Thank you for the opportunity to testify today. 

My name is Derek Murrow -I'm Director of federal energy policy for the Natural 

Resources Defense Council- or NRDC. 

Building on my colleague David's comments- I am here to support EPA in their 

proposal and make the case that we can make it stronger to ensure we limit 

pollution and protect future generations of Americans from the impacts of 

climate change. 

I am going to discuss very briefly our response to the EPA proposal and the 

establishment of the best system of emissions 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 testifying tomorrow 

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 important to note that the amount of reductions identified as feasible for 

each block does not indicate the amount that block should or will be relied on by 

a state in meeting its target. Each block is simply an inventory of the available 

tools to cut power sector carbon pollution and when EPA omits or underestimates 

the potential contribution of a block, it is underestimating the 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 of 6% and 

ignores capital projects such as turbine blade replacements or co-firing of other 

fuels. We are reviewing EPA's analysis to determine whether higher levels of 

efficiency and other operational changes at power plants should have been 

included. 

Block 2- Natural Gas and Coal Dispatch: 
This block reduces coal generation based on the amount of underutilized natural 

gas combined cycle capacity in a state. 

In assessing the emissions reductions that this block can achieve state by state, 

the proposal fails to account for the existing trend of retiring old, high-emissions 

fossil-fired plants in favor of new low- or zero-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, it should be adjusted to account for planned and 

anticipated coal and other fossil plant retirements and general rates of generation 

change from coal to lower emitting resources. 

In other words, EPA should ensure that Block 2 will drive additional emission 

reductions- all states should be expected to transition from old, high-emitting 

coal and gas plants to cleaner resources over time. 

EPA asked for comment on whether states can use new natural gas plants to 

comply with the emissions targets, but it has not factored those plants into the 

establishment of the targets. 

There must be symmetry between the resources considered in setting the target 

and the resources allowed for compliance. 

I'm going to repeat that- there must be symmetry between the resources 

considered in setting the target and the resources allowed for compliance. If not, 

some states with modest targets will achieve their goal simply as a result of 

implementing their existing plans to close old coal plants and replace them with 

new natural gas plants. This lack of symmetry should be fixed. 

Finally, I want to thank EPA for all their hard work in developing the proposal and 

their leadership on this critical environmental issue.