4:1‘n‘ , WESTERN RESOURCE ADVOCATES 

Celebrating 25 years of conservation in the West g, 

CONTACTS: 

Stacy Tellinghuisen, Senior Energy/Water Policy Analyst 

Western Resource Advocates, (720)763-3716 

WESTERN RESOURCE ADVOCATES' STATEMENT TO EPA ON THE CLEAN 

POWER PLAN, DELIVERED JULY 29, 2014 

Key Western States Are Close to Achieving EPA's Carbon Reduction Goals 

"My name is Stacy Tellinghuisen. I work on energy/water issues for Western Resource Advocates, a 

conservation organization working to protect the West's air, water, and landscapes, and the 

communities that depend on them. 

If you take away one key point from my testimony today it is this: 

• Western Resource Advocates has analyzed Colorado, New Mexico and Nevada's current energy 

policies and finds that these three states will be very close to achieving EPA's proposed 2030 

targets. In fact, in Colorado and New Mexico, policies already in place will accomplish over 80% 

of what EPA's standard requires. In Nevada, the state and main utility will have to do little if 

anything else to meet EPA's proposed requirements. 

Earlier this year, the U.S. released the fourth National Climate Assessment. In the Southwest, the litany 

of current and future impacts described in the assessment include earlier snowmelt, hotter summers, 

more frequent and intense droughts, increased wildfires, along with secondary impacts on human 

health and environmental resilience. One of the report's key conclusions was "The Southwest is already 

experiencing the impacts of climate change." For those of us living in the region, that conclusion rings 

true. 

For these reasons, EPA's proposed Clean Power Plan is of critical importance. Western Resource 

Advocates believes EPA's proposed standards for greenhouse gas emissions from existing power plants 

are essential for protecting our natural resources and our health, and our Western way of life. The 

regulations are thoughtful, fair and rigorous, and consistent with the specific requirements of Section 

111(d) of the Clean Air Act. We appreciate the work that EPA has put into developing these important 

regulations. While we expect to submit more specific and technical written comments to EPA at a later 

time, Western Resource Advocates believes the regulatory framework EPA has established is very 

workable, and that the regulations are on solid technical and legal footing. Moreover, we believe the 

regulations are doable and come at a critical time. Given the pressing nature of climate change, we urge 

you to maintain your proposed adoption and implementation schedule. 

To further explain my opening point: In the West, many states and utilities have already been taking the 

initiative to advance clean energy, improve energy efficiency, and transition the most carbon-intensive 

power plants to cleaner sources of energy. Key stakeholders — including our utilities, state agencies, 

Arizona Colorado Nevada New Mexico Utah 

P.O. Box 1064 2260 Baseline Rd. 550 W. Musser Street 409 East Palace Ave. 150 South 600 EOS' 

Scottsdale, AZ 85252 Suite 200 Suite! Unit 2 Suite 2AB 

Boulder, CO 80304 Carson City, NV 89703 Santa Fe, NM 87501 Salt Lake City, UT 84102 

www.westernresourceadvocates.org 
health and environmental advocates — have worked together to pursue creative, workable solutions. 

Those solutions have helped us meet other clean air requirements to reduce mercury, air toxics, and 

regional haze. Those solutions protect our communities' air quality and health, and have protected 

electricity customers from untenable rate increases. For example, 

• In Colorado, the Clean Air Clean Jobs Act is allowing our state to economically transition to 

cleaner energy and a stronger economy; 

• In Nevada, SB 123 is similarly transitioning that State from conventional coal-fired power plants 

to renewable energy; 

• And in New Mexico, recent plans to advance the retirement of a portion of San Juan Generating 

Station and replace it with cleaner energy sources have similarly moved that state towards a 

much lower carbon footprint. 

And the five Southwestern states of Arizona, Colorado, Nevada, New Mexico, and Utah all have energy 

efficiency programs in place to further reduce the environmental impacts of our energy needs. 

These policies have put western states well on their way to meeting EPA's proposed standards. In fact, 

Western Resource Advocates assessed the likely emissions trajectory of three southwestern states: 

Colorado, Nevada, and New Mexico. These three states have taken a proactive approach to addressing 

environmental issues and greenhouse gas emissions, and those efforts have served them well. 

Our analysis finds that, if Colorado and New Mexico simply follow through on what they are planning to 

do anyway under current policies, both states will accomplish over 80% of what EPA's standard requires. 

In Nevada, we found that by implementing current policies as already planned, the state will need to 

take few if any additional actions to meet EPA's standard. 

So again — if you only take one point away from my testimony today it is this: 

Western states — particularly Colorado, New Mexico, and Nevada — have proactively addressed this 

issue, and are well prepared to meet EPA's standard on the reasonable timeframe EPA has proposed. 

While there is more to do over time in Colorado and New Mexico, as well as several of the other states 

in the region, our history shows that western stakeholders can and will come together to find workable, 

low cost and practical solutions that protect our communities, our economies, our jobs and our 

environment. We very much appreciate EPA's willingness to provide states with significant flexibility to 

comply with these regulations, in ways that make local sense. 

Most importantly, EPA's proposed regulations are a vital step toward managing our greenhouse gas 

emissions. Reducing emissions is critical to protecting our communities, as well as the rivers, farmland, 

forests, and landscapes that define the West. Thank you for your important work on this issue."