CITY OF ASPEN 

CANARY INITIATIVE 

The City of Aspen 

130 S. Galena Street - Aspen Colorado 81611 - Phone: 970-920-5000 - Fax: 970-920-5197 

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City of Aspen Testimony - EPA Clean Power Plan (Docket ID No. EPA-HQ-OAR-2013-0602) 

Hello, my name is Chris Menges — I'm a climate, energy and greenhouse gas (GHG) analyst representing 

the City of Aspen. We appreciate the opportunity to present testimony here today and to share several 

of the reasons that the City supports EPA in finalizing, implementing and enforcing the Clean Power 

Plan. 

Aspen's support is based on our obligation to protect and maintain the viability of our local and regional 

economy and environment, and safeguard human health. Our tourism dependent economy relies 

directly on stable climate conditions. If the impacts that we are already seeing — like reduced snowpack 

and streamflows and more frequent and intense drought and wildfires — continue unabated, the 

foundations of our way of life and economic viability will be challenged and could plausibly erode. Since 

1940 we have already experienced a 2°F increase in temperature, accompanied by numerous 

documented impacts. A recent Aspen—specific climate assessment revealed that like the rest of the 

world, the severity of climate-impacts for our region is directly tied to emissions trajectories. As such, 

'business as usual' emissions are unacceptable for us. 

Accordingly, in 2004, Aspen's City Council adopted CO2 reduction goals of 30% below 2004 levels by 

2020 and 80% below those levels by 2050. Additionally, we operate a municipal electric utility which will 

source 100% of its power from renewable resources by 2015 (while still maintaining some of the lowest 

rates in the state). While the actions Aspen has taken on the path to meeting our own CO2reduction 

goals have improved quality of life for residents and visitors, we know they are not enough to address 

climate change. For that, binding CO2 limits on future and existing electricity generating units (EGU5) are 

necessary on a national and international scale. Aspen's support for the implementation of this rule is 

therefore a request that EPA help safeguard our economy and way of life. 

The City believes that the proposed regulations are a necessary, flexible, achievable, fair and cost 

effective step in the right direction. Further, we are confident that finalization of the rule would provide 

a greater chance of negotiating international commitments. Aspen is pleased that the US Supreme Court 

has three times affirmed the EPA's authority to regulate this pollutant under the Clean Air Act. Because 

the state-by-state approach has been used repeatedly and successfully to reduce other pollutants, we 

are pleased to see that EPA proposes to allow each state to achieve its own emission reduction target 

however it sees fit, within certain guidelines and criteria. It is important that EPA take steps to ensure 

that both the interim and 2030 targets are met in a meaningful and measurable way. 

For Colorado, we are confident that the 2030 target of -35% CO2 is achievable and in fact quite modest. 

If the State's renewables and efficiency deployment continued growing at current rates, we could likely 

surpass this goal. 

City of Aspen Testimony re - Docket ID No. EPA-HQ-OAR-2013-0602 - July 30, 2014 
A significant part of the City of Aspen's support for the proposed rules comes from our ongoing 

experience in diversifying and de-carbonizing our electricity sources. Currently, our municipal electric 

utility's generation portfolio contains approximately 80% renewables, yet we have the seventh lowest 

residential electricity rates (amongst municipal utilities) in the state. Our rates are also lower than those 

of most Colorado coops and Investor Owned Utilities (IOUs). Investments in renewables and efficiency 

by former and current City leaders have not only benefitted the environment, they have also insulated 

us against the inherent volatilities of fossil-fuel markets and prices. Prices that should only increase as 

their true costs to society begin to be monetized. 

I would like to close my remarks by sharing Aspen's confidence that the Clean Power Plan would save 

consumers money, improve public health and reduce GHG emissions. EPA estimates that electricity bills 

will be 8% lower by 2030 and that the Plan will generate $7 in health benefits for every $1 invested —

similar to America's experience with the CAA since 1970. When we consider the added benefits in 

criteria pollutant reductions and cost avoidance from climate impact mitigation, the Clean Power Plan is 

a great deal at the right time, and the City of Aspen is proud to encourage its timely implementation. 

Thank you for the opportunity to share our support with you today and for the important and beneficial 

work that EPA is doing, 

Chris Menges - On behalf of the City of Aspen Government. 

Data Research and Project Planner 

City of Aspen Canary Initiative 

(970) 920-5072 

Chris.Menges@cityofaspen.com 

With approval from: 

Ashley Perl 

Climate Action Manager 

City of Aspen Canary Initiative 

(970) 429-1798 

Ashley.Perl@cityofaspen.com 

Steven Skadron 

Mayor - City of Aspen 

(970) 920-5199 

Steve.Skadron@cityofaspen.com 

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City of Aspen Testimony re - Docket ID No. EPA-HQ-OAR-2013-0602 -July 30, 2014