Statement of Daniel A. Lashof, Ph.D. Director, Climate and Clean Air Program Natural Resources Defense Council Public Hearing on the Environmental Protection Agency's Proposed Carbon Pollution Standard for New Power Plants Washington, D.C., May24, 2012 I appreciate the opportunityto appear here todayto provide furthercomments on behalfofthe Natural Resources Defense Council in support of EPA's proposal to establish carbon pollution standard for new electric power plants. As my colleagues have noted, this will be the first national limiton carbon pollution from power plants and is avital step toward protecting public healthfrom the dangers of climate change. One ofthe clearest and most direct healththreatsfrom climate change is deadly heatwaves. We all knowthat hot, muggy conditions are unpleasant. They are also dangerous-especially forold people, young children, and individuals with certain pre-existing conditions. Already an average of more than 1000Americans die each yearfrom the direct and indirect effects ofexcessive heat. Yesterday NRDC released a report showing that unabated climate change could increase that numberdramatically, resulting in a cumulative total of more than 30,000 additional deaths by mid-century and more than 150,000additional deaths by century's end. Power plants are America's largest source ofcarbon pollution, so there is simply no question that carbon dioxidefrom power plants cause orcontribute to endangering public health and welfare. Given that, EPA is simply doing is job by moving forward with common sense standards to limitcarbon pollution standards from power plants. Indeed, these standards are long overdue. NRDC strongly supports EPA's decision to establish a fuel-neutral standard applicable to all new fossil fuel fired electricity generating units. Our electricity system is operated as an integrated whole and

a megawatt-hourgenerated by acoal plant provides the same service as a megawatt-hour provided by a gas plant. As EPA notes in the proposal, a developer ofa new power plant has awide variety ofdesignoptionsthat allow itto comply with the proposed standard. So there would be nojustification for EPA to allow more pollution from certain types ofplants based on a design choice within the developer's control, particularly when less polluting options are also less expensive. Indeed, NRDC urges EPA to go even further in establishing afuel-neutral and technology-neutral carbon pollution standard for new power plants. We see no reason to make distinctions among fossil fuel generating units based solely on theirtechnology configuration. We therefore urge EPA to include all fossil electricity generating units with acapacity greaterthan 25 MW in the category of potentially affected sources. (EPA has specifically asked for comment on howto address simple cycle turbines used to meet peak load and NRDC plans to elaborate on this in ourwritten comments). Some opponents ofEPA's proposal have characterized itas awaron coal. This is simply untrue. EPA is combating pollution, to protect the health ofthe American people. And the benefits have been

enormous. In 2010 alone the health and environmental benefits ofclean air standards have been valued at 

### $1.3 trillion- more than 2S times their cost. Where else can you get that kind of return on investment? The proposed carbon standard for new power plants is fuel-neutral. In fact, EPA has gone out of its way by providing an option thatwould allow a newcoal plant to have higher emissions than the standard for its first 10years ofoperations, provided that its average emissions over 30 years comply with the standard. Ifcoal is losing the battle for marketshare, it is because ofmarketforces, notthe EPA. Market analysts, utilityexecutives, independent economists, and government forecasters all agree. For example, Alliance Bernstein's Senior UtilitiesAnalyst Hugh Wynne cites the narrowing price differentials between natural gas and coal, the greaterfuel efficiency ofcombined cycle gas turbines (CCGTs) over conventional coal steam plants and the lowerconstruction cost ofCCGTs in explaining that it's unlikelythatthe economics ofcoal would improve enough to revive interest in building new coalplants even in the absence ofthe proposed standard. "

...we expect the proposed rule to have little impacton capacity additions over the remainderofthe decade," he concluded. Most utilityexecutives have acknowledged this reality, and some have gone further-welcoming the regulatory certaintythatthe proposed standard would provide. In a statementthatfollowed EPA's announcement ofthe proposed standards, Public Service Enterprise Group (PSEG) Chairman and CEO Ralph lzzo stated,"

... EPA took an important step today in addressing the significant environmental threat posed by climate change. The Agency's action establishes a logical and modest standard for new electric power plants and provides the industrywith much needed regulatory certainty. The EPA provides aframework for the industryto confrontthis problem in a cost effective manner." Finally, governmentforecasts by both the Department of Energy and EPA confirm that no new coal plants are likely to be built duringthis decade otherthan those already under construction. This remains true even in sensitivity analyses assuming much higher natural gas prices than are actually expected. EPA's proposal to set the first national limits on carbon pollution from power plants is in fact essential to establish an electric system thattruly serves electricity customers. Afterall, electricity customers are also breathers. We need a reliable electric system, buta system that destabilizes our climate is anything but something we can rely on. Improvingand finalizing this proposal is a small, but critical, step toward creating an electricity system we can all live with.