Thank you forthe opportunityto testifytoday. My name is Derek Murrow-I'm Director offederal energy policy forthe Natural Resources Defense Council- or NRDC. Building on my colleague David's comments- Iam here to support EPA in their proposal and make the case that we can make it strongerto ensure we limit pollution and protect future generations ofAmericans from the impacts of climate change. Iam goingto discuss very briefly our response to the EPA proposal and the establishment ofthe best system ofemissions reduction (BSER) and the building blocks EPA has used to set a state emissions goal. I'm going to focus on building blocks 1 and 2 and colleagues testifyingtomorrow will talk about blocks 3 and 4. EPA's proposed targets can and should be strengthened. The pollution reductions could be greater at a reasonable cost, in both the near-term and the long-term. It's importantto note thatthe amount of reductions identified as feasible for each block does not indicate the amountthat block should orwill be relied on by a state in meeting its target. Each block is simply an inventory ofthe available tools to cut power sector carbon pollution and when EPA omits or underestimates the potential contribution ofa block, it is underestimatingthe amount of pollution cleanup that is feasible in each state. Block 1- Coal Plant Efficiency: This block is currently limited to coal plant efficiency improvements of6% and ignores capital projects such as turbine blade replacements or co-firing ofother fuels. We are reviewing EPA's analysis to determinewhether higher levels of efficiency and otheroperational changes at power plants should have been included. Block 2- Natural Gas and Coal Dispatch:This block reduces coal generation based on the amount ofunderutilized natural gas combined cycle capacity in astate. In assessing the emissions reductions thatthis block can achieve state by state, the proposal fails to account forthe existingtrend of retiring old, high-emissions fossil-fired plants in favor of new low- orzero-emission resources. This means that EPA has set 2030 goals that some states will easily achieveparticularly in states that are very coal intensive. To ensure that this block, and the proposal as a whole, achieves additive reductions in carbon pollution, itshould be adjusted to account for planned and anticipated coal and otherfossil plant retirements and general rates ofgeneration change from coal to lower emitting resources. In otherwords, EPA should ensure that Block 2will drive additional emission reductions- all states should be expected to transition from old, high-emitting coal and gas plants to cleaner resources overtime. EPA asked for comment on whether states can use new natural gas plants to comply with the emissions targets, but it has notfactored those plants intothe establishmentofthe targets. There must be symmetry betweenthe resources considered in settingthe target and the resources allowed for compliance. I'm goingto repeat that- there must be symmetry between the resources considered in settingthe target and the resources allowed for compliance. If not, some states with modesttargets will achieve their goal simply as a result of implementingtheir existing plans to close old coal plants and replace them with new natural gas plants. This lack ofsymmetryshould be fixed. Finally, Iwantto thank EPA for all their hard work in developingthe proposal and their leadership on this critical environmental issue.