Testimony of Dr. Jeremy Richardson at EPA's Public Hearing on Carbon 

Pollution Standards for Existing Power Plants, on behalf of the Union of 

Concerned Scientists 

July 30, 2014 

Thank you for the opportunity to testify today in support of strong carbon 

pollution standards for existing power plants. 

My name is Jeremy Richardson and I am a senior energy analyst at the Union 

of Concerned Scientists (UCS). UCS is the nation's leading science-based 

nonprofit working for a healthy environment and a safer world. 

I have a unique perspective on reducing greenhouse gas emissions from the 

burning of fossil fuels. As a scientist, I understand the urgency to reduce 

greenhouse gas emissions to protect the planet's climate. As the brother, son, 

and grandson of West Virginia coal miners, the question of how we go about 

tackling climate change is deeply personal to me. 

First, on behalf of UCS's more than 450,000 supporters, I want to say today 

that we strongly support the Environmental Protection Agency's (EPA's) 

efforts to limit carbon emissions from fossil fuel-fired power plants under the 

Clean Air Act. Simultaneously, I want to emphasize the need for special 

consideration for the families and communities facing the negative 

consequences of the transition to a cleaner, low carbon energy system. 

Human-induced climate change is already having impacts that are being felt 

by people here in America and around the world. If we collectively fail to 

make deep reductions in our carbon emissions, we will greatly increase the 

risk of serious economic, health, and environmental consequences from 

accelerating sea level rise, storm surges, heat waves, drought, wildfires, more 

frequent heavy downpours, and increased hurricane intensity. 

These impacts are a direct consequence of the increasing concentration of 

greenhouse gases like carbon dioxide (CO2) in our planet's atmosphere. 

Power plants are the largest single source of U.S. CO2 emissions, representing 
about 40 percent of the total. Reducing emissions from the electric power 

sector is therefore crucial to our overall efforts to tackle climate change. 

These facts compel us to act, and to act decisively. In doing so, we must 

recognize that some regions of our country are facing a heavier burden than 

others in accelerating this transition to a less fossil-intensive electricity 

system. 

The proposed carbon standard for existing power plants provides a sound 

framework for reducing emissions from the power sector, but is not 

ambitious enough in the overall result of a 30 percent reduction in 

emissions in 2030 relative to 2005. UCS analysis shows that we can achieve 

twice that - a 60 percent reduction in emissions in 2030 relative to 2005. 

UCS supports EPA's proposal to incorporate "outside-the-fence" emissions 

reduction measures, namely renewable energy (RE) and energy efficiency 

(EE), in state compliance plans. Renewables such as wind, solar, and 

geothermal energy emit no carbon, and are already delivering safe, reliable, 

and affordable power to consumers. They also help diversify their electricity 

mix, improve public health, strengthen state and local economies, and reduce 

the risks of over reliance on natural gas. 

EPA used four "building blocks" to determine the Best System of Emission 

Reduction (BSER) and establish emission rate reduction goals for each state. 

For the renewables block, EPA has really proposed an "average" system of 

emission reduction, seriously underestimating the true potential for 

renewable energy to cut carbon emissions. EPA's state renewable energy 

targets are in many cases close to a business-as-usual approach—four states 

had more renewable generation in 2012 than their EPA targets for 2030. 

States could be more ambitious in using renewables to reduce emissions. 

Costs of renewable energy have fallen dramatically. For example, the cost of 

solar PV is already equal to retail electricity rates in 10 states, and this 

number could more than double over the next year and a half as the costs of 

solar continue to fall, according to a recent study by Deutsche Bank. Since the 

beginning of 2011, the average price of a solar PV panel has declined 60 
percent, while the average installed cost has fallen by more than 35 percent. 

Meanwhile, the cost of wind power dropped 43 percent in the last four 

years—and is now competitive with power from new fossil fuel plants in 

some regions of the country. Multiple market factors are making coal-fired 

power too expensive relative to other cheaper, less polluting options like 

natural gas, renewable energy, and energy efficiency. 

EPA's framework also includes the option for states to comply on a multi-state 

or regional basis, which not only rewards early actors like the RGGI states but 

also creates an opportunity for new or expanded multi-state col.laborations to 

drive down emissions at a lower cost. 

States have a major role to play in developing implementation plans for 

carbon standards. Together with federal policy makers, states should help 

ensure that economic diversification and resources for worker transition are 

an important part of their plans. In doing so, together we can not only 

establish a strong standard to protect the planet's climate, but also 

ensure that workers and communities have fresh economic 

opportunities, as market forces drive a shift away from coal. 

I do not accept that this is an "either-or" proposition. 

Our children and our grandchildren will face the risks of a vastly different 

climate caused by our failure to act to reduce emissions today. My young 

niece, and maybe someday her children and grandchildren, will face an 

uncertain future if we don't get the second part right too. 

It is much harder, but it is imperative that we do both. 

Thank you.