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 

behind 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 

technologically achievable.

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

geographical 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 

individuals 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 

harness the benefits of coal based electricity in an environmentally sound manner. The EPA should hold at 

least one listening session in North Dakota. 

Sincerely,

Michael T. Anderson

Safety & Compliance Manager 

Office: (307) 687-0776 

Mobile: (307) 660-4526 

 

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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, 

Affordable 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. 

My 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 

generation 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. 

Adopting 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 

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, 

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)
4
5

From: Scott For Colorado [scottforcolorado@gmail.com]

Sent: Wednesday, October 30, 2013 12:45 PM

To: Carbon Pollution Input

Subject: Regulations 

Coal 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.com

 
6

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 

power 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 

Dear 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. 

Assistant 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

NOTICE: The information contained in this e-mail message (including any attachments) is intended only for the personal 

and confidential use of the recipient(s) named above. The information in and attached to this message may constitute 

an attorney-client communication and may contain information that is PRIVILEGED and CONFIDENTIAL and/or 

ATTORNEY WORK PRODUCT. As such - it is privileged and confidential. If you are not an 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 message in error, please do not read, copy or 

forward this message. Please permanently delete all copies and any attachments and notify the sender immediately by 

sending an e-mail to hsmith@naruc.org

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8

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which may be a computer program. This attached computer program could 

contain a computer virus which could cause harm to EPA's computers, 

network, and data. The attachment has been deleted. 

This was done to limit the distribution of computer viruses introduced 

into the EPA network. EPA is deleting all computer program attachments 

sent from the Internet into the agency via Email. 

If the message sender is known and the attachment was legitimate, you 

should contact the sender and request that they rename the file name 

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For further information, please contact the EPA Call Center at 

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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 

Submitted 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. Environmental 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 establishing “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 for 

consideration 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 an 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 

Modifications, 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 Standards 
11

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 

Submitted 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 come 

that 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 applaud 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 Standards 
13

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 

Submitted 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 Standards 
14

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 10th Amendment 

requires 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 Residents 
15

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 

emission 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 and 

entities 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 demonstrated (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 depend 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 efficiency 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 standards 

would 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 

501.570.2420 
21

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

To 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 Bzdawka 
22

Business Manager 

IBEW Local #494 

3303 South 103rd Street 

Milwaukee, WI 53227-4108 

(414) 327-5202 Ext. 227 

E-mail: johnb@ibew494.com 
23

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 

pollution. 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 ProtectTools
24

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 

Submitted 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 system. 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 Standards 
26

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 

transmission 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

Citizens 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 

 

Right-click 

here to 

download 

pictures. To 

help protect 

your privacy, 

Outlo ok 

prevented 

auto matic 

download of 

this picture 

from the 

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 

unauthorized. 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 

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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 

Submitted 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 account 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 Standards 
29

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 

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 multipurpose 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 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 expected 
32

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 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 Arizona 
33

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 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 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. 

Right-click 

here to 

download 

pictures. To 

help protect 

your privacy, 

Outlo ok 

prevented 

auto matic 

download of 

this picture 

from the 

Internet.

Central Arizona Project Disclaimer:

This e-mail message from Tony J. DeMarco and any files transmitted with it may contain confidential or privileged information 

intended solely for the individual(s) addressed in the message. Any review, use, distribution, or disclosure of this information by 

others is strictly prohibited. If you are not the intended recipient, or authorized to receive this transmission for the intended recipient, 

please contact the sender by reply e-mail and delete all copies of this message and any files transmitted with it from your system.

Tony J. DeMarco

Business Planning & Government Programs Analyst, Business Planning & Gov Prgrms

phone ● (623) 869-2485 cell ● (623) 826-2480 email ● ademarco@cap-az.com
34

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 

Submitted 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 water 
35

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 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 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, early 
36

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 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 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 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 established 
37

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 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 carbon 
38

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 Standards 
39

From: Maner Shaw [MShaw@shawinterests.com]

Sent: Thursday, November 07, 2013 11:26 AM

To: Carbon Pollution Input

Subject: Comment

Ladies and Gentlemen, 

Nationwide 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 our 

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 

involved 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 

allen.knoll@nacoal.com

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. 
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 

in 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

Good 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 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 
43

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 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 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 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.com
45

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 

Missouri. 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 

PO Box 209, 102 Maple Avenue 

Licking MO 65542 

573-674-2211, ext 1237 

cell# 417-260-0115 

karen.mcnew@ieca.coop
46

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 

electricity from my cooperative.

Adopting a regulatory strategy that will deliberately eliminate one of the most affordable sources of 

electricity

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

Right-click 

here to 

download 

pictures. To 

help protect 

your privacy, 

Outlo ok 

prevented 

auto matic 

download of 

this picture 

from the 

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 

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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 

Submitted 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 do 
48

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 Standards 
49

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 

Submitted 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 do 
50

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 Standards 
51

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 

generating 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 

2801 1st St. SW 

Underwood, ND 58576-1087 

(701) 442-5751 

trevor.schaar@nacoal.com

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. 
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 

Submitted 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 Standards 
55

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 Nongovernmental 
57

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/092013-671984-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-regulations-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 

Submitted 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 sessions 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 Standards 
60

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 

profit 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 

Callaway Electric Cooperative 

o) 573-826-2332 

c) 573-220-5431 
61

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: 

Our 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

330-429-2061 
62

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 

America 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 be 
63

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 

Services, 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 with 
65

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 

Brad 
66

Safety is Everyone's Job - All the Time 

Bradley Charles Lewis P.E. 

President 

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.com
67

From: Jimmy Evans [jevans@ibewlocal816.org]

Sent: Friday, November 01, 2013 5:43 PM

To: Carbon Pollution Input

Subject: Reducing Carbon Pollution

Jimmy Evans 

IBEW 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 at 

plants 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 42003 
68

270-898-2456 

270-898-2694 Fax 

jevans@ibewlocal816.org

__________ Information from ESET NOD32 Antivirus, version of virus signature database 8996 (20131101) 

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The message was checked by ESET NOD32 Antivirus. 

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69

From: Jimmy Evans [jevans@ibewlocal816.org]

Sent: Friday, November 01, 2013 5:35 PM

To: Carbon Pollution Input

Subject: Reducing Carbon Pollution

Paducah, KY 

Nov. 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

__________ Information from ESET NOD32 Antivirus, version of virus signature database 8996 (20131101) 

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http://www.eset.com
71

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 

comments 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 

Phone: (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, 

2013 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 

have 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 small scale. Storing carbon dioxide 

underground is not geologically feasible in much of the United States.Storing carbon dioxide 

underground 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 natural 
73

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 closer 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, would 

drive 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 30th 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 region 
74

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 

Submitted 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 Standards 
77

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 7th 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 Florida
78

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, 

This 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 CO2 

. Without similar restrictions on all countries, including China, CO2 reductions from the US 

will be insignificant and not result in an overall worldwide decrease in CO2. I must also state 

that 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 

The Falkirk Mining Company 

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 
81

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 

Submitted 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 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 
83

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 Standards 
84

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 

Submitted 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 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 
85

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 Standards 
86

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 

Submitted 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 homes. 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