Comments on EPA Clean Power Plan 

Docket No. EPA-HQ-OAR-2013-0602 

Pittsburgh, PA 

July 31, 2014 

Don Goldstein, Ph.D. 

Department of Economics, Allegheny College 

First, let me thank the EPA for proposing this Clean Power Plan, organizing these sessions, 

and giving me the opportunity to comment. I teach corporate finance and environmental 

management at Allegheny College, about ninety miles north of here. During my 24 years at 

Allegheny, I have also worked with many local companies around environmental 

management in a variety of capacities. My research examines lower-carbon energy and 

transportation technologies, including their potential roles in the economic future of this 

region. Everything that I have seen tells me that the proposed Plan will move us in the right 

direction, especially to the extent that its boost toward renewables in our energy mix is 

maintained and even strengthened. That is where I will focus my comments, while I 

welcome the many benefits the Plan will create for human health and the environment. 

Innovation and investment in new technologies require clear signposts signalling firms that 

such investments will be consistent with where others and the economy at large are 

heading. Sometimes market signals alone provide adequate signals, and - especially for 

major, systemic changes - sometimes this requires an assist from government action. The 

move toward lower-carbon energy is that kind of technology transition. 

My research suggests that Northwestern PA has regional assets that could be leveraged as 

part of this shift. For example, there is sufficient hardwood forest acreage within 75 miles 

of Erie to support at least 1 million tons of pelletized wood annually for biomass energy, 

sustainably managed from waste cuttings and pulpwood. But pellet mill investors need to 

know they will be able to get their output shipped economically, and transportation 

facilities investors need to know there will be ongoing demand for the product. In addition, 

the southern shores of Lake Erie have a commercially viable wind resource, estimated 

offshore at 18 mph at 90 meters and onshore at 15 mph at 80 meters high. But developers 

await signals that State policy support will be there for wind power demand and for a 

workable regulatory framework. 

These are only the direct potential opportunities in low-carbon energy. Actualizing them 

would also create indirect and mutually supporting ones. The Erie-Meadville region has a 

world-class cluster of several hundred precision machining companies, with the capacity to 

become major suppliers for renewable energy equipment and infrastructure. Upgrading 

port and intermodal facilities to support biomass and Lakeshore wind would encourage 

reinvigoration of the region's historical strengths as a freight transportation nexus. And 

expansion in both energy technology supply-chain and intermodal shipping capabilities 

would make the region more competitive in the ongoing shift toward natural gas as a 

lower-carbon fossil fuel source. 

Such projections are, to some extent, speculative. But we can confidently predict that 

pragmatic, flexible Federal regulatory choices can start a process in which a combination of 

State policy and market forces would allow the region's companies to pursue the 

opportunities in low-carbon technologies as they perceive them, in the process generating 

not only power, but also jobs, income, and economic development. 
The Clean Power Plan is well-designed to stimulate such a process. The States get clear 

carbon-intensity targets embodying a few simple action areas, to be utilized at State 

discretion for the greatest leverage. Companies get a consistent Federal and State policy 

framework within which to make decisions as opportunity suggests. With the signposts in 

place, private sector innovation and investment can move us faster and farther along in this 

critical technology transition than would occur without the Plan. 

For the companies and workers in NWPA, fundamentally this is about adaptation to the 

national and global economies as they evolve in a world of climate change. Like politics, at 

the end of the day all climate adaptation is local. The local politics in NWPA have not, in 

general, been friendly to the Administration's climate and energy agenda. But this 

proposed EPA Plan can, over time, contribute to re-framing climate adaptation in terms of 

economic opportunity. This could ultimately be one of its most important co-benefits. 

Thank you.