ERCC 

Electnc 

Rel1ab1llty 

Coordmatmg 

Council 

Statement of Christopher R. Burk 

Electric Reliability Coordinating Council 

EPA's Proposed Clean Power Plan 

Public Hearing in Pittsburgh, Pennsylvania 

Friday, August 1, 2014 

I appreciate the opportunity to speak with you today. My name is Christopher Burk. I 

am speaking on behalf of the Electric Reliability Coordinating Council-the ERCC. 

ERCC is a broad-based coalition of energy companies that works to ensure that 

consumers across the United States continue to have access to reliable, affordable, and 

environmentally responsible power. 

Climate change policy is complicated and involves difficult choices and careful 

balancing of costs, risks, and benefits-and it must take into account the international 

nature of carbon emissions. This attempt to establish a nationwide energy and 

electricity policy through EPA regulations, however, is not the best path for this policy 
debate. ERCC shares the concerns about the EPA's proposal that have been raised by 

many state officials, energy companies, small businesses owners, manufacturers, union 

members, legal experts, and individuals. This proposal is an unprecedented use of an 

obscure provision of the Clean Air Act that threatens the reliability of our country's 

electricity supply and will result in significantly higher energy costs. And without 

appreciable benefits. Overall, EPA should not finalize the proposal as written and 

should provide additional time for comments and analyses to be prepared. 

The reliability risks created by the proposal are significant, and need to be analyzed 

carefully prior to the adoption of climate change policies. When electricity is unreliable, 

vulnerable populations can face life-threatening conditions as result of heat or cold, and 

the basic functioning of our economy is imperiled. 

EPA's proposal increases the risk that our electricity supply will be less reliable. EPA's 

"building blocks" require that states seeking EPA approval reconfigure both how 

electricity is generated and how it is dispatched, and at the end of this process the 

proposal also promises that almost a third of the existing coal-fired generation fleet will 

be retired between 2020 and 2022. These plants currently provide electricity that 

sustains our economy and the health and well-being of our citizens. When these plants 

are shuttered, our electricity supply will be entirely dependent on EPA's predictions 

about energy efficiency and the growth of costly, underdeveloped alternative energies. 

Our fear is that without these generating facilities, another polar vortex or heat wave 

-2-
may expose these vulnerabilities and subject citizens and businesses to energy 

shortages and price shocks. 

EPA is not in a position to craft reliability policies, and EPA has never been tasked with 

such authority by Congress. The most effective reliability policies result from the careful 

coordination between the Federal Energy Regulatory Commission, state and regional 

regulators, reliability organizations, and other stakeholders-and under this proposal 

EPA would be given the power to trump their decisions by approving or disapproving 

state energy policies. 

ERCC is also concerned because EPA's proposal will increase electricity prices for 

households and businesses. In fact, EPA admits that electricity prices will increase 

between 6 and 7 percent nationally in 2020 as result of the rule, with some areas facing 

double-digit increases in electricity prices. 

These increases are uniquely harmful to vulnerable populations-such as the poor and 

the elderly- because the money needed to pay for electricity can directly trade off with 

their ability to purchase services and products, including those essential to their health 

and well-being. Even small increases in electricity prices can be harmful because they 

increase the operating costs for manufacturers, schools, and hospitals. Those higher 

-3-
costs will reverberate through all sectors. The result will be higher prices, fewer jobs, 

and a slower economy. 

EPA has attempted to camouflage these increases by promising that they will save 

households money by encouraging them to use less electricity. But that is cold comfort. 

Knowing that the government is trying to make you use less electricity will do nothing to 

help people on fixed incomes who have to run their A/C longer during a heat wave or 

their heat during a cold snap-because a promise of greater efficiency or lower costs in 

the next decade will not pay their bills at the end of this next month. 

Some proponents here today seem to think that the proposed rule will reduce asthma. 

Because the rule produces little if any benefits, EPA appears to be purposefully 

confusing the rule with one designed to address conventional air pollution. The fact is 

that EPA admits that conventional air pollution has been on decline for years and the 

Agency has adopted a number of recent rules to directly address the very sort of 

emissions it now claims to be reducing with the carbon rule. Put another way, the 

Agency continues to pile on new regulatory costs but claims the same old benefits it has 

used before to justify other costly rules. This is called double accounting, and EPA 

should know better. 

-4-
Carbon emissions are a global issue. Indeed, U.S. carbon emissions have been stable 

or declined over the last decade. By contrast, Chinese emissions have increased over 

170 percent while Indian emissions have increased over 90 percent. Therefore, climate 

policy requires a comprehensive approach incorporating coordinated legislation, 

international diplomacy, and a thorough deliberative process. The current EPA 

proposal, however, is wrong path. It is risky. It is expensive. And it will not address the 

global nature of carbon emissions. EPA's proposal comes with real risks for the health 

and economic well-being of our country, and the proposal should not be finalized as 

currently drafted. 

Thank you for your time. 

### 

-5-