James (Jay) Gill, Jr. ' / -....JII!anager, Co_!!!!lll.lnieations & Public Relations

**·-·--~-.---·** Carroll Electric Membership Cooperative ing/ Atlanta July 29, 2014 7:00pm

• The bad news is that we are all crammed in here at 7pm on aTuesday night listeningto me. The good news is that I'm well versed in the art of brevity. • First ofall, let me thank you forthis opportunityto speak to you on behalf ofthe Members ofour cooperative and unfortunately express our opposition to the EPA's proposed rules for existing power plants. • My name is Jay Gill and Iam the Manager ofCommunications and Public Relations for Carroll EMC. Carroll EMC is a not-for-profit, consumer-owned business that distributes electricityto roughly 50,000 residential, commercial and industrial accounts. Our service area covers a large portion ofwestern Georgia from Polk and Paulding counties down to thetop ofTroup and alongthe edge ofCoweta. As an employee, I am naturally concerned about any regulation that is placed on our industrythat doesn't make sense. However, as a Member and a consumer, I am more concerned aboutthe affects ofthis policy regarding reliability and cost increase.

• At Carroll EMC wejudge every government policy against the impact it will have on our abilityto provide our members and ourcommunities with safe, reliable and affordable power. We ask the EPA to withdraw its proposed guidance and start over because the proposal as drafted underminesthose goals. In fact, I have yetto hearofany professional in our industry speak out against the idea ofclean air, clean water orclean soil. As professionals, we understand that ittakes careful planning and time to phase out oldertechnology and replace it with newtechnology, especially ifthat newer technology doesn't exist yet. Ifyou are waiting on a livertransplant, you don't unplug your life support machine hopingthe donor organ will getto you more quickly. • But more importantly, there are many reasons we oppose these regulations. First and foremost we believe Georgia is being treated unfairly in these rules. • These proposed regulations ignore the significant progress Georgia has already made in reducing greenhouse gas emissions. Georgia has reduced C02 emissions by approximately 30% between 2005 and 2012. That is equivalenttothe national goal the EPA set for 2030. In otherwords, Georgia has already achieved EPA's goal.• Yet instead of rewarding this early action by codifying the state ofGeorgia's accomplishment, or at most seeking a modest further reduction, these rules instead require another44% emission reduction by 2030. • Under EPA's plan, Georgia will be makingthe 6th largest reduction required ofstates nationwide and so Georgia is being penalized for taking significant early action. We consider this a bad policy and unfairtreatment. • Again, I believe we all agree on the ultimate goal or ideal of reducing dependencyon fossil fuels, howeverthere is a much better way to achieve this goal. Myfirst suggestion is to retain input from the engineers and professionals in the power industry, including cooperatives. • On behalfofCarroll EMC, I urge you to abandon these rules and work with cooperatives to achieve a more balanced approach thattreats states fairly. • Thank you for the opportunityto be heretoday.