for this coordination.

AECC believes that multistate plan submittals should be an option. If a region wishes to develop a carbon trading program, the program would be more robust with more units within it. Also, one state in a region may have a resource supply that could benefit the other states in that region.

Question 4.3 : Would certain types of measures that might be included in state plans increase the need for coordination among states?20 

### AECC believes that there should be no measures that specifically require that a state must coordinate with other states. A state should be able to make that decision on its own without being required to do so.

Question 4.4 : Are there model rules that EPA could develop that would assist states and what would those
rules cover?

AECC believes that it would be best if EPA generalized any requirements and allow a state or region to develop its own specificities.

This concludes AECC’s comments. AECC appreciates EPA’s willingness to consider an array of options to regulate EGUs under Section 111(d).

Sincerely,

Stephen Cain Manager – Environmental Compliance Arkansas Electric Cooperative Corporation

501.570.242021 From: John Bzdawka [johnb@ibew494.com] Sent: Thursday, November 07, 2013 11:34 PM To: Carbon Pollution Input Subject: EPA Listening Session on Existing Source Greenhouse Gas Controls

T o Whom it May Concern,

Good morning. I am John Bzdawka and I am here on behalf of the Wisconsin IBEW State Conference. We represent approximately 5,500 jobs in Wisconsin Electrical Building Trades. The future of our union's jobs and the welfare of our families and communities will be vitally impacted by EPA's decisions on the guidelines for existing source greenhouse gas controls for power plants scheduled to be proposed in June 2014.

• Many unions are experiencing unprecedented job losses due to the shutdowns of coal plants that are occurring in response to EPA's mercury rule and lower natural gas prices. The U.S. Department of Energy projects that more than 50,000 megawatts of coal capacity will be shut down over the next few years. Most of these closures will occur at older and smaller coal plants that are not economically feasible to be retrofitted with scrubbers and other controls needed to meet the new mercury standards.

• These job losses will accelerate in 2015 and 2016 when the mercury rule takes effect. These plants have already spent millions of dollars to comply with MATS and are the same plants being targeted by the proposed existing source rule. The additional expenditures required to comply with the existing source rule will force these plants
to close.

• We, along with other unions involved in the maintenance, fuel supply, and operation of coal plants, will lose tens of thousands of high-paying, high-skilled jobs.

• In addition to the loss of jobs, we are concerned that with the loss of generation will affect the stability and reliability of the electric grid.

• The loss of generation has the potential to increase electric rates which will be incurred by all consumers.

• Our primary concern about EPA's existing source "guidelines" for CO2 reductions is finding ways to avoid the loss of jobs at plants that have just invested billions in retrofit controls.

• We know that states are supposed to have a lot of discretion in this program, and we do not want to see arbitrary CO2 emission rate targets imposed on states that would force a lot of additional plant closures and job losses. Some environmental groups are urging you to set such targets, which we strongly oppose.

• We believe that the Clean Air Act calls for plant-by-plant assessments, by the states, of what amounts of CO2 can reasonably be reduced at existing plants, such as by efficiency improvements.

• We also must note that CO2 emissions from coal plants are down 23% from 2005 levels, and will be further reduced as more plants are shut down. U.S. coal generation is only 4% of global energy-related CO2 emissions, so even major reductions would not have any meaningful future impact on global climate. India, China and other developing countries are the principal sources of future greenhouse gas emissions growth, and these countries have not agreed to any legally binding limits on their emissions growth. U.S. emissions are declining and are on track to meet the President's target of a 17% reduction from 2005 levels by 2020.

• We are not putting our heads in the sand here. We will support reasonable measures to increase energy efficiency at coal generation plants, reducing their CO2 emissions. However, we cannot support arbitrary targets that would force a new wave of plant closures and job losses.

We will appreciate the agency's consideration of our views.

John Bzdawka22 Business Manager
IBEW Local #494
3303 South 103rd Street Milwaukee, WI 53227-4108 (414) 327-5202 Ext. 227 E-mail: johnb@ibew494.com23 From: Tom Mullins [tmullins@tylertexas.com] Sent: Thursday, November 07, 2013 6:39 PM To: Carbon Pollution Input Cc: Hill, Charles; shawn.parker@energyfutureholdings.com Subject: EPA proposed regulations

The Tyler (Texas) Area Chamber of Commerce is concerned about the proposed EPA regulations restricting carbon

p ollution. Our regional economy is closely tied to the production of energy including coal fired power plants. If these plants have to close as a result of these proposed regulations we stand to lose thousands of good paying jobs, have less reliable energy options and increased energy costs as a result of diminished supplies.

We request the EPA work closely with the State of Texas to create reasonable rules that support a diverse mix of reliable, affordable energy for our expanding Texas population and economy.

Thank you

Tom Mullins President/CEO Tyler Area Chamber of Commerce and Tyler Economic Development Council (903-593-2004x246) 315 N. Broadway Tyler Texas 75702

Protected by HP ProtectTools24 From: drupal_admin@epa.gov on behalf of Bruce Ramme, Vice President, Environmental, We Energies [bruce.ramme@we-energies.com] Sent: Thursday, November 07, 2013 5:51 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Thu, 11/07/2013 - 17:50

S ubmitted values are:

Name: Bruce Ramme, Vice President, Environmental, We Energies Email: bruce.ramme@we-energies.com
Comments: Statement of We Energies to EPA Listening Sessions on Regulating Carbon Dioxide Emissions from Existing Power plants Under Section 111(d) of the Clean Air Act

November 7, 2013

Wisconsin Electric Power Company, doing business as We Energies, submits these comments in response to the U.S. Environmental Protection Agency’s (EPA’s) request for input on regulating carbon dioxide (CO2) emissions from existing power plants under Section 111(d) of the Clean Air Act.

We Energies is an investor-owned electric and gas utility that serves more than 1.1 million electric customers in Wisconsin and Michigan’s Upper Peninsula and more than 1 million natural gas customers in Wisconsin. We Energies owns and operates five coal (two are “must run” from a reliability standpoint) and four natural gas power plants that may be covered by regulating CO2 emissions from existing power plants. Four coal power plants and four natural gas power plants are located in Wisconsin and one coal power plant is located in Michigan. Our system of electricity generation units and associated facilities and operations will be significantly impacted by regulation of CO2 emissions from existing power plants.

No law requires EPA to propose and finalize section 111(d) emission guidelines for CO2 emissions from existing power plants by any particular date. EPA should refrain from doing so because of potential negative impacts to the economy and electric reliability.

Congress gave states, not EPA, the primary responsibility and authority to set and implement performance standards for existing power plants. Section 111(d) gives EPA no direct regulatory authority over existing power plants. States have broad discretion under section 111(d) to develop, implement, and enforce such plans.

Section 111(d) directs EPA to establish a procedure for states to submit plans establishing performance standards for existing power plants. EPA’s guidelines are not legally binding or directly enforceable on sources. These guidelines set out considerations for states to address in adopting their own standards for existing power plants.

States can depart from EPA guidelines, and EPA shall approve state plans that are “satisfactory” under section 111(d). States have significant discretion in designing their own plans and determining how individual power plants may demonstrate compliance.

Section 111(d) focuses on the performance of individual sources. Any EPA guidelines and any state performance standards must be achievable using commercially available on-site technology that does not redefine the source.25 The Clean Air Act does not allow EPA to prescribe a performance standard that applies to the industry as an entire sys tem. Existing source performance standards apply to sources and must be achievable by each source.

EPA cannot rely on possible national or regional benefits to justify a standard that is unachievable, based on technology that is not commercially available, or is otherwise unreasonable for an individual source. Once performance standards have been established based on what is achievable on-site at each individual source, based on commercially available technology without redefining the source, more flexible mechanisms to comply with the performance standards can be considered.

Please contact Kris McKinney at 414-221-2157 or kris.mckinney@we-energies.com with any questions about these comments.

Web Area: Carbon Pollution Standards26 From: Van Robinson [VRobinson@cecmo.com] Sent: Thursday, November 07, 2013 4:54 PM To: Carbon Pollution Input Subject: Opposed to EPA Carbon Regulations

My name is Van Robinson and I am the Chief Executive Officer at Citizens Electric Corporation (CEC). CEC is a

t ransmission and distribution utility in southeast Missouri that operates as a not-for-profit cooperative. We’re proud to serve approximately 27,000 homes, farms, and businesses, and we’re focused on providing electric service in a reliable and affordable manner. Unfortunately, the increasing burdens of federal regulations make that goal more challenging every day.

Approximately 80% of CEC’s costs are for power supply. Like many utilities in the Midwest, more than half of that power supply is generated from coal. We have worked with our power supplier to add more diversity to our portfolio in the form of natural gas, wind, solar, landfill gas, and methane digesters. However, that diversity has done little to enhance our reliability or affordability. Our experience has shown that wind generation will only be available about one-third of the time, and an upcoming investment in solar will cost us two to four times our investments in fossil-fueled generation. The fact remains that coal is still a crucial part of our generation mix because it is a dependable and cost-effective

resource.

I’m very disappointed to learn that President Obama has directed the EPA to continue its attack on coal-fired generation. Electric utilities have spent billions of dollars to meet previous EPA regulations regarding sulfur dioxide, nitrogen oxide, and mercury. Now, the EPA is crippling us with carbon regulations. These regulations will only add to the uncertainty and difficulty of planning for our future power supply needs. New coal-fired plants won’t be built, older plants will be retired, and we’ll face a tremendous dilemma on how to fill that hole in our portfolio. Some will suggest that we simply make up the deficit with more renewables. Germany has gone down a similar path and nearly 25% of their generation capacity is now wind and solar. Their electric rates have nearly doubled and blackouts are feared because of these costly, intermittent resources. I’m confident that CEC’s members won’t accept this type of outcome. In a recent survey, 65% of our members said they preferred a balanced approach that included coal.

Instead of the “all-of-the above” strategy that President Obama declared during his campaign, it appears that EPA regulations are promoting an “all-but-one” strategy. CEC wants a balanced, common-sense approach with respect to federal regulations. Please don’t take coal off the table. Let’s keep our power supply reliable and affordable.



## Van Robinson

Chief Executive Officer
Ci tizens Electric Corporation 1500 Rand Ave., PO Box 368 Perryville, MO 63775 vrobinson@cecmo.com
573-768-3900 office
573-576-0997 cell
573-768-3700 fax

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Internet. The information in this e-mail is confidential and may be legally privileged. It is intended solely for the addressee. Access to this e-mail by anyone else is

u nauthorized. If you are not the intended recipient, any disclosure,copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. If you believe that you have received this e-mail in error, please contact the sender by return e-mail and permanently delete the original and any copy of this e-mail message or attachments and any printed originals and copies. E-mail transmission cannot be guaranteed to be secure or error-free as27

information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, or for any damage caused by any virus which arises as a result of e-mail transmission.28 From: drupal_admin@epa.gov on behalf of Chip Casteel [ccasteel@stlregionalchamber.com] Sent: Thursday, November 07, 2013 4:37 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Thu, 11/07/2013 - 16:37
S ubmitted values are:

Name: Chip Casteel
Email: ccasteel@stlregionalchamber.com
Comments: The St. Louis Regional Chamber of Commerce is a broad community of leaders united for economic prosperity throughout our bi-state metropolitan region. We believe that access to safe, reliable, and affordable energy is critical for long-term business growth. We support policies that increase our energy independence and security as well as reasonable regulations that properly balance economic growth and environmental protection. We also support policies that foster the region’s growing “green economy” and encourage broader adoption of sustainable business practices.

We urge caution in implementing the new greenhouse gas rules regulations on power plants, because such regulations could unduly raise energy costs for businesses and jeopardize the creation of jobs in the St. Louis region. We request that the U.S. EPA consider a balanced and reasonable policy approach that would be equitable to all regions and industries, encourage innovation and economic growth, and achieve sustainability.

Because coal is our primary energy source, the impacts of the greenhouse gas regulations would spread throughout the St. Louis regional economy and could adversely impact our regional competitiveness through higher energy costs. We urge the U.S.EPA to undertake a thorough analysis of the costs and benefits of the proposed regulations. This analysis should employ a “whole-economy model” that takes into ac count the cascading effects of comprehensive regulations across interconnected industries and markets. The study should also take into account potential employment losses and other economic effects.

The St. Louis Regional Chamber believes the U.S. EPA must take the necessary time to work with key stakeholders to fully address the many concerns that have been expressed regarding the design and impact of these regulations. Simply put, these regulations are so important that the Agency simply must get them right the first time around. We and our members stand ready to participate in this discussion as we all work to appropriately balance the twin objectives of economic prosperity and environmental quality.

Web Area: Carbon Pollution Standards29 From: Tony J. DeMarco [ademarco@cap-az.com] Sent: Thursday, November 07, 2013 12:34 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website



### Ronald Lunt Power Programs Manager Central Arizona Project

Testimony Public Listening Session November 5, 2013 U.S. EPA Region 9 Offices, San Francisco

On behalf of the Central Arizona Water Conservation District (CAWCD), I wish to provide the following

t estimony regarding development of approaches to carbon pollution under the Clean Air Act, particularly for power plants such as Navajo Generating Station that do not fall under state jurisdiction.

CAWCD, commonly referred to as the Central Arizona Project (CAP), was established in 1971 as the state

a gency that manages and operates the CAP system, collects revenues from ratepayers and, since substantial project completion in 1993, repays the federal government for the reimbursable costs of construction. Our goal at CAP is to provide an affordable, reliable and sustainable supply of Colorado River water to cities, industries, farms, and Tribal communities in a service area that includes more than 80 percent of Arizona's population. We have successfully achieved this goal for the past 25 years.

Background

Central Arizona Project, constructed by the Bureau of Reclamation (BOR) for the State of Arizona, is a multip urpose water resource development and management project that delivers Colorado River water into central and southern Arizona. The largest supplier of renewable water in Arizona, CAP delivers an average of over 1.5 million acre-feet of Arizona’s 2.8 million acre-foot Colorado River entitlement each year to municipal and industrial users, agricultural irrigation districts, and Indian communities. CAP meets approximately 50 percent of municipal demand within its service area, including 45 percent of the City of Phoenix's total water demand and about 80 percent of the City of Tucson’s water demand. In addition, 47 percent of the long-term CAP entitlement is dedicated to Indian Tribal use, while 41 percent of current CAP deliveries support non-Indian agricultural production.

These renewable water supplies are critical to Arizona's economy and to the economies of Native American

c ommunities throughout the state. Nearly 90% of economic activity in the State of Arizona occurs within CAP's service area. CAP also helps the State of Arizona meet its water management and regulatory objectives of reducing groundwater use and ensuring availability of groundwater as a supplemental water supply during future droughts. Achieving and maintaining these water management objectives is critical to the long-term sustainability of a state as arid as Arizona.30 

### CAP infrastructure includes a 336-mile-long delivery system that moves water 3,000 feet uphill from the Colorado River. The system entails 14 pumping plants and one combination pumping/generating facility; 10 siphons that carry water under riverbeds and washes; three tunnels; more than 45 turnouts that connect the CAP aqueduct with customers' water delivery systems; a large storage reservoir; and a state-of-the-art control center. A large and reliable supply of baseload power is essential to operating CAP infrastructure and delivering water to its customers, including potable water treatment plants that must supply drinking water to millions of Arizona residents every day.

CAP construction necessitated the development of new power generation facilities to provide a dedicated energy source for the operation of the system. The Colorado River Basin Project Act allowed the federal government, specifically the Bureau of Reclamation, to participate in the non- federal Navajo Generating Station (NGS), a 2250-Megawatt facility near Page, Arizona, to provide power for pumping CAP water as an alternative to building additional dams along the Colorado River. Construction of NGS was the result of an environmental compromise brokered by then-Secretary of the Interior Stewart Udall. NGS also was intended to help maintain and improve the economies of the Navajo Nation and the Hopi Tribe by providing revenues for the Tribal governments and high-paying jobs for Tribal members.

NGS was constructed by the Salt River Project Agricultural Improvement and Power District of Arizona, now part of the Salt River Project (SRP). In addition to BOR and SRP, other current participants in NGS are Arizona Public Service, NV Energy, Tucson Electric Power Co., and Los Angeles Department of Water and Power. In addition to providing CAP pumping energy, the other participants utilize NGS to provide electricity to retail customers in Arizona, Nevada and California. BOR's share of NGS's output is 24.3 percent, or 546,750

kilowatts for the benefit of CAP.

It is important to note that NGS is one of two coal-fired power plants in the United States located on tribal lands. More specifically, the plant is located on the Navajo Nation, and the Kayenta Mine, which supplies coal to the facility, is located on Navajo Nation and Hopi Tribal lands. This plant is not subject to state jurisdiction, but rather is regulated directly by the Environmental Protection Agency (EPA).

Navajo Generating Station – Decisions that Impact Water and Power Costs

Regulatory Issues : NGS is near numerous national parks, monuments, and wilderness areas, and controlling plant emissions has been and still remains a priority for CAP and the NGS participants. Pursuing this proactive commitment, in the1990's the NGS participants invested more than $400 million in scrubbers to reduce sulfur dioxide emissions. From 2009 to 2011 the plant owners voluntarily installed additional environmental controls to reduce smog-forming nitrogen oxide (NOx). The low-NOx burners with separated over-fire air (LNB/SOFA) cost approximately $46 million for installation on all three units at NGS.

Currently, the EPA is in the process of setting new rules to control NOx emissions at coal-fired power plants, including NGS, under the Regional Haze Rule of the Clean Air Act. How this regulatory activity has been addressed at NGS by the plant owners, CAP and other stakeholders bears directly on CAP's recommendation today regarding greenhouse gas-emissions rulemaking at NGS. The following brief history will illuminate the concepts proposed, as well as address steps already taken to offset carbon generation at the plant.31 

### On February 5, 2013, EPA issued a proposed Federal Implementation Plan (FIP) for establishing Best Available Retrofit Technology (BART) to limit NOx emissions at NGS. The proposed FIP contains a BART Determination based on a calculated NOx cap over the useful life of the plant (to 2044) and a "Better than BART" Alternative 1 that takes into account the voluntary, early installation of LNB/SOFA by the owners and the applicability of the Tribal Authority Rule of the Clean Air Act to NGS. Both the proposed BART Determination and "Better than BART" Alternative 1 require a NOx emissions limit within five and 10 years respectively, that can only be met at by Selective Control Technology (SCR) at a cost of approximately $544 million to as much as $1.1 billion, should SCR also require installation of baghouses.

The extremely high costs of the EPA's proposed BART SCR/baghouse options within a five- to 10-year timeframe could jeopardize continued operation of the NGS facility, with severe economic impacts to CAP users and to the Navajo Nation and the Hopi Tribe. Because a number of critical uncertainties face the Navajo plant, including the renewal of land and coal-supply leases and the likely departure of LADWP and NV Energy from the plant by 2019, and the unusual requirement for the plant to engage in an extensive National Environmental Protection Act (NEPA) process, a near- term requirement to install SCR at NGS raises the risk of plant closure. Rather than risk a huge and potentially unrecoverable investment in retrofitting the plant with SCR technology prior to the resolution of these uncertainties, NGS participants have indicated they may pursue closing the plant and meeting their energy needs through other means.

As a consumer of NGS power rather than a retail marketer of power, CAP would be catastrophically impacted by closure of NGS, as would a number of Arizona Indian tribes:

• 

### Should the NGS facility cease operations, CAP would have to acquire a substitute source of pumping power at market rates. Using several forecasts, CAWCD estimates that CAP pumping energy costs could increase by 50 to 300 percent (rising from $65 per acre foot to $95 - $180 per acre foot) by 2017.

• The NGS, along with the Kayenta mine that provides coal to the plant, is a major contributor to the economies of the Navajo Nation, the Hopi Tribe, the City of Page, Coconino County, and the state of Arizona. NGS employs more than 520 people, more than 85% of whom are Navajo. The Kayenta Mine, which supplies coal to NGS, has more than 400 employees, most of whom are Native American. This accounts for about 1,000 direct jobs between the two facilities.

• 

### Indian Tribes would lose access to millions of dollars from the sale of surplus NGS power that otherwise could be available to assist with implementing their water rights settlements.

• 

### Agricultural users of CAP water could find the use of CAP water uneconomical. Non-Indian agricultural users could be forced to return to unsustainable groundwater pumping. Tribal users, having accepted delivery of CAP water in lieu of pursuing their claims to other water rights including groundwater, could find their newly-developed agricultural enterprises to be worthless investments.

Impacts from such regulatory requirements extend beyond the increased costs for energy and water. As authorized by Congress, NGS power not used for CAP pumping is sold to help repay CAP construction costs and to help fund Arizona Indian water rights settlements. These amounts are not trivial. Revenues from the sale of surplus NGS power now contribute about $22 million per year toward the $57 million in annual repayment obligations for the CAP. In the future, new contracts for the sale of surplus NGS power are expected32 

### to contribute $50 million or more per year toward CAP repayments and toward Indian water rights settlements, including those approved by Congress in the 2004 Arizona Water Settlements Act.

In recognition of the importance of NGS and the unique circumstances surrounding the plant, the EPA also invited the submittal of alternative proposals that would achieve the same or greater emissions reductions as EPA's proposed FIP. In response to EPA's invitation, a Technical Work Group (TWG) consisting of CAP, Salt River Project (on behalf of itself and the other NGS owners), the Bureau of Reclamation/U.S. Depar tment of the Interior, the Navajo Nation, Gila River Indian Community, Environmental Defense Fund and Western Resource Advocates was established to identify emission reduction alternatives for NGS that would be "better than BART" but that also would keep the plant open to the end of its useful life, which is 2044.

The TWG worked hard to address the concerns of the many diverse parties with an interest in the future of the plant by taking into consideration current and future economic and environmental issues. The result was a "better than BART" alternative that achieves overall greater emission reductions than the EPA's proposed FIP. Under the agreement, emissions of nitrogen oxide and carbon dioxide will be significantly reduced over the life of the plant while also maintaining essential operations at NGS for the foreseeable future.

As a result, on September 25, 2013, the EPA released a Supplemental Proposal consisting, in large part, of the TWG "better than BART" Proposal, and invited public comment on this alternative as well as the BART Determination and "better than BART" Alternative 1 contained in the agency's proposed FIP.

Carbon reduction at NGS: The TWG agreement includes a number of commitments from the Interior Department that are separate from the "better than BART" alternative, but that are critical to the issue of carbon management being addressed here today. These commitments include promoting development of clean energy, with an emphasis on Indian Tribes affected by NGS; conducting studies to identify options for replacing the federal share of energy from NGS with low-carbon dioxide emitting energy; and a commitment to reduce the CO2 associated with the energy used to pump CAP water by three (3) percent annually for a total of 11.3 million metric tons (approximately 12.5 million U.S. tons) to be achieved no later than December 31, 2035 through measures taken at NGS or through qualifying low-emitting clean energy projects. In addition, Interior's commitment will be administered through an innovative credit-based CO2 tracking and accounting program developed to assure the carbon reductions are genuine and accurately measured. The Department's clean energy commitment also includes facilitating the development of clean energy at a pace and scope to achieve 80 percent clean energy by 2035 for the U.S. share in NGS by securing approximately 26,975,000 megawatt hours of clean energy projects.

The agreement also calls for Interior to help carry out a National Renewable Energy Laboratory study (Phase 2) to identify options for replacing the federal share of energy from NGS with low-emitting energy resources, and guarantees that the environmental review for NGS will consider clean energy generation options.

Collaborative Approach Recommended:

CAP, along with other interested stakeholders, has participated since January 2011 in a series of collaborative dialogues regarding the BART rulemaking to identify reasonable solutions that would: 1) meet the energy needs of CAP so that the project can fulfill its mission of providing affordable and reliable water supplies to Arizona33 

### and Tribal communities; 2) result in continued reductions in regional haze; 3) uphold provisions of the 2004 Arizona Water Settlements Act; and 4) expand clean energy opportunities, including use of renewable energy. As a result of these efforts, and most notably the 2013 efforts of the TWG to develop a "better than BART" alternative that has since been largely accepted by the EPA for public review and comment, it is clear that the unique circumstances of the Navajo Generating Station require a collaborative process that can sort through competing interests and ultimately chart a course within any rulemaking process that maintains operation of the plant while addressing environmental concerns.

Although the final BART rule has yet to be determined by the EPA, CAP recommends that the collaborative process engaged in by the plant owners and critical stakeholders resulting ultimately in the TWG BART Proposal be considered by the EPA as a model to address carbon management at NGS. In addition, it is important that the EPA take into consideration the elements of the TWG agreement that have already beendeveloped to address offsetting carbon output at the plant. It is particularly critical that after securing the longterm operation of NGS for all the reasons previously described through the BART rulemaking process for NOx, that greenhouse-gas rulemaking on the part of the EPA does not raise, once again, the specter of plant closure.

In conclusion, CAP’s mission to provide reliable, renewable and affordable water supplies to its municipal, industrial and Indian and non-Indian agricultural customers is a multi-faceted and highly collaborative effort. This model of collaboration between the stakeholders should be implemented for NGS as well other facilities that could be impacted by this potential regulation as it is clear that there are no regulations that could be developed as a "one size fits all" solution, assuming this process is pursued by the EPA. Continued access to consistent and reasonably-priced energy supplies is critical to the operation of the CAP system. Until such t ime as other baseload energy supplies can be developed including renewable energy, NGS will remain essential to the CAP, its customers and numerous Native American tribes within Arizona.

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### Tony J. DeMarco Business Planning & Government Programs Analyst, Business Planning & Gov Prgrms phone ● (623) 869-2485 cell ● (623) 826-2480 email ● ademarco@cap-az.com34 From: drupal_admin@epa.gov on behalf of Ronald Lunt [ademarco@cap-az.com] Sent: Thursday, November 07, 2013 12:31 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Thu, 11/07/2013 - 12:30
S ubmitted values are:

Name: Ronald Lunt Email: ademarco@cap-az.com
Comments: Ronald Lunt Power Programs Manager Central Arizona Project

Testimony Public Listening Session November 5, 2013 U.S. EPA Region 9 Offices, San Francisco

On behalf of the Central Arizona Water Conservation District (CAWCD), I wish to provide the following testimony regarding development of approaches to carbon pollution under the Clean Air Act, particularly for power plants such as Navajo Generating Station that do not fall under state jurisdiction.

CAWCD, commonly referred to as the Central Arizona Project (CAP), was established in 1971 as the state agency that manages and operates the CAP system, collects revenues from ratepayers and, since substantial project completion in 1993, repays the federal government for the reimbursable costs of construction. Our goal at CAP is to provide an affordable, reliable and sustainable supply of Colorado River water to cities, industries, farms, and Tribal communities in a service area that includes more than 80 percent of Arizona's population. We have successfully achieved this goal for the past 25 years.

Background

Central Arizona Project, constructed by the Bureau of Reclamation (BOR) for the State of Arizona, is a multi-purpose water resource development and management project that delivers Colorado River water into central and southern Arizona. The largest supplier of renewable water in Arizona, CAP delivers an average of over 1.5 million acre-feet of Arizona’s 2.8 million acre-foot Colorado River entitlement each year to municipal and industrial users, agricultural irrigation districts, and Indian communities. CAP meets approximately 50 percent of municipal demand within its service area, including 45 percent of the City of Phoenix's total water demand and about 80 percent of the City of Tucson’s water demand. In addition, 47 percent of the long-term CAP entitlement is dedicated to Indian Tribal use, while 41 percent of current CAP deliveries support non-Indian agricultural production.

These renewable water supplies are critical to Arizona's economy and to the economies of Native American communities throughout the state. Nearly 90% of economic activity in the
State of Arizona occurs within CAP's service area. CAP also helps the State of Arizona meet its water management and regulatory objectives of reducing groundwater use and ensuring availability of groundwater as a supplemental water35 supply during future droughts. Achieving and maintaining these water management objectives is critical to the long-term sustainability of a state as arid as Arizona.

CAP infrastructure includes a 336-mile-long delivery system that moves water 3,000 feet uphill from the Colorado River. The system entails 14 pumping plants and one combination pumping/generating facility; 10 siphons that carry water under riverbeds and washes; three tunnels; more than 45 turnouts that connect the CAP aqueduct with customers' water delivery systems; a large storage reservoir; and a state-of-the-art control center. A large and reliable supply of baseload power is essential to operating CAP infrastructure and delivering water to its customers, including potable water treatment plants that must supply drinking water to millions of Arizona residents every day.

CAP construction necessitated the development of new power generation facilities to provide a dedicated energy source for the operation of the system. The Colorado River Basin Project
Act allowed the fed eral government, specifically the Bureau of Reclamation, to participate in the non-federal Navajo Generating Station (NGS), a 2250- Megawatt facility near Page, Arizona, to provide power for pumping CAP water as an alternative to building additional dams along the Colorado River. Construction of NGS was the result of an environmental compromise brokered by then-Secretary of the Interior Stewart Udall. NGS also was intended to help maintain and improve the economies of the Navajo Nation and the Hopi Tribe by providing revenues for the Tribal governments and high-paying jobs for Tribal members.

NGS was constructed by the Salt River Project Agricultural Improvement and Power District of Arizona, now part of the Salt River Project (SRP). In addition to BOR an d SRP, other current participants in NGS are Arizona Public Service, NV Energy, Tucson Electric Power Co., and Los Angeles Department of Water and Power. In addition to providing CAP pumping energy, the other participants utilize NGS to provide electricity to retail customers in Arizona, Nevada and California. BOR's share of NGS's output is 24.3 percent, or 546,750 kilowatts for the
benefit of CAP.

It is important to note that NGS is one of two coal-fired power plants in the United States located on tribal lands. More specifically, the plant is located on the Navajo Nation, and the Kayenta Mine, which supplies coal to the facility, is located on Navajo Nation and Hopi Tribal lands. This plant is not subject to state jurisdiction, but rather is regulated directly by the Environmental Protection Agency (EPA).

Navajo Generating Station – Decisions that Impact Water and Power Costs

Regulatory Issues: NGS is near numerous national parks, monuments, and wilderness areas, and controlling plant emissions has been and still remains a priority for CAP and the NGS participants. Pursuing this proactive commitment, in the1990's the NGS participants invested more than $400 million in scrubbers to reduce sulfur dioxide emissions. From 2009 to 2011the plant owners voluntarily installed additional environmental controls to reduce smogforming nitrogen oxide (NOx). The low-NOx burners with separated over-fire air (LNB/SOFA) cost approximately $46 million for installation on all three units at NGS.

Currently, the EPA is in the process of setting new rules to control NOx emissions at coalfired power plants, including NGS, under the Regional Haze Rule of the Clean Air Act. How this regulatory activity has been addressed at NGS by the plant owners, CAP and other stakeholders bears directly on CAP's recommendation today regarding greenhouse gas-emissions rulemaking at NGS. The following brief history will illuminate the concepts proposed, as well as address steps already taken to offset carbon generation at the plant.

On February 5, 2013, EPA issued a proposed Federal Implementation Plan (FIP) for establishing Best Available Retrofit Technology (BART) to limit NOx emissions at NGS. The proposed FIP contains a BART Determination based on a calculated NOx cap over the useful life of the plant (to 2044) and a "Better than BART" Alternative 1 that takes into account the voluntary, early36 installation of LNB/SOFA by the owners and the applicability of the Tribal Authority Rule of the Clean Air Act to NGS. Both the proposed BART Determination and "Better than BART" Alternative 1 require a NOx emissions limit within five and 10 years respectively, that can only be met at by Selective Control Technology (SCR) at a cost of approximately $544 million to as much as $1.1 billion, should SCR also require installation of baghouses.

The extremely high costs of the EPA's proposed BART SCR/baghouse options within a five- to 10-year timeframe could jeopardize continued operation of the NGS facility, with severe economic impacts to CAP users and to the Navajo Nation and the Hopi Tribe. Because a numberof critical uncertainties face the Navajo plant, including the renewal of land and coalsupply leases and the likely departure of LADWP and NV Energy from the plant by 2019, and the unusual requirement for the plant to engage in an extensive National Environmental Protection Act (NEPA) process, a near-term requirement to install SCR at NGS raises the risk of plant closure. Rather than risk a huge and potentially unrecoverable investment in retrofitting the plant with SCR technology prior to the resolution of these uncertainties, NGS participants have indicated they may pursue closing the plant and meeting their energy needs through other means.

As a consumer of NGS power rather than a retail marketer of power, CAP would be catastrophically impacted by closure of NGS, as would a number of Arizona Indian tribes:

• Should the NGS facility cease operations, CAP would have to acquire a substitute source of pumping power at market rates. Using several forecasts, CAWCD estimates that CAP pumping energy costs could increase by 50 to 300 percent (rising from $65 per acre foot to $95 - $180 per acre foot) by 2017. • The NGS, along with the Kayenta mine that provides coal to the plant, is a major contributor to the economies of the Navajo Nation, the Hopi Tribe, the City of Page, Coconino County, and the state of Arizona. NGS employs more than 520 p eople, more than 85% of whom are Navajo. The Kayenta Mine, which supplies coal to NGS, has more than 400 employees, most of whom are Native American. This accounts for about 1,000 direct jobs between the two
facilities.
• Indian Tribes would lose access to millions of dollars from the sale of surplus NGS power that otherwise could be available to assist with implementing their water rights settlements. • Agricultural users of CAP water could find the use of CAP water uneconomical. Non-Indian agricultural users could be forced to return to unsustainable groundwater pumping. Tribal users, having accepted delivery of CAP water in lieu of pursuing their claims to other water rights including groundwater, could find their newly-developed agricultural enterprises to be worthless investments.

Impacts from such regulatory requirements extend beyond the increased costs for energy and water. As authorized by Congress, NGS power not used for CAP pumping is sold to help repay CAP construction costs and to help fund Arizona Indian water rights settlements. These amounts are not trivial. Revenues from the sale of surplus NGS power now contribute about $22 million per year toward the $57 million in annual repayment obligations for the CAP. In the future, new contracts for the sale of surplus NGS power are expected to contribute $50 million or more per year toward CAP repayments and toward Indian water rights settlements, including those approved by Congress in the
2004 Arizona Water Settlements Act.

In recognition of the importance of NGS and the unique circumstances surrounding the plant, the EPA also invited the submittal of alternative proposals that would achieve the same or greater emissions reductions as EPA's proposed FIP. In response to EPA's invitation, a Technical Work Group (TWG) consisting of CAP, Salt River Project (on behalf of itself and the other NGS owners), the Bureau of Reclamation/U.S. Department of the Interior, the Navajo Nation, Gila River Indian Community, Environmental Defense Fund and Western Resource Advocates was established37 to identify emission reduction alternatives for NGS that would be "better than BART" but that also would keep the plant open to the end of its useful life, which is 2044.

The TWG worked hard to address the concerns of the many diverse parties with an interest in the future of the plant by taking into consideration current and future economic and
environmental issues. The result was a "better than BART" alternative that achieves overall greater emission reductions than the EPA's proposed FIP. Under the agreement, emissions of nitrogen oxide and carbon dioxide will be significantly reduced over the life of the plant while also maintaining essential operations at NGS for the foreseeable future.

As a result, on September 25, 2013, the EPA released a Supplemental Proposal consisting, in large part, of the TWG "better than BART" Proposal, and invited public comment on this
alternative as well as the BART Determination and "better than BART" Alternative 1 contained in the agency's proposed FIP.

Carbon reduction at NGS: The TWG agreement includes a number of commitments from the Interior Department that are separate from the "better than BART" alternative, but that are critical to the issue of carbon management being addressed here today. These commitments include promoting development of clean energy, with an emphasis on Indian Tribes affected by NGS; conducting studies to identify options for replacing the federal share of energy from NGS with low- carbon dioxide emitting energy; and a commitment to
reduce the CO2 associated with the energy used to pump CAP water by three (3) percent annually for a total of 11.3 million metric tons (approximately 12.5 million U.S. tons) to be achieved no later than December 31, 2035 through measures taken at NGS or through qualifying low- emitting clean energy projects. In addition, Interior's commitment will be administered through an innovative credit-based CO2 tracking and accounting program developed to assure the carbon reductions are genuine and accurately measured. The Department's clean energy commitment also includes facilitating the development of clean energy at a pace and scope to achieve 80 percent clean energy by 2035 for the U.S. share in NGS by securing approximately 26,975,000 megawatt hours of clean energy projects.

The agreement also calls for Interior to help carry out a National Renewable Energy Laboratory study (Phase 2) to identify options for replacing the federal share of en ergy from NGS with low-emitting energy resources, and guarantees that the environmental review for NGS will consider clean energy generation options.

Collaborative Approach Recommended:

CAP, along with other interested stakeholders, has participated since January 2011 in a series of collaborative dialogues regarding the BART rulemaking to identify reasonable solutions that would: 1) meet the energy needs of CAP so that the project can fulfill its mission of providing affordable and reliable water supplies to Arizona and Tribal communities; 2) result in continued reductions in regional haze; 3) uphold provisions of the 2004 Arizona Water Settlements Act; and 4) expand clean energy opportunities, including use of renewable energy. As a result of these efforts, and most notably the 2013 efforts of the TWG to develop a "better than BART" alternative that has since been largely accepted by the EPA for public review and comment, it is clear that the unique circumstances of the Navajo Generating Station require a collaborative process that can sort through competing interests and ultimately chart a course within any rulemaking process that maintains operation of the plant while addressing environmental concerns.

Although the final BART rule has yet to be determined by the EPA, CAP recommends that the collaborative process engaged in by the plant owners and critical stakeholders resulting ultimately in the TWG BART Proposal be considered by the EPA as a model to address carbon management at NGS. In addition, it is important that the EPA take into consideration the elements of the TWG agreement that have already been developed to address offsetting carbon38 output at the plant. It is particularly critical that after securing the long- term operation of NGS for all the reasons previously described through the BART rulemaking process for NOx, that greenhouse- gas rulemaking on the part of the EPA does not raise, once again, the specter of plant closure.

In conclusion, CAP’s mission to provide reliable, renewable and affordable water supplies to its municipal, industrial and Indian and non-Indian agricultural customers is a multi- faceted and highly collaborative effort. This model of collaboration between the stakeholders should be implemented for NGS as well other facilities that could be impacted by this potential regulation as it is clear that there are no regulations that could be developed as a "one size fits all" solution, assuming this process is pursued by the EPA. Continued access to consistent and reasonably-priced energy supplies is critical to the operation of the CAP system. Until such time as other baseload energy supplies can be developed including renewable energy, NGS will remain essential to the CAP, its customers and numerous Native American tribes within Arizona.

Web Area: Carbon Pollution Standards39 From: Maner Shaw [MShaw@shawinterests.com] Sent: Thursday, November 07, 2013 11:26 AM To: Carbon Pollution Input Subject: Comment

Ladies and Gentlemen,
N ationwide mandates on carbon emission for power plants will once again send a crippling effect on our nations business’s to both small proprietors and large corporations alike, at a time when we need to keep production costs low to continue to stimulate our economy. Industry as a whole over the last 30 years has been crippled by the EPA’s one size fits all mandates and hundreds of thousands of jobs have been lost to foreign countries. I am all for clean air and clean water, but it is time for the EPA to begin to recognize that it is free enterprise and not government that supports the wealth of ou r nation and find methods that are win-win by working with the engineers and financial planners of our nations businesses to find economic solutions and not impose government mandates.



## Maner B. Shaw

Shaw Interests, Inc. 310 W. Wall St, Suite 305 Midland, TX 79701 Phone: (432) 685-1404 Fax: (432) 685-1343
mshaw@shawinterests.com

CONFIDENTIALITY NOTICE: This message is confidential and intended only for the use of the individual or entity to whom it is addressed. It may contain confidential and privileged information which is legally protected by law from disclosure. You are notified that if you are not the intended recipient, then reading or disclosing this communication is prohibited.40 From: Knoll, Allen M [Allen.Knoll@nacoal.com] Sent: Thursday, November 07, 2013 9:23 AM To: Carbon Pollution Input Subject: "Contact Us Comment: Carbon Pollution Standard Wedsite"

The need to finally end this assault on the coal industry must come to an end. As a resident of North Dakota and

i nvolved in the coal industry I am very aware of the positive benefits this state and other states have receive from the coal industry! Our state goes above and beyond to comply with current standards. I strongly feel the need to end this war on an industry that is sound, reliable and creates inexpensive power for our country. North Dakota has always been
an leader in environmental standards and our commitment to air quality; one of seven states that meets the ambient air standards. I urge the EPA not to force states to adopt these new greenhouse gas performance standards on existing power plants, this is bad for our state and bad for our nations. I also question the science, the conflicting reports of the modeling and EPA making assumptions from flawed inconsistent data . Finally how can EPA make these unnecessary decisions that would radically change our country for the worst, placing heavier burdens on the American people! Thank you for your time.



### Allen M. Knoll Maintenance Manager The Falkirk Mining Company 2801 1st ST SW Underwood, ND 58576 Telephone: 701-442-5751 Ext. 451 Cell 701-214-3750

a llen.knoll@nacoal.com



### N OTICE: This message may contain privileged and confidential information which is protected from disclosure. If you are not the addressee indicated in this communication (or an agent or employee responsible for delivering this communication to such person), you may not read, copy, use or disseminate this message to any other person. In such case, you should destroy this communication and kindly notify the sender immediately by reply email or telephone. Please advise the sender immediately if you or your employer do not consent to Internet email for messages of this kind. This communication is restricted to the intended recipient and is not to be provided to a third party without the prior consent of The North American Coal Corporation or its representatives.41 From: Jody Harlan & Tim Wagner [hwinc@cox.net] Sent: Thursday, November 07, 2013 3:07 AM To: Carbon Pollution Input Subject: Carbon Pollution Comments



## Comments to the EPA at Public Listening Sessions i n Dallas, Texas on Carbon Pollution Standards Why We Should Not Let the Fox Watch the Hen House

I am the chair of Sierra Club in Oklahoma. I am here today to thank the Environmental Protect Agency for taking the first steps under President Obama’s Climate Action Plan to reduce carbon pollution from existing power plants.

The electric power companies are responsible for 33 percent of total greenhouse gas emissions in the U.S. Their power plants are the largest stationary source of carbon pollution accounting g for 60 percent of U.S. stationary source greenhouse gas emissions. Greenhouse gas pollution threatens Americans’ health and welfare leading to devastating climate disruption with a range of long-lasting and deadly effects.

Oklahomans have endured another year of devastating tornados that have steadily grown more severe in intensity. It has been difficult so far to prove that climate change is a factor in storm severity, but many of us believe science will someday confirm the connection.

Meanwhile, the evidence is there to prove that climate change has contributed to dangerous floods, ravaging wildfires, record drought, and superstorm Sandy, which cost Americans hundreds of lives and hundreds of billions of dollars.

The EPA has taken important first steps by setting standards that will cut the carbon pollution from automobiles and trucks nearly in half by 2025. The agency also proposed standards to limit the carbon pollution from new power plants. But the EPA has not yet tackled the primary greenhouse gas pollutant, carbon dioxide, which accounts for 84 percent of greenhouse gas emissions from hundreds of existing fossil-fueled power plants in the U.S.

We can't afford to wait any longer before we act. For the health and welfare of Americans, for the nation's economy, and for the stability of the planet, now is the time to reduce pollution generated by America's power plants. We also need to significantly increase energy efficiency and conservation in order to reduce the threat of climate change.

Jody Harlan, Chapter Chair Sierra Club Oklahoma (405) 354-3189 cell (405) 326-3600 hwinc@cox.net

Visit Sierra Club Oklahoma on the web at http://oklahoma.sierraclub.org/42 From: Chris Billings [cbillings@jennmar.com] Sent: Wednesday, November 06, 2013 10:25 AM To: Carbon Pollution Input Subject: EPA Listening Sessions



### G ood morning/afternoon, my name is Chris Billings. I am Customer Service and Global Logistics coordinator with Jennmar Specialty Products.

Thank you for the opportunity to speak today about EPA’s plan to regulate carbon dioxide emissions from coal-fired power plants.

Jennmar is concerned about EPA’s carbon regulations because of their impact on the use of coal to produce affordable and reliable electricity. Coal plays a crucial role in providing electricity to consumers in virtually every state in the nation. For example, coal provides more than one quarter of the electricity in 29 states with a collective population of more than 175 million people. Unfortunately, EPA regulations have already contributed to the closure of 300 existing coal units in 33 states. And recently proposed regulations would ban new, efficient state-of- art coal plants.

To begin with, we disagree with EPA’s decis ion to regulate greenhouse gas emissions
under the Clean Air Act. EPA regulations are an ineffective and economically harmful way to address climate change. But, since EPA is developing these regulations anyway, I want to offer Jennmar’s perspective.

EPA is focused on reducing carbon dioxide emissions f rom coal- fired power plants as a way to address global climate change. However, carbon dioxide emissions from the U.S. coal fleet represent only 3 percent of global greenhouse gas emissions. Reducing c arbon dioxide emissions from the U.S. coal fleet will increase energy prices without having any meaningful effect on global climate change. Further, the U.S. electric sector has already reduced its carbon dioxide emissions more than any other sector of the economy. U.S. power plants have reduced carbon dioxide43

### emissions by 16 percent below 2005 levels, and carbon dioxide emissions from coalfired power plants have declined by almost 24 percent.

With that in mind, we believe EPA should follow thes e princ iples in developing carbon regulations:

First, EPA’s carbon regulations should do no harm. Carbon regulations should not interfere with affordable electricity prices and reliable electricity supplies, especially in states that rely on coal.

Second, EP A’s carbon regulations should provide states with all the flexibility they need in order to develop plans that suit their unique circumstances, including continuing their reliance on coal if they choose that approach. Also, EPA must give states ample time to develop and implement their plans.

Third, coal plant owners are expected to invest over $30 billion in the near- term to further reduce emissions of conventional air pollutants. EPA must ensure that carbon regulations do not cause additional prematur e closures of coal units and, therefore, stranded investments in emission controls.

Finally, EPA should remove regulatory barriers to efficiency improvements at existing coal-fueled power plants. Efficiency improvements are a cost- effective way to reduce emissions, while maintaining affordable and reliable operations. EPA should remove barriers to these projects.

Thank you for your attention.

Chris Billings Inside Sales / 

### Logistics

Jennmar Specialty Products
559 Wardell Industrial Park Rd. | Cedar Bluff, VA 24609 |44

 Phone : 276.964.7000 | Fax : 276.964.4752 | cbillings@jennmar.com www.jennmar.com45 From: Karen McNew [karen.mcnew@ieca.coop] Sent: Wednesday, November 06, 2013 10:02 AM To: Carbon Pollution Input Subject: Carbon pollution standards



### My name is Karen McNew and I am Manager of Member Services for Intercounty Electric Cooperative in rural
M issouri. Electric cooperatives in Missouri serve some of the most economically disadvantaged members of our society. A large portion of our members are seniors 55 years older. One third of these senior members earn less than $25,000 a year, and one third are retired and living on a fixed income. On the other end of the spectrum, those younger members just getting started with families and careers also earn less than $25,000 a year. These are the people least able to afford a rate increase of the magnitude we see coming if the proposed rules from EPA are enacted. I am sending this message on behalf of these people who can’t afford an increase
in their electric bill. I respectfully ask the EPA to recognize and respect the fact that the electric cooperatives in Missouri followed every law and every regulation when we constructed our power plants and we cannot afford to lose any option for affordable electricity. Please develop a final rule that will allow us to continue to provide safe, affordable, reliable non-profit electric power to our members from all sources, including coal.



## Karen McNew
INTERCOUNTY ELECTRIC COOPERATIVE Manager Member Services & Development
P O Box 209, 102 Maple Avenue Licking MO 65542 573-674-2211, ext 1237
cell# 417-260-0115 karen.mcnew@ieca.coop46 From: Tom Borowiak [TBorowiak@cecmo.com] Sent: Wednesday, November 06, 2013 9:24 AM To: Carbon Pollution Input Subject: EPA - Do not remove affordable clean coal from our sources of electricity.



### My name is Thomas Borowiak. I am an employee, VP of Engineering, of an electric utility in Missouri. I wanted to tell you that affordable electricity is absolutely essential to the people that buy their

e lectricity from my cooperative. Adopting a regulatory strategy that will deliberately eliminate one of the most affordable sources of

e lectricity for our members can have only one outcome - their electric rates will go up. Please do not finalize a rule that removes affordable clean coal from our sources of electricity. Thank you, Thomas Borowiak, P.E. VP of Engineering Citizens Electric Corporation

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Internet. The information in this e-mail is confidential and may be legally privileged. It is intended solely for the addressee. Access to this e-mail by anyone else is

u nauthorized. If you are not the intended recipient, any disclosure,copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. If you believe that you have received this e-mail in error, please contact the sender by return e-mail and permanently delete the original and any copy of this e-mail message or attachments and any printed originals and copies. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, or for any damage caused by any virus which arises as a result of e-mail transmission.47 From: drupal_admin@epa.gov on behalf of John T. Boyd Company [jtb2@jtboyd.com] Sent: Wednesday, November 06, 2013 9:19 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Wed, 11/06/2013 - 09:18
S ubmitted values are:

Name: John T. Boyd Company
Email: jtb2@jtboyd.com
Comments: Good morning/afternoon, my name is John T. Boyd II. I am the president and chief executive officer at John T. Boyd Company.

Thank you for the opportunity to speak today about EPA’s plan to regulate carbon dioxide emissions from coal-fired power plants.

John T. Boyd Company is concerned about EPA’s carbon regulations because of their impact on the use of coal to produce affordable and reliable electricity. Coal plays a crucial role in providing electricity to consumers in virtually every state in the nation. For example, coal provides more than one quarter of the electricity in 29 states with a collective population of more than 175 million people. Unfortunately, EPA regulations have already contributed to the closure of 300 existing coal units in 33 states. And recently proposed regulations would ban new, efficient state-of-art coal plants.

To begin with, we disagree with EPA’s decision to regulate greenhouse gas emissions under the Clean Air Act. EPA regulations are an ineffective and economically harmful way to address climate change. But, since EPA is developing these regulations anyway, I want to offer John T. Boyd Company’s perspective.

EPA is focused on reducing carbon dioxide emissions from coal-fired power plants as a way to address global climate change. However, carbon dioxide emissions from the U.S. coal fleet represent only 3 percent of global greenhouse gas emissions. Reducing carbon dioxide
emissions from the U.S. coal fleet will increase energy prices without having any meaningful effect on global climate change. Further, the U.S. electric sector has already reduced its carbon dioxide emissions more than any other sector of the economy. U.S. power plants have reduced carbon dioxide emissions by 16 percent below 2005 levels, and carbon dioxide emissions from coal- fired power plants have declined by almost 24 percent.

With that in mind, we believe EPA should follow these principles in developing carbon regulations:

First, EPA’s carbon regulations should do no harm. Carbon regulations should not interfere with affordable electricity prices and reliable electricity supplies, especially in states that rely on coal.

Second, EPA’s carbon regulations should provide states with all the flexibility they need in order to develop plans that suit their unique circumstances, including continuing their reliance on coal if they choose that approach. Also, EPA must give states ample time to develop and implement their plans.

Third, coal plant owners are expected to invest over $30 billion in the near-term to further reduce emissions of conventional air pollutants. EPA must ensure that carbon regulations do48 not cause additional premature closures of coal units and, therefore, stranded investments in
emission controls.

Finally, EPA should remove regulatory barriers to efficiency improvements at existing coalfueled power plants. Efficiency improvements are a cost-effective way to reduce emissions, while maintaining affordable and reliable operations. EPA should remove barriers to these projects.

Thank you for your attention.

Web Area: Carbon Pollution Standards49 From: drupal_admin@epa.gov on behalf of Frank Calandra, Jr. [fcalandra@jennmar.com] Sent: Wednesday, November 06, 2013 9:01 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Wed, 11/06/2013 - 09:01
S ubmitted values are:

Name: Frank Calandra, Jr.
Email: fcalandra@jennmar.com
Comments: My name is Frank Calandra, Jr. I am President & CEO of Jennmar Corporation

Thank you for the opportunity to contact you about EPA’s plan to regulate carbon dioxide emissions from coal-fired power plants.

Jennmar is concerned about EPA’s carbon regulations because of their impact on the use of coal to produce affordable and reliable electricity. Coal plays a crucial role in providing electricity to consumers in virtually every state in the nation. For example, coal provides more than one quarter of the electricity in 29 states with a collective population of more
than 175 million people. Unfortunately, EPA regulations have already contributed to the closure of 300 existing coal units in 33 states. And recently proposed regulations would ban new, efficient state-of-art coal plants.

To begin with, we disagree with EPA’s decision to regulate greenhouse gas emissions under the Clean Air Act. EPA regulations are an ineffective and economically harmful way to address climate change. But, since EPA is developing these regulations anyway, I want to offer Jennmar’s perspective.

EPA is focused on reducing carbon dioxide emissions from coal-fired power plants as a way to address global climate change. However, carbon dioxide emissions from the U.S. coal fleet represent only 3 percent of global greenhouse gas emissions. Reducing carbon dioxide emissions from the U.S. coal fleet will increase energy prices without having any meaningful effect on global climate change. Further, the U.S. electric sector has already reduced its carbon dioxide emissions more than any other sector of the economy. U.S. power plants have reduced carbon dioxide emissions by 16 percent below 2005 levels, and carbon dioxide emissions from coal- fired power plants have declined by almost 24 percent.

With that in mind, we believe EPA should follow these principles in developing carbon regulations:

First, EPA’s carbon regulations should do no harm. Carbon regulations should not interfere with affordable electricity prices and reliable electricity supplies, especially in states that rely on coal.

Second, EPA’s carbon regulations should provide states with all the flexibility they need in order to develop plans that suit their unique circumstances, including continuing their reliance on coal if they choose that approach. Also, EPA must give states ample time to develop and implement their plans.

Third, coal plant owners are expected to invest over $30 billion in the near-term to further reduce emissions of conventional air pollutants. EPA must ensure that carbon regulations do50 not cause additional premature closures of coal units and, therefore, stranded investments in
emission controls.

Finally, EPA should remove regulatory barriers to efficiency improvements at existing coalfueled power plants. Efficiency improvements are a cost-effective way to reduce emissions, while maintaining affordable and reliable operations. EPA should remove barriers to these projects.

Thank you for your attention.

Web Area: Carbon Pollution Standards51 From: Schaar, Trevor F [trevor.schaar@nacoal.com] Sent: Wednesday, November 06, 2013 8:41 AM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

I am writing in comment on the proposal by EPA to place carbon emission limits on existing fossil fueled electric

g enerating stations. I believe this is a grossly misguided regulatory initiative at this time. Unlike virtually all previous emissions limits established through rulemaking, there is no commercially and technically proven technology to accomplish any significant reduction in CO2 emissions from power plants that already are in service, short of completely rebuilding them as if they were new projects. Such a proposal will, despite whatever limit is applied, have the effect of eliminating coal fired generation, no matter how clean they are with regard to the other regulated emissions, from service in providing the baseload of electricity so critical to our everyday lives and well being. Even if achieved, such limits will have a negligible effect upon the presumed connection with global climate change, which would require a global reduction by nations such as China and the rest of Asia and Europe. There is no available replacement for coal fired baseload other than natural gas, and reducing the diversity of our fuel sources to a single source will undoubtedly have significant cost inflationary effects and require enormous additional infrastructure for pipelines and other means of moving the supply. Economically punishing our own populace, and especially those most vulnerable to energy costs, while achieving no significant environmental benefits, while the rest of the world enjoys the benefits of increasing coal based energy makes no sense for our government or our society. Our economy and our society would be far better served by working on the Clean Air Act and its regulations to encourage the removal of outdated unscrubbed and grandfathered generation facilities and replacing them with the latest in gasification and carbon capture technology, while maintaining and improving the achievable emissions from the existing fleet of stations built under the rules of the Act. Our nation is totally dependent on affordable and dependable electricity supplies. One has only to look to Europe and especially the UK to see that their efforts to maximize the use of, and move to “renewable” energy has resulted in electricity becoming so expensive and unreliable that many of their people are going into another winter without electricity. I urge the EPA to back away from any further consideration of carbon limiting regulations on existing generation stations and instead focus on using existing and proven technologies to affordably and predictably improve emissions where achievable across the country. Thank you for the opportunity to comment on this important and potentially dangerous regulatory initiative.



## Trevor Schaar
The Falkirk Mining Company
2 801 1 st St. SW
U nderwood, ND 58576-1087 (701) 442-5751
trevor.schaar@nacoal.com



### N OTICE: This message may contain privileged and confidential information which is protected from disclosure. If you are not the addressee indicated in this communication (or an agent or employee responsible for delivering this communication to such person), you may not read, copy, use or disseminate this message to any other person. In such case, you should destroy this communication and kindly notify the sender immediately by reply email or telephone. Please advise the sender immediately if you or your employer do not consent to Internet email for messages of this kind. This communication is restricted to the intended recipient and is not to be provided to a third party without the prior consent of The North American Coal Corporation or its representatives.52 From: Mark McLeod [sustainablemcleod@gmail.com] Sent: Wednesday, November 06, 2013 12:14 AM To: Carbon Pollution Input Cc: Mark McLeod; Greta Twombly; Richard Eidlin; David Brodwin; Keven Kennedy; Erin Kilmer Neel; lisa martinengo; Amy Barr; Elisabeth Hogvall; johanna lovett; Jenny Lovett Subject: Transcript, my testimony, EPA Listening Session, San Francisco, 11/5/13



### I am Mark McLeod. I work and live in the San Francisco East Bay.

I am a member of the Board of Partners of the American Sustainable Business Council. The Council is a Washington DC-based association of businesses and business associations across the country. They are united by their commitment to operate in such a way that they are honoring the Triple Bottom Line -- people, planet, profit.

The Council supports EPA's commitment to establish guidelines on carbon emissions for existing power plants, and hopes that EPA will establish related guidelines to power plants under construction and to power plants that may be constructed in the future.

The Council agrees with climate change activist, Bill McKibben, that concentrations of GHGs in the atmosphere are already so dangerously high that there is only one place where coal, oil, and gases that have not already been extracted belong, and that is right where they are -- BENEATH THE EARTH!

The Council supports the most rapid possible development of renewables, such as wind and solar, so that we may, as hastily as possible, wean ourselves altogether from carbon-based energy.

The Council believes that industrialized nations can protect themselves from self- destruction only by recovering an understanding that they are "a part of nature," and that, as such, they must love and protect nature if they wish nature to love and protect them.53 From: drupal_admin@epa.gov on behalf of Glenn A. Goss [ggoss@jennmar.com] Sent: Tuesday, November 05, 2013 11:33 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Tue, 11/05/2013 - 23:33
S ubmitted values are:

Name: Glenn A. Goss
Email: ggoss@jennmar.com
Comments: EPA Listening Sessions

Good morning/afternoon, my name is Glenn Goss. I am Corporate Safety Manager with Jennmar.

Thank you for the opportunity to speak today about EPA’s plan to regulate carbon dioxide emissions from coal-fired power plants.

Jennmar is concerned about EPA’s carbon regulations because of their impact on the use of coal to produce affordable and reliable electricity. Coal plays a crucial role in providing electricity to consumers in virtually every state in the nation. For example, coal provides more than one quarter of the electricity in 29 states with a collective population of more
than 175 million people. Unfortunately, EPA regulations have already contributed to the closure of 300 existing coal units in 33 states. And recently proposed regulations would ban new, efficient state-of-art coal plants.

To begin with, we disagree with EPA’s decision to regulate greenhouse gas emissions under the Clean Air Act. EPA regulations are an ineffective and economically harmful way to address climate change. But, since EPA is developing these regulations anyway, I want to offer [organization’s] perspective.

EPA is focused on reducing carbon dioxide emissions from coal-fired power plants as a way to address global climate change. However, carbon dioxide emissions from the U.S. coal fleet represent only 3 percent of global greenhouse gas emissions. Reducing carbon dioxide emissions from the U.S. coal fleet will increase energy prices without having any meaningful effect on global climate change. Further, the U.S. electric sector has already reduced its carbon dioxide emissions more than any other sector of the economy. U.S. power plants have reduced carbon dioxide emissions by 16 percent below 2005 levels, and carbon dioxide emissions from coal- fired power plants have declined by almost 24 percent.

With that in mind, we believe EPA should follow these principles in developing carbon regulations:

First, EPA’s carbon regulations should do no harm. Carbon regulations should not interfere with affordable electricity prices and reliable electricity supplies, especially in states that rely on coal.

Second, EPA’s carbon regulations should provide states with all the flexibility they need in order to develop plans that suit their unique circumstances, including continuing their reliance on coal if they choose that approach. Also, EPA must give states ample time to develop and implement their plans.54 Third, coal plant owners are expected to invest over $30 billion in the near-term to further reduce emissions of conventional air pollutants. EPA must ensure that carbon regulations do
not cause additional premature closures of coal units and, therefore, stranded investments in
emission controls.

Finally, EPA should remove regulatory barriers to efficiency improvements at existing coalfueled power plants. Efficiency improvements are a cost-effective way to reduce emissions, while maintaining affordable and reliable operations. EPA should remove barriers to these projects.

Thank you for your attention.

Web Area: Carbon Pollution Standards55 From: jrust [jrust@bellsouth.net] Sent: Tuesday, November 05, 2013 8:43 PM To: Carbon Pollution Input Cc: jim rust Subject: Response to Carbon Pollution Standards For Existing Stationary Power Plants



### The following information is written to protest any form of carbon (carbon dioxide) pollution standards on existing stationary power plants.

Regards,

Dr. James H. Rust, Professor of nuclear engineering (ret.) and policy adviser The Heartland Institute



### REPORT ON EPA PUBLIC LISTENING SESSION ON REDUCING CARBON POLLUTION IN ATLANTA, GEORGIA OCTOBER 23

The Environmental Protection Agency (EPA) had hearings in Atlanta, GA October 23 soliciting public comments about reducing carbon (carbon dioxide) pollution from existing stationary power plants. The EPA has a goal of eliminating coal from power production and if successful most likely would lead to future attacks on natural gas as a fuel source.

Approximately 200 attended the opening session Wednesday afternoon. The Region 4 EPA Director made introductory remarks about the need for reducing carbon dioxide pollution siting severe climate events that plagued the United States in 2012. The country had 8 million acres burned by wildfires, droughts, floods, and in particular the devastating hurricane Sandy that hit New York last October. The EPA uses reports from the UN Intergovernmental Panel on Climate Change (UNIPCC) as their sole source for scientific information on climate change. Apparently no one told the Region 4 Director the 2013 UNIPCC report stated carbon dioxide is not responsible for weather events like Sandy.

Speakers were allowed 3 minutes for presentations which is a woeful lack of time for such an important topic. I stayed to hear presentations from 31 speakers--29 protested these rules would create burdensome increases in electricity prices and 2 said the rules were necessary to save the planet.

I was the twentieth speaker and attacked the scientific basis EPA used for their rules that was not addressed by other speakers up to the end of 31 presentations. I passed out a 4-page handout that gave detailed, referenced reasons why EPA actions had no scientific merit. The handout follows this material.

I immediately attacked the EPA for rules that endangered public health and would ruin the nation's economy. I challenged the EPA to bring their top scientific advisor to Atlanta and engage in a debate on the merits of carbon dioxide being anything but a necessary airborne fertilizer and an insignificant player on climate behavior. The public should put pressure on the EPA to be forthright in engaging in open debate about the merits of their onerous proposals. The rules proposed by EPA will have a negative impact of trillions of dollars on the United States' economy.

The EPA selected 11 locations for public testimony. Testimony will continue until November 8. Information on these sessions and to register online is at < http://www2.epa.gov/carbon-pollution-standards/public -listeningsessions >. For those who cannot attend these sessions, input can be e-mailed to carbonpollutioninput@epa.gov by November 8, 2013.56 

### As an attempt to stop these economy killing carbon dioxide pollution standards, the public is urged to e-mail their complaints immediately and if possible testify at a public hearing.

TESTIMONEY BEFORE EPA ON PUBLIC LISTENING SESSIONS ON REDUCING CARBON POLLUTION FROM EXISTING POWER PLANTS, OCTOBER 23, 2013 Dr. James H. Rust, Policy Advisor The Heartland Institute

J'accuse were the headline words that shocked France in 1898 by Emile Zola in his famous news article protesting corruption and anti-Semitism in the French Military by convicting Alfred Dreyfus of treason. These words are used again in protesting the attack of the Environmental Protection Agency (EPA) on coal use based
on unsound scientific reasons.

J'accuse the EPA of proposing rules to abolish use of coal for stationary power plants that unnecessarily increases costs of electric power generation with harm to health and economy of our country. J’accuse the EPA of implementing rules to abolish use of coal for future electric power plants with unnecessary harmful increased cost for electricity. J’accuse the EPA of implementing Mercury and Air Toxic Standards (MATS) rules on coal-fired electric power plants that added unnecessary expenses to their operation with forced plant shutdowns and increased electricity costs.

For five years the EPA has waged war on fossil fuels due to misguided views carbon dioxide from burning fossil fuels causes catastrophic global warming. The EPA is substituting words carbon pollution for carbon dioxide in order to mislead the public about its aims. To the public, the words carbon pollution means soot that conjures up images of blacked snow in the winter and soot-covered cars prevalent before the 1960s—a time when coal was burned without environmental controls. This is the same misrepresentation applied to global warming alleged due to burning fossil fuels. When global warming stopped in 1998, in spite of increased use of fossil fuels, climate change was substituted for global warming as key words for predicted cataclysmic planet future. In a sense alarmist views can’t miss with this label because climate change is continuous over the 4 billion-year planet history.

Fossil fuel use has annually increased in an energy-starved planet due to demands of poorer inhabitants for a decent living standard. This caused an increase in atmospheric carbon dioxide from 310 parts per million (ppm) in 1950 to 400 ppm in 2013. For more than a century it has been hypothesized atmospheric carbon dioxide absorbs infrared radiation and re-emits the radiation back to the atmosphere causing planet warming labeled the greenhouse effect. Water vapor, with an average atmosphere concentration of 10,000 ppm, produces the same effect. Concerns about global warming caused by increased fossil fuel use resulted in creation of the United Nations organization Intergovernmental Panel on Climate Change (UNIPCC) in 1988 to study effects of increasing atmospheric carbon dioxide. Since 1990, the IPCC has published a series of five reports (1990, 1995, 2001, 2007, and 2013) stating their beliefs in the role of carbon dioxide on climate and made projections of future global temperatures based on computer generated data from global climate models.

The EPA has used IPCC reports as their major source of information about the role of increasing atmospheric carbon dioxide from increasing fossil fuel use. The IPCC reports estimate increased global warming so the EPA embarked on a path to reduce fossil fuel use starting with coal, oil, and, natural gas. The UNIPPC was an international organization predicting future climate change without oversight. To balance their reporting, the Nongovernmental International Panel on Climate Change (NIPCC) was created in 2003.

The 2007 IPCC report stirred up controversy over errors and the NIPCC issued a countering report Nature, Not Human Activity, Rules the Climate in 2008. To highlight more details about errors in the 2007 IPCC report, the NIPCC produced an 856-page report Climate Change Reconsidered: The 2009 Report of the Nongovernmental57 

### International Panel on Climate Change. The Heartland Institute assisted in preparation and publication of these reports.

Anticipating science to be overlooked by the future 2013 IPCC report, the NIPCC produced Climate Change Reconsidered: The 2011 Interim Report of the Nongovernmental International Panel on Climate Change . The report featured new scientific evidence and information overlooked by the 2009 report and is found on the
Internet at< www.nipccreport.org > .

With much media attention and leaking of portions of its report, the UNIPCC announced publication of its fifth report September 27, 2013. In anticipation of the IPCC report, the NIPCC released its first of two reports the 1000-page Climate Change Reconsidered II: Physical Science and 20-page Summary for Policymakers September 17, 2013. Key takeaway messages are (1) the human impact on climate is very small and (2) any change in temperatures that might be occurring or will occur in the future are so small they won't be noticed against the climate’s entirely natural variability . These reports are available on the Internet at < http://www.climatechangereconsidered.org >.

In order to compare information from the NIPCC with that of the IPCC, the 2013 IPCC Summary for Policymakers issued September 27, 2013 is found at < http://ipcc.ch/ >. The IPCC report glosses over no global warming for 15 years and failure of all global climate models to match experimental global temperature data.

The EPA refuses to examine information that counters global warming is produced by increased use of fossil fuels and any benefits achieved by global warming. There are thousands of papers and books showing benefits of global warming and increased carbon dioxide on the planet. A good summary of benefits is the paper in the October 19, 2013 Spectator “Why Climate Change is Good For The World” by Matt Ridley found

at < http://www.spectator.co.uk/features/9057151/carry-on -warming/ >.

Warming saves lives, while cold kills. It is estimated 29,000 Britons died in the United Kingdom the past winter due to cold. Increasing atmospheric carbon dioxide increases plant growth and makes plants more resistant to drought due to larger root systems. We are able to produce enough food to feed 7 billion on the planet due to the 40 percent increase in atmospheric carbon dioxide concentrations since the start of the
Industrial Revolution.

It is suspected the EPA will issue rules involving carbon dioxide emissions for current power plants similar to rules applying to future power plants—1000 pounds of carbon dioxide emissions per megawatt-hour (MW-hr.) for natural gas-fueled power plants and 1100 pounds of carbon dioxide emissions per MW-hr. for coal-fired power plants. The rules for future power plants were issued September 2013 which prompted Investor’s Business Daily to write an editorial September 20, 2013 “New Rules On Power Plants Will Kill Coal Industry”
found at < http://news.investors.com/ibd-editorials/092013-6719 84-epa-rules-will-send-energy-costs-upsharply.htm > . The editorial stated, “Far from being a plan to clean up the environment, it is in fact a road map to de-industrialization and poverty.” Examples were given of power plant shutdowns and the threat of businesses to leave the country because of escalating electricity prices. Gas turbine combined cycle (GTCC) power plants can meet requirements of 1000 pounds of carbon dioxide emissions per MW-hr. High performance coal- fired power plants typically emit 1800 pounds of carbon dioxide per MW- hr. and can’t meet these standards without carbon dioxide capture and sequestration (CDCS) of at least 40 percent of carbon dioxide emissions.

CDCS has not been demonstrated for large power plants. It is a very costly process that requires one-third the power output of plants and needs safe places for underground storage of enormous amounts of high-pressure carbon dioxide. Widespread application of CDCS would require annual storage of billions of tons of carbon
dioxide.58 

### Underground storage of high-pressure carbon dioxide presents safety problems never encountered in the United States. Carbon dioxide is denser than air and large leaks from underground storage would produce situations where leaking gas spreading along the earth’s surface would suffocate all encountering the gas. In 1986, carbon dioxide emerging from Lake Nyos in the Cameroon suffocated 1700 people and thousands of head of cattle.
Similar situations have occurred elsewhere in Africa.

It is ironic the EPA charged with safety of American citizens is taking a non-existent hazard of carbon dioxide emissions from burning coal and creating situations of enormous waste of money on CDCS that kills unsuspecting citizens. This debacle applies to controlling carbon dioxide emissions from current and future coal-fired power plants.

A critique of EPA’s Mercury and Air Toxic Standards (MATS) by Prof. James H. Rust “Do New EPA Regulations on Power Plant Mercury Effluents Make Sense?” is published May 3, 2011 by The Heartland
Institute < http://blog.heartland.org/2011/05/do-new-epa-regulat ions-on-power-plant-mercury-effluents-makesense/ >. These rules reduce mercury emissions, that are not problems, from coal-fired power plants at great costs and shut downs of operating power plants. At the same time EPA endorses use of compact fluorescent light bulbs (CFL) because they use less electricity. CFLs contain about 4 milligrams of mercury and when you factor in over one billion CFLs in use today and fast growing, you have a vast potential for mercury contamination directly inside homes from bulb breakage and improper disposal. When four billion light sockets in homes are filled with CFLs (18 tons of mercury), considerations of mercury contamination from coal- burning power plants may look silly. Humans occupy less than one-tenth percent of the United States’ land area for living space; so inside mercury contaminations per square foot can be large.

In summary, using poor science and a lack of judgment, the EPA has promulgated rules pertaining to fossil fuel use that are aimed at eliminating use of the nation’s vast reservoir of fossil fuels. Once these rules are implemented, more onerous rules must follow. Great economic damage is done that leads to poverty for the nation. On top of these problems, the rules that are issued in the name of promoting health create health problems far more damaging.

The EPA is succeeding in these objective due to lack of realistic media attention and public apathy. At the end of WWII, Pastor Martin Niemoller was asked how the destructive Nazis Party could take over the country in the 1930s. He said apathy and produced a four-sentence verse that described his failure to sound alarm about impending events from demonic National Socialism.

In our present time, Pastor Niemoller might have said the following about EPA pollution rules: First they closed the coal mines, and I didn't speak out because I was not a miner. Then they stopped oil and gas drilling, and I didn't speak out because I didn't work in oil fields. Then they shut down nuclear power plants, and I didn't speak out because I didn't work at nuclear power plants. Then they shut off all my electricity and there was no one left to speak out for me.

Heed these words; the EPA is set upon a path to destroy the Unites States economy and impoverish most of our citizens. Poverty kills as surely as disease.59 From: drupal_admin@epa.gov on behalf of Alyssa Burgin [alyssa@texasdroughtproject.org] Sent: Tuesday, November 05, 2013 8:40 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Tue, 11/05/2013 - 20:40
S ubmitted values are:

Name: Alyssa Burgin Email: alyssa@texasdroughtproject.org
Comments: As Executive Director of the Texas Drought Project, a member of numerous coalitions in Texas which are fighting for cleaner air and fewer emissions, I would like to applaud the proposed carbon emission pollution standards. Additionally, I would like to urge that the proposed standards be extended to existing fossil-fuel fired electric utility generating units. Ideally, a moratorium should be issued on construction of new coal plants Standards shall not be relaxed simply because of Texas political pressure or threats from the backwards, climate-change denying TCEQ or attorney general, they should be enforced across the board, with no exemptions, grandfathering or delays. There should be a date set by which all coal plants in Texas must cease operation, preferably 2030 or before. In order to ease the transition period, the federal government should offer subsidies and tax breaks for the building of platforms utilizing renewable energy--wind, solar, geothermal. These should equal or exceed subsidies offered for the building of nuclear plants or the tax breaks given to oil and gas. Federal government advisors should work with municipalities in leading community planning sessi ons which will help determine the future of energy production in different regions. There is no question that continued emissions from EGU's in Texas is harming the residents of our state, with increased asthma and other respiratory illnesses among both children and adults. The cost of treating those illnesses, together with lost productivity, is skyrocketing. In 1994, these costs exceeded 763 million dollars according to state records, and is now projected at well over one billion. But more significant than the costs are the tolls these diseases take on human lives, limiting activity and performance, affecting education and jobs. These costs are more than Texas should have to bear. It is not unreasonable to expect that the federal government should protect its citizens by enacting these standards, and should not bend to political pressure or lobbying by special interests. The greatest interest should be that of the people, for whom the government works- -not the other way around.

Web Area: Carbon Pollution Standards60 From: Wease, Dennis [DWease@callawayelectric.com] Sent: Tuesday, November 05, 2013 5:09 PM To: Carbon Pollution Input Cc: Thomas, Kim; Smith, Clint; Long, Brent; Peeper, Paula Subject: We need an "All of the above, Energy Strategy"



### My name is Dennis Wease and I am an employee and member of Callaway Electric Cooperative, a not for

p rofit rural electric utility that serves the majority of Callaway County and the southern half of Montgomery County. One of my responsibilities at the cooperative is helping our members address energy usage issues which is usually due to they don’t have the money to pay their electric bill. As various jobs have left our local area there has been an increase in the number of folks that contact my office each month. I care very much about these folks, many are my friends and neighbors. Most are too proud to ask for help and it hurts to see the concern on their faces as they try to figure out how they’re going to come up with the money to pay their electric bill. I don’t have the heart to tell them about the proposed regulations your agency are considering or the impact it will have on their lives.

I sincerely hope you will take these folks into consideration when making your decision concerning regulations that will drastically increase the cost of energy.

Sincerely,



# Dennis W. Wease

Manager of Member Services
C allaway Electric Cooperative o) 573-826-2332 c) 573-220-543161 From: Mike Bohan [Mike.Bohan@rosebudmining.com] Sent: Tuesday, November 05, 2013 3:00 PM To: Carbon Pollution Input Subject: Comment: Carbon Pollution Standards for Existing Sources

Dear EPA:

O ur global economic competitors are not enacting ANY CO2 Policy and we, the free states of the U.S.A. will be economically disadvantaged. In- fact, in the not too distant past, the Australian government repealed a carbon trading / tax policy because it realized that that strategy would leave the country at a disadvantage in the global market/economy.

The cost of energy is buried in everything we buy, produce, and provide services for. To increase energy costs is to increase societies cost, decrease our living standards, and give an economic edge to those countries we compete against,
such as China.

Lets use some common sense and consider supporting the COAL INDUSTRY for a change!

Respectfully,

Michael P. Bohan Geologist Rosebud Mining Company mike.bohan@rosebudmining.com
330-429-206162 From: sidabma@gmail.com on behalf of Sid Abma [Sid@SidelSystems.com] Sent: Monday, November 04, 2013 8:35 PM To: Carbon Pollution Input Subject: Carbon Pollution Standards For Existing Power Plants



### Hi EPA
A merica is truly blessed with our abundance of natural gas, our clean fuel. What bothers me though is America's attitude for wasting energy. The EIA states that in 2012 America consumed approx. 19.5 Trillion cu.ft. of natural gas at commercial buildings and industry and at the power plants. How many of these natural gas consuming locations have a chimney poking out of their roof? What is leaving most of those chimneys? Hot exhaust. Hot wasted energy. How much of the natural gas that was combusted was wasted, vented into the atmosphere? 40% ~ 60%? That is a lot of wasted energy. At what temperatures was this hot exhaust vented out of the end of all those chimneys? Could this effect global warming?

The residential market also consumes natural gas, but they have "condensing" boilers and condensing water heaters. These appliances can/will operate at mid 90% energy efficiency, venting Cool exhaust into the atmosphere. America only has one grade of natural gas. Why are the large natural gas consumers not operating as efficiently as the residential market? Why are they not venting cool exhaust into the atmosphere? They can't say the technology is not there for them. It has been available to their locations and industries for the past 30 plus years. It is called Condensing flue gas heat recovery. Proven technology. It has no moving parts to wear out. It requires little or no electricity to operate. It requires little or no maintenance. It can/will bring these natural gas appliances to near 100% energy efficiency, showing reduced CO2 emissions and creating clean distilled Water, that is very usable.

The 3 main elements of Climate Change to be reduced are: 1) Reduce global warming 2) Reduce CO2 emissions 3) Conserve water

America, by increasing natural gas energy efficiency can accomplish all 3 of those items. Sidel Systems USA Inc. wants to work with the EPA at making this change possible. Power plants can give back to the American people much more than just electricity. They can operate in a "clean method" that will create jobs and products from the "waste" exhaust gases. This waste energy is no longer wasted energy. It is profit streams for the local communities.

I look forward to your reply.

Have a Fantastic Day!

Right-click here to download pictures. To help protect your privacy, Outlook prevented auto matic downlo ad o f this picture from the Internet.

What natural gas is not wasted today, will be there to be used another day.

Sid Abma www.SidelSystems.com (805) 462-1250
1 800 668-5003 Sidel Systems Info Download :: http://www.youtube.com/watch?v=l88zRg6rwbM

My profiles: This electronic message contains information from Sidel Systems USA Inc., which may be company sensitive, proprietary, privileged or otherwise protected from disclosure. The information is intended to be63 used solely by the recipient (s) named above. If you are not an intended recipient, be aware that any review, disclosure, copying, distribution or use of this transmission or its contents is prohibited.

Get a sig natu re like this. C LICK HERE.64 From: Lewis, Brad [BLewis@westmoreland.com] Sent: Friday, November 01, 2013 6:16 PM To: Carbon Pollution Input Subject: Carbon Pollution Standards For Existing Power Plants



## My name is Bradley Charles Lewis. I am the President of Westmoreland Energy

Ser vices, Inc., the President of Friends of Coal West, a registered professional mining engineer and have been working in the global coal mining market for the past 24 years (i.e., 14 countries). My comments today being presented on behalf of Friends of Coal West and also include my personal concern regarding America’s declining competitiveness in the global market place.

One of America’s longstanding and foremost competitive advantages in the global
market is our low cost and reliable supply of electricity. Coal fired - base load power plants (approximately 50% of our generation) have been the foundation for America’s industrial revolution and our global competitiveness. Emerging economies are mimicking this blueprint for success and rightly so.

Energy is the business that fuels all other businesses. As such, the domino effect of rising electricity rates is increased costs in all aspects of our life.

Carbon Dioxide is made up of carbon and oxygen – both of which are valuable products. These products need to be recycled. The cost of recycling is less than the cost of sequestering and the chances of success are higher.

Relative to energy, the world needs everything, everywhere, all the time. Both the coal and utility industries welcome the alternative energy sources provided that we all compete on a level playing field. Free market competition and investment tax credits (not subsidies) have the proven track record of getting viable/consistent results in the shortest period of time. The private sector should be responsible for achieving the predetermined level of emission reductions.

Killing coal fired generation is a cop out and an economic disaster. A panel of industry and bipartisan government experts should be tasked with prioritizing the environmental concerns, defining incremental reduction levels along with65 

## reasonable time frames. Given the capital intensive nature and complexity of the utility industry, the time horizon for reductions should be approximately 10 - 20

years.

This panel’s vision should be “Flourishing Coal Fired Generation - Energizing the Technological Revolution.”

Relative to measuring performance, two long time axioms are applicable:

Simplicity promotes effectiveness

What gets measured – gets done

EPA can play a vital role in shaping the future for a brighter America by being the quarterback that brings together the best of the best and defines success. With the boundaries and goal posts defined; entrepreneurs can plan, invest, compete
and build on their successes.

America has everything it needs to be energy independent. We must realize this goal and regain our global prominence. Affordable, abundant and reliable fossil fuels are the source of energy which has and will result in longer, healthier, more prosperous and more comfortable lives.

As far back as Biblical times, we have been called upon to be good stewards of the resources with which we are blessed. Utilizing fossil fuels to make a better world is rising to our calling.

Thank you for spearheading these listening sessions across America and for the opportunity to speak.

God Bless America

Brad66 

## Safety is Everyone's Job - All the Time

Bradley Charles Lewis P.E. P resident

Westmoreland Energy Services, Inc. 9540 South Maroon Circle Suite 200 Englewood, Colorado 80112-5730

Mobile: 412 - 369 - 7233

Office: 720 - 354 - 4531

Fax: 720 - 354 - 4564

blewis@westmoreland.com

http://www.westmoreland.com67 From: Jimmy Evans [jevans@ibewlocal816.org] Sent: Friday, November 01, 2013 5:43 PM To: Carbon Pollution Input Subject: Reducing Carbon Pollution

Jimmy Evans

I BEW Local Union 816

Paducah, KY Nov. 1, 2013

I am writing on behalf of IBEW local Union 816. We represent approximately 1200 jobs in far western Kentucky.

There is no more important regulation in EPA's pipeline than this one. EPA's guidelines for existing source greenhouse gas controls for power plants are scheduled to be proposed in June 2014. The welfare of our families - and the communities supported by our jobs, and the tax base for local schools and other vital services created by existing power plants - are all at stake.

• We already are experiencing job losses due to the shutdowns of coal plants in response to EPA's new mercury rule and the lower price of natural gas. It is widely recognized that 50,000 megawatts of coal capacity - or more - will be shut down. This will represent the largest job loss in the history of the Clean Air Act.

• In addition to the loss of jobs, we are concerned that with the loss of generation that the stability and reliability of the electric grid will be compromised.

• Unions involved in the coal supply and transportation, maintenance, and operation of coal plants will lose thousands of high-skilled jobs. These plants have already spent millions of dollars to comply with MATS and are the same plants being targeted by the proposed existing source rule. The additional expenditures required to comply with the existing source rule will force these plants to close.

 States have a lot of discretion in the existing source program, and we cannot support arbitrary CO2 emission rate guidelines that would force additional plant closures and job losses.

• We believe it is essential that EPA's existing source guidelines provide for states to avoid the loss of jobs atplants that have invested in controls to meet the new mercury rules. The way to do that is to provide for unitspecific assessments of efficiency improvements and similar initiatives that can reduce emissions.

• Section 111(d) of the Clean Air Act calls for this kind of "inside the fence" assessment, by the states, of what amounts of CO2 can reduced at existing plants. It specifically allows states to take into account the remaining
useful life of the source.

• We encourage EPA to provide guidelines that will support reasonable measures to increase energy efficiency at coal generation plants. However, we cannot accept arbitrary and unachievable emission reduction goals that would bring on another round of plant closures. We seriously doubt that electric reliability could be maintained
under these circumstances.

• The U.S. coal-based electric generation system has over 300,000 megawatts of capacity, and represents 3% of global greenhouse gas emissions. Since 2005, CO2 emissions from the coal fleet have declined by 23%, in excess of President Obama's 17% reduction target for 2020. In short, we already have done our fair share.

Thank you.

Jimmy Evans, Business Manager
I.B.E.W. Local Union 816
4515 Clarks River Rd. Paducah, KY 4200368 270-898-2456

270-898-2694 Fax jevans@ibewlocal816.org



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http://www.eset.com69 From: Jimmy Evans [jevans@ibewlocal816.org] Sent: Friday, November 01, 2013 5:35 PM To: Carbon Pollution Input Subject: Reducing Carbon Pollution

Paducah, KY

N ov. 1, 2013

Jimmy Evans
IBEW Local Union 816

I’m writing this on behalf of IBEW Local Union 816 we represent approximately 1200 jobs in western Kentucky. The future of our union's jobs and the welfare of our families and communities will be vitally impacted by EPA's decisions on the guidelines for existing source greenhouse gas controls for power plants scheduled to be proposed in June 2014.

• Many unions are experiencing unprecedented job losses due to the shutdowns of coal plants that are occurring in response to EPA's mercury rule and lower natural gas prices. The U.S. Department of Energy projects that more than 50,000 megawatts of coal capacity will be shut down over the next few years. Most of these closures will occur at older and smaller coal plants that are not economically feasible to be retrofitted with scrubbers and other controls needed to meet the new mercury standards.

• These job losses will accelerate in 2015 and 2016 when the mercury rule takes effect. These plants have already spent millions of dollars to comply with MATS and are the same plants being targeted by the proposed existing source rule. The additional expenditures required to comply with the existing source rule will force these plants
to close.

• We, along with other unions involved in the maintenance, fuel supply, and operation of coal plants, will lose tens of thousands of high-paying, high-skilled jobs.

• In addition to the loss of jobs, we are concerned that with the loss of generation will affect the stability and reliability of the electric grid.

• The loss of generation has the potential to increase electric rates which will be incurred by all consumers.

• Our primary concern about EPA's existing source "guidelines" for CO2 reductions is finding ways to avoid the loss of jobs at plants that have just invested billions in retrofit controls.

• We know that states are supposed to have a lot of discretion in this program, and we do not want to see arbitrary CO2 emission rate targets imposed on states that would force a lot of additional plant closures and job losses. Some environmental groups are urging you to set such targets, which we strongly oppose.

• We believe that the Clean Air Act calls for plant-by-plant assessments, by the states, of what amounts of CO2 can reasonably be reduced at existing plants, such as by efficiency improvements.

• We also must note that CO2 emissions from coal plants are down 23% from 2005 levels, and will be further reduced as more plants are shut down. U.S. coal generation is only 4% of global energy-related CO2 emissions, so even major reductions would not have any meaningful future impact on global climate. India, China and other developing countries are the principal sources of future greenhouse gas emissions growth, and these countries have not agreed to any legally binding limits on their emissions growth. U.S. emissions are declining and are on track to meet the President's target of a 17% reduction from 2005 levels by 2020.

• We are not putting our heads in the sand here. We will support reasonable measures to increase energy efficiency at coal generation plants, reducing their CO2 emissions. However, we cannot support arbitrary targets that would force a new wave of plant closures and job losses.

We will appreciate the agency's consideration of our views.70 Jimmy Evans, Business Manager
I.B.E.W. Local Union 816
4515 Clarks River Rd. Paducah, KY 42003

270-898-2456

270-898-2694 Fax jevans@ibewlocal816.org



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http://www.eset.com71 From: Johnson, Dee Ann [DAJohnson@peabodyenergy.com] Sent: Friday, November 01, 2013 4:52 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website

I live in the beautiful state of Indiana and am proud to be an American. Please take into consideration the following

c omments when formulating regulations of greenhouse gasses.

-Carbon emissions from coal-fired power plants only represent 3% of global greenhouse gas emissions. -Coal generates over 80% of Indiana’s electricity and any rules that restrict power production from coal will hurt mining jobs and raise our cost of electricity. -Indiana has over 200 years of coal reserves, and we should be striving for energy independence and use this resource instead of encouraging a switch to other fuel sources. -Flexibility to choose coal, natural gas, wind power, solar, nuclear, or other means to generate electricity should be left to the states and be flexible enough to fit all states and their diverse resources. -Indiana and the nation’s economy cannot withstand any new regulatory costs for business or individual taxpayers. -If EPA develops rules that takes coal out of our energy mix, all Hoosiers will have to pay for investments that utilities have made to comply with all existing emission rules and also pay for new gas fired electric plants.

Thank you for your consideration.



### Dee Ann Johnson Business Unit Controller Peabody Midwest
P hone: (812) 434-8534 Fax: (812) 437-6711



### E-mail Disclaimer: The information contained in this e-mail, and in any accompanying documents, may constitute confidential and/or legally privileged information. The information is intended only for use by the designated recipient. If you are not the intended recipient (or responsible for the delivery of the message to the intended recipient), you are hereby notified that any dissemination, distribution, copying, or other use of, or taking of any action in reliance on this e-mail is strictly prohibited. If you have received this email communication in error, please notify the sender immediately and delete the message from your system.72 From: Parker, James M [jmparker@pplweb.com] Sent: Friday, November 01, 2013 3:42 PM To: Carbon Pollution Input Cc: Daly, Carl; Dew, Wendy Subject: FW: EPA's October 30th listening Session on Climate Change Regulations for Existing Plants

For your convenience listed below is the written version of comments presented verbally at EPA’s October 30,
2 013 Listening Session in Denver, CO.

Thanks again for the opportunity to comment!

James M Parker, PE Mgr ECS PPL Montana, LLC 303 N Broadway, Ste 400 Billings, MT 59101

406 237-6932

************************* 

### Good Afternoon. I am Jim Parker, Manager, Environmental Compliance Services, PPL Montana. We h ave ownership interests in and operate the Colstrip and Corette coal fired electric generating units in Montana. PPL Montana is part of PPL Energy Supply, which owns and operates coal fired EGUs in Kentucky and Pennsylvania, as well as Montana.

PPL has a pragmatic view of environmental regulation. The company does not oppose reasonable regulation that establishes achievable targets based on proven and commercial available technologies, acknowledges and mitigates effects on electricity prices and reliability, and maintains the diversity of fuels used to generate electricity.

For the upcoming proposed carbon regulation for existing EGUs, we believe EPA should formulate their regulation to incorporate the following essential characteristics

1. Government policy should embrace an “all of the above” approach to generation fuel sources to ensure long-term reliability of electricity supply that is essential to the U.S. economy at a price that does not harm electricity customers or disadvantage U.S. business in global markets. Removing coal as an option would drive the industry to depend primarily on natural gas for future baseload generation needs. Over-dependence on any fuel source is risky policy that could have serious consequences for electricity prices and reliability.

2. Technology to remove carbon dioxide from power plant emissions is a long way from being ready for broad use on a commercial scale, and should not be considered a viable option for meeting near-term reduction goals at existing EGUs..Technology to capture carbon dioxide from power plant emissions has been tested on only a very s mall scale. Storing carbon dioxide underground is not geologically feasible in much of the United States. Storing carbon dioxide

u nderground has many unresolved legal issues.

3. EPA regulations should establish broad general guidelines and allow states the flexibility to develop compliance strategies consistent with those guidelines based on their natural73



### resources, geography, existing generation fuel mix and established energy efficiency and conservation programs. States should be allowed to credit early CO2 reductions by EGUs

4. Environmental regulations also have economic impacts. Federal policies must address the near-term economic impacts of restricting carbon dioxide emissions.

5. We join with other commenters and urge EPA to hold further Listening Sessions cl oser to states heavily dependent on coal, such as Montana and North Dakota.



### I would like to thank EPA for the opportunity to give input on this very significant rulemaking. Your consideration of these comments will result in a reasonable and workable set of rules for existing
EGUs.

From: Parker, James M
Sent: Thursday, October 24, 2013 10:50 AM
To: Khanwalkar, Arundhati; Simonich, Pete J; Dennehy, Neil J; Olson, Tommy Marvin; Criswell, Gordon D; Christian, Stephen J Cc: Murphy, Megan A; Lewis, George C; Hoffman, M David; Kinnard, David B Subject: EPA's October 30th listening Session on Climate Change Regulations for Existing Plants 

### Government policy should embrace an “all of the above” approach to generation fuel sources to ensure long-term reliability of electricity supply that is essential to the U.S. economy at a price that does not harm electricity customers or disadvantage U.S. business in global markets.

Removing coal as an option, as the proposed regulation for new power plants does, woulddrive the industry to depend primarily on natural gas for future baseload generation needs. Overdependence on any fuel source is risky policy that could have serious consequences for electricity prices and reliability.

Based upon conversations with PPLM Management, Tinku, Meghan, and George Lewis, we are pursuing attending and giving comments to EPA at their October 30 th Listening Session in Denver. The current plan is for me to attend and deliver those comments.

Our reasoning is to reflect engagement in the regulation setting process, demonstrate allegiance with other stakeholders such as our plant workers and others, and reinforce some basic points about the general framework of a program to EPA. Our goal is to give input without in any way limiting our future flexibility in development of our position on these regulations.

With that in mind the points we intend to bring up generally will center on the following:



### 1. EPA should give states maximum flexibility to implement rules that are suitable for the particular region74



### 2. EPA guidelines need to reflect the current state of technology – i.e. – carbon capture and sequestration is not a suitable technology for existing plants 

### 3. EPA guidelines should allow states to credit early CO2 reductions by plants

These points are stated in more detail on the attached document, vetted and approved by E&EPC.

Please let me know if you have any questions or comments. Please feel free to pass this email on to anyone whom you feel should review and give input.

Thanks!

Jim



### The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately, and delete the original message.75 From: drupal_admin@epa.gov on behalf of Travis Deti [tdeti@vcn.com] Sent: Friday, November 01, 2013 1:08 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Fri, 11/01/2013 - 13:07
S ubmitted values are:

Name: Travis Deti Email: tdeti@vcn.com
Comments: Comments of the Wyoming Mining Association Environmental Protection Agency Listening Session On Proposed Carbon Dioxide Rules for Existing Coal-Fired Power Plants Denver, Colorado October 30, 2013

My name is Travis Deti, and I am the Assistant Director of the Wyoming Mining Association. The Wyoming Mining Association is a statewide trade organization that represents and advocates for 39 mining company members producing bentonite, coal, trona and uranium, as well as one company developing rare earth minerals. WMA also represents 129 associate member companies, two railroads and 180 individual members.

Wyoming leads the nation in coal production, mining over 400 million tons of annually. In addition, Wyoming is the single largest net producer of energy for the nation. While Texas produces slightly more energy than Wyoming, it consumes more than its production. Wyoming exports almost 10 trillion BTU’s per year to the rest of the nation for use in power plants, automobiles, homes and factories. Most of that energy is from coal.

Recently President Obama announced stringent Environmental Protection Agency (EPA) emission standards on new coal-fired power plants. The proposal will require new coal plants to limit emissions to 1,100 pounds of carbon dioxide per megawatt hour, about 700 pounds less than most modern day units. To achieve this standard, utilities will be required to implement costly and largely unproven carbon capture technology – technology that is simply not yet viable.

In effect, the EPA, at the President’s direction, has placed a de facto ban on the
construction of new coal- fired plants. It has essentially eliminated coal as a future source of electricity for our nation. The implications of this are enormous. Coal currently accounts for nearly 40 percent of America’s electricity generation, and the question of what will make up the megawatt difference once existing plants are retired has largely gone unanswered. But aside from this problematic scenario, there will be real and tangible effects for every citizen. If the agency’s decision on future plants is an indicator of future action, WMA has serious concerns. This continued uncompromising effort to end coal as a viable energy source for America has very real consequences for real people in Wyoming and around the country.

In Wyoming, real people rely on extraction industries to fund our state and local governments. Revenues from coal mining alone account for over $1 billion annually in taxes, royalties, fees and Abandon Mine Lands funds. This keeps the tax burden for Wyoming citizens low. Among other things, these revenues fund schools, the University of Wyoming and community colleges, highways, and cities and towns. Monies derived from coal are a key reason as to why Wyoming people are not burdened with a
state income tax.76 In the past two decades bonus bids paid to the state by coal companies on federal coal lease sales, over $2.6 billion since 1992, have built new schools in every county in Wyoming. Regretfully, the uncertainty caused by EPA’s regulatory regimen contributed to the collapse of the two most recent lease sales, costing Wyoming millions. The federal government also lost out, as those bonus bids as shared equally.

WMA estimates that every coal mining job supports three more jobs around the state in the form of service and supply employment. If we continue on EPA’s current regulatory path, the coal industry and our economy will necessarily contract due to restrictions placed on utilities and the choking off of export opportunities. The elimination of the industry’s customers and markets will cause job losses here at home. Real people will be hurt.

Finally, Americans everywhere will feel the crunch of rising electricity costs. Coal is America’s most abundant, reliable and affordable energy source. Yet, the choice has been made to deliberately put it off limits, playing favorites for costly, heavily subsidized and unreliable resources to blindly advance the president’s environmental program. Utilities will face issues from over-reliance on natural gas and the innate inability and undependability of renewables meet generation needs, while passing along the cost at the expense of consumers.

Again, here lies the real crux of the matter: the elimination of coal as a source of electricity generation through oppressive regulation hurts real people in the form of job losses, higher utility bills and a lower standard of living for little to no benefit to public health, reduction in global emissions, or lowering of perceived global temperature
hikes. This is a lose-lose situation for America.

The facts speak for themselves, but are often lost in the gamesmanship that accompanies the implementation of political agendas. According to the EPA’s own data, coal based power generation in the United States has increased 170 percent since 1970, while emissions of the pollutants originally regulated under the Clean Air Act have decreased over 85 percent. This remarkable success has been achieved by common sense regulation and timely advances in technology. There is every reason to expect this trend will continue in respect to carbon
dioxide.

State-of-the-art coal-burning plants in Illinois and Arkansas are proof today that coal can continue to be used more cleanly and efficiently than ever before. The technology will continue to improve, viable carbon capture and storage will come online in time, and performance of current and future plants will become even better. But not under arbitrary, costly and unattainable standards and timelines.

WMA appreciates the opportunity to be here to comment today, and we respectfully urge the agency to fully consider the real impact of its actions on the American consumer and taxpayer, jobs and affordable energy in developing CO2 emissions rules for the existing coal fire fleet. WMA would also urge the EPA to consider holding additional listening sessions in rural America and coal producing states.

Web Area: Carbon Pollution Standards77 From: albertine harris [rash360@yahoo.com] Sent: Friday, November 01, 2013 12:08 PM To: Carbon Pollution Input Subject: Fw: demonstrations for New Products and a Green Industry

On Thursday, October 31, 2013 10:18 AM, "Johnson, Dianna" <Dianna.Johnson@mail.house.gov> wrote: Good Morning Ms. Harris,

In our phone conversation you stated you lived in the 7 th District. However, I will need address, preferred dates, location and contact number to complete request.

Thanking you in advance! Congresswoman Office Alabama

From: albertine harris [mailto:rash360@yahoo.com] Sent: Wednesday, October 23, 2013 2:50 PM To: Johnson, Dianna; lawyers@flaginc.org; selleman@comcast.net; jlass@nrdc.org; tradmard@edpa.org; mark.mchenry@kcmo.org; acheltnut@aol.com; fsc@mindspring.com; heathergray@federation.civil Subject: demonstrations for New Products and a Green Industry

I am a Consultant in the city of Alabama communicating with landowners and farmers interested in AGDOs' new green products and inventions. Contractors, landowners and farmers to invest in Land and sea project with Arab German Development Organization can become a member cooperate plans for a new green industry . Nonprofits can schedule a webcam meeting with Advanced Sword and promote clean air, food, technology and research.

Youth that promote Animal Welfare, Human Health and Intelligence can participate by visiting the link to AGDO (Arab German Development Organization). Our next demonstrations for global peace, green production and environmental programs for education in politics and awareness to health, environmental issues and election choices is organized by Chemiewende. By 2014, jobs and new products: fertilizers, dyes, plastics and medicines integrate for new technology and military involvement. @AGDA2050 is on facebook, twitter and linkedin, breakingbarriersdiscussions.blogspot.comchemiewende.eventbrite.com skype Captain energy see the petitions by Albertine Harris

P.S. I would like to speak at an event to be held in Alabamas' Black Belt to Florida78 From: Kost, Jay H [Jay.Kost@nacoal.com] Sent: Friday, November 01, 2013 10:13 AM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website



## Environmental Protection Agency Personnel,

T his is to comment on any carbon dioxide limits you are contemplating for existing power plants that are fueled by coal. I am one of a group of North Dakotans, many who grew up on farms and ranches, that now are responsible for operating the mines that provide coal to local power plants supplying electricity to the upper Midwest. Our heritage is one of taking care of the environment, in fact reclamation at the mines in North Dakota is world class having received many national awards. We understand the desire to reduce pollution and be responsible stewards of our natural resources. However, there is a distinction between pollutants (such as sulfur and mercury) as opposed to the colorless, odorless and tasteless gas of carbon dioxide which is formed naturally by processes such as breathing and burning fossil
fuels.

Your agency says the debate about carbon dioxide resulting from human activity and its impact on the environment is over. You also say that coal fired power plants emit the most CO2 so they must be regulated. This is in our opinion a very short sited view, especially of history. If you came to North Dakota, you would find at our coal mine at least 4 different coal seams that were formed over time. If you don’t subscribe to the idea that God created the earth in 6 days then you probably believe that these coal seams were formed by a process where plant life that existed in a swamp like atmosphere was covered and compressed. With an average low temperature of approximately 0 degrees Fahrenheit in January, our state will have to increase in temperature at least 35 to 40 degrees to sustain this type of vegetation. That type of climate would have had to exist at least 4 times to allow the formation of these coal seams. Please have a discussion about the long term world cyclical temperature variations and address those in any rules you might propose on carbon capture or regulation.

The power plants we serve are among the cleanest in the world. I agree with having old plants add scrubbing capacity to take care of sulfur and mercury but to add carbon sequestration to existing power plants makes no environmental or economic sense. Please consider that these are base load plants and that the electricity they produce is “necessary” to power homes and businesses. “Necessary” as opposed to “elective” activities that we undertake every day. To fuel the economic recovery of our country, businesses, manufacturing and critical needs like heating our homes should have the lowest electric rates possible as long as we’re producing clean energy, which we are. These plants provide that electricity very efficiently, safely and they are good stewards of the environment.79 

## One last bit of feedback for your agency. We are frustrated because although you take comments, you just don’t seem to listen. During the last round of comments for carbon standards on new power plants, the final rules had virtually no significant changes compared to the what you originally proposed as they related to coal. And we know, there were millions of comments generated. You don’t seem to care about lost jobs, increased electric rates, the financial well-being of our country, the fact that we are running clean plants – you just don’t seem to care. Your agency seems to be stuck on the idea that unless we reduce carbon dioxide out of these plants that nothing is good. Please quit taking this “my way or the highway” viewpoint and listen to what the people are telling you. We need to get this country back on its feet with low cost electricity and take a common sense approach to pollution and carbon dioxide reduction. Real jobs are on the line here.

Thank you for accepting these comments.

Respectfully, Jay Kost The Falkirk Mining Company Underwood, North Dakota

NOTICE: This message may contain privileged and confidential information which is protected from disclosure. If you are not the addressee indicated in this communication (or an agent or employee responsible for delivering this communication to such person), you may not read, copy, use or disseminate this message to any other person. In such case, you should destroy this communication and kindly notify the sender immediately by reply email or telephone. Please advise the sender immediately if you or your employer do not consent to Internet email for messages of this kind. This communication is restricted to the intended recipient and is not to be provided to a third party without the prior consent of The North American Coal Corporation or its representatives.80 From: Eckroth, Jeremy J [Jeremy.Eckroth@nacoal.com] Sent: Tuesday, October 29, 2013 4:53 PM To: Carbon Pollution Input Subject: Contact Us Comment: Carbon Pollution Standards Website



## Dear Environmental Protection Agency,

I am submitting comments on the EPA’s proposed regulation of existing coal-fired power plants. America’s most abundant fuel source, coal, provides dependable and affordable power. I believe that new federal regulations should not be used to shut down or restrict low-cost and dependable coal-fired power generation. Also, the EPA should not impose rules that raise the cost of electricity. Any regulations that raise the price of electricity will adversely impact the American people. It will particularly hit the poor the hardest. Also, regulations restricting coal use or forcing power plants to switch fuels will raise demand for other fuels, thus raising their costs unnecessarily.

Restricting or eliminating America’s use of coal will cost jobs and hurt our economy, just as it is struggling to get back on its feet. It will negatively impact my job also. I am proud to work at a coal mine and provide a dependable low cost energy source for many Americans. Coal mining and coal-fired power provides thousands of secondary jobs as well, and billions of dollars of taxes nationwide to support our schools, highways, police and other essential services

It is unfair for Americans to bear the brunt of unnecessary greenhouse gas restrictions without similar requirements for countries such as China, which today is the number one emitter of CO 2 

## . Without similar restrictions on all countries, including China, CO 2 

## reductions from the US

w ill be insignificant and not result in an overall worldwide decrease in CO 2 

## . I must also state

t hat I do not believe that global warming is human caused. The world has gone through many heating and cooling cycles throughout history.

I also request that the EPA conduct more listening sessions where people impacted by the proposed rule actually live – there are no coal miners in Seattle, San Francisco, Boston or New York City.

Respectfully,

Jeremy Eckroth
Environmental Specialist

Th e Falkirk Mining Company

N OTICE: This message may contain privileged and confidential information which is protected from disclosure. If you are not the addressee indicated in this communication (or an agent or employee responsible for delivering this communication to such person), you may not read, copy, use or disseminate this message to81 

### any other person. In such case, you should destroy this communication and kindly notify the sender immediately by reply email or telephone. Please advise the sender immediately if you or your employer do not consent to Internet email for messages of this kind. This communication is restricted to the intended recipient and is not to be provided to a third party without the prior consent of The North American Coal Corporation or its representatives.82 From: drupal_admin@epa.gov on behalf of Jeffery Stinnett [jeff2337@airmail.net] Sent: Tuesday, October 29, 2013 11:55 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Tue, 10/29/2013 - 11:55
S ubmitted values are:

Name: Jeffery Stinnett Email: jeff2337@airmail.net
Comments: (Tatum,Texas) (October 29, 2013)

(Jeffery Stinnett) International Brotherhood of Electrical Workers Good morning, I am Jeffery Stinnett and I am
here on behalf of IBEW Local 2337 We represent approximately 1500 jobs in Texas. The future of our union's jobs and the welfare of our families and communities will be vitally impacted by EPA's decisions on the guidelines for existing source greenhouse gas controls for power plants scheduled to be proposed in June 2014.

• Many unions are experiencing unprecedented job losses due to the shutdowns of coal plants that are occurring in response to EPA's mercury rule and lower natural gas prices. The U.S. Department of Energy projects that more than 50,000 megawatts of coal capacity will be shut down over the next few years. Most of these closures will occur at older and smaller coal plants that are not economically feasible to be retrofitted with scrubbers and other controls needed to meet the new mercury standards. • These job losses will accelerate in 2015 and 2016 when the mercury rule takes effect. These plants have already spent millions of dollars to comply with MATS and are the same plants being targeted by the proposed existing source rule. The additional expenditures required to comply with the existing source rule will force these plants to
close. • We, along with other unions involved in the maintenance, fuel supply, and operation of coal plants, will lose tens of thousands of high-paying, high-skilled jobs. • In addition to the loss of jobs, we are concerned that with the loss of generation will affect the stability and reliability of the electric grid. • The loss of generation has the potential to increase electric rates which will be incurred by all consumers. • Our primary concern about EPA's existing source "guidelines" for CO2 reductions is finding ways to avoid the loss of jobs at plants that have just invested
billions in retrofit controls. • We know that states are supposed to have a lot of discretion in this program, and we do not want to see arbitrary CO2 emission rate targ ets imposed on states that would force a lot of additional plant closures and job losses. Some environmental groups are urging you to set such targets, which we strongly oppose. • We believe that the Clean Air Act calls for plant-by-plant assessments, by the states, of what amounts of CO2 can reasonably be reduced at existing plants, such as by efficiency improvements. • We also must note that CO2 emissions from coal plants are down 23% from 2005 levels, and will be further reduced as more plants are shut down. U.S. coal generation is only 4% of global energy-related CO2 emissions, so even major reductions would not have any meaningful future impact on global climate. India, China and other83 developing countries are the principal sources of future greenhous e gas emissions growth, and these countries have not agreed to any legally binding limits on their emissions growth. U.S. emissions are declining and are on track to meet the President's target of a 17% reduction from 2005 levels by 2020. • We are not putting our heads in the sand here. We will support reasonable measures to increase energy efficiency at coal generation plants, reducing their CO2 emissions. However, we cannot support arbitrary targets that would force a new wave of plant closures and job losses.

We will appreciate the agency's consideration of our views.

Web Area: Carbon Pollution Standards84 From: drupal_admin@epa.gov on behalf of Randall Pierce [ibew2337@airmail.net] Sent: Tuesday, October 29, 2013 11:33 AM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Tue, 10/29/2013 - 11:33
S ubmitted values are:

Name: Randall Pierce
Email: ibew2337@airmail.net
Comments: (Tatum, Texas) (October 29, 2013)

(Randall Pierce) (International Brotherhood of Electrical Workers)

Good morning, I am Randall Pierce and I am here on behalf of IBEW Local 2337. We represent approximately (1500) jobs in Texas. The future of our union's jobs and the welfare of our families and communities will be vitally impacted by EPA's decisions on the guidelines for existing source greenhouse gas controls for power plants scheduled to be proposed in June 2014.

• Many unions are experiencing unprecedented job losses due to the shutdowns of coal plants that are occurring in response to EPA's mercury rule and lower natural gas prices. The U.S. Department of Energy projects that m ore than 50,000 megawatts of coal capacity will be shut down over the next few years. Most of these closures will occur at older and smaller coal plants that are not economically feasible to be retrofitted with scrubbers and other controls needed to meet the new mercury standards. • These job losses will accelerate in 2015 and 2016 when the mercury rule takes effect. These plants have already spent millions of dollars to comply with MATS and are the same plants being targeted by the proposed existing source rule. The additional expenditures required to comply with the existing source rule will force these plants to
close. • We, along with other unions involved in the maintenance, fuel supply, and operation of coal plants, will lose tens of thousands of high-paying, high-skilled jobs. • In addition to the loss of jobs, we are concerned that with the loss of generation will affect the stability and reliability of the electric grid. • The loss of generation has the potential to increase electric rates which will be incurred by all consumers. • Our primary concern about EPA's existing source "guidelines" for CO2 reductions is finding ways to avoid the loss of jobs at plants that have just invested
billions in retrofit controls. • We know that states are supposed to have a lot of discretion in this program, and we do not want to see arbitrary CO2 emission rate targets imposed on states that would force a lot of additional plant closures and job losses. Some environmental groups are urging you to set such targets, which we strongly oppose. • We believe that the Clean Air Act calls for plant-by-plant assessments, by the states, of what amounts of CO2 can reasonably be reduced at existing plants, such as by efficiency improvements. • We also must note that CO2 emissions from coal plants are down 23% from 2005 levels, and will be further reduced as more plants are shut down. U.S. coal generation is only 4% of global energy-related CO2 emissions, so even major reductions would not have any meaningful future impact on global climate. India, China and other85 developing countries are the principal sources of future greenhouse gas emissions growth, and these countries have not agreed to any legally binding limits on their emissions growth. U.S. emissions are declining and are on track to meet the President's target of a 17% reduction from 2005 levels by 2020. • We are not putting our heads in the sand here. We will support reasonable measures to increase energy efficiency at coal generation plants, reducing their CO2 emissions. However, we cannot support arbitrary targets that would force a new wave of plant closures and job losses.

We will appreciate the agency's consideration of our views.

Web Area: Carbon Pollution Standards86 From: drupal_admin@epa.gov on behalf of Richard H. Oates Jr. [rhoates@wyomingcat.com] Sent: Monday, October 28, 2013 6:09 PM To: Carbon Pollution Input Subject: Webform Comment: Carbon Pollution Standards Website

Submitted on Mon, 10/28/2013 - 18:09
S ubmitted values are:

Name: Richard H. Oates Jr.
Email: rhoates@wyomingcat.com
Comments: Docket ID: EPA-HQ-OAR-2013-0495 Good Morning. I am Richard H. Oates Jr., Vice President of Mining for Wyoming Machinery Company. We are the authorized Caterpillar Dealer for 16 counties in the Great State of Wyoming. We have been in business since 1969, or 44 years and I have been employed by the company for 31 of those. Today, we employ 760 employees working from 5 locations. Coal producing customers are a significant part of our business opportunity and generate over half of our revenue.

Wyoming Coal provides a secure and affordable source for electric power generation. Currently, about 40% (over 400 Million tons) of America’s coal comes from Wyoming, with Wyoming coal going to 34 states. Wyoming coal meets the EPA standard of 1.2 pounds of sulfur dioxide per million BTUs. Wyoming has a 42 billion ton reserve of recoverable coal or over 100 years of production remaining based upon current production. Subject to future advances in mining technics, to control cost, there is another 200 years of coal that may be produced someday. We’re talking about 1.4 trillion tons or 300 potential years of low cost electric power generation resource.

For example, after years of planning and permitting, the Dry Fork Station Coal plant, located 7 miles north of Gillette, WY, was dedicated in August of 2011 incorporating state-of-the-art environmental technology. This plant produces maximum net generation of 385 MW by burning about 3.5 million tons of coal annually. One megawatt of capacity is generally considered to be sufficient electric power for 800 homes, so the Dry Fork Station’s output will provide enough electricity for 308,000 hom es. Therefore Wyoming’s production of 400 Million tons of coal theoretically could power 38.5 million homes.

Wyoming Machinery Company sells Caterpillar Equipment which provides the lowest cost per ton of Coal production or our customers won’t purchase the equipment from us. Our business depends upon our customers’ ability to continue to produce and sell Coal for a profit. Our customers customers must then produce power that meets the Americas energy demand. Coal is an abundant resource, that we have right here in the United States and it produces low cost electricity today and will in the future.

If the EPA creates regulations which require compliance that is not technically possible to meet or economically feasible the results to our Wyoming economy would be catastrophic. In turn the nation would experience a large price increase for electric power which could make things far worse than they are today. We contend Coal continues to provide a low cost energy solution and complement those Power Plants that burn Wyoming Coal. Our customers and Caterpillar have invested heavily in protecting the environment and we are confident that they will continue to do everything they are capable of to continue down that path.

Please, don’t create rules and regulations that are unattainable as the results will eliminate jobs and increase energy costs for everyone.87 Web Area: Carbon Pollution Standards