### 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 considerationfor 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, representingabout 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 60percent, 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.