DB03/0504745.0013/10046506.1 RG19 Statement of Kansas City Board of Public Utilities

November 4, 2013

Lenexa, KS Public Listening Session To Solicit Idea s and Input

About The Best Clean Air Act Approaches To Reduce Carbon Pollution from Existing Power Plan ts

Good evening. I am David Mehlhaff, Chief Communica tions Officer of the Kansas City Board of Public Utilities (or BPU). BPU appreciates the opportunit y to share our ideas about the best approaches to reduce carbon emissions from existing power plants as well as our concerns about the potential economi c impact of new regulations on our customers. BPU has a keen interest in this matter because it operates coal-fired power plants. While BPU appreciates the importance of reducing air pollution, it also has a duty to provide reliable, affordable electricity for its customers. BPU is a municipally- owned, not-for-profit utility governed by an elected Board and subject to laws, regulations, and Charter Ordinances of the Unified Government of Wyandotte County/Kansas City, Kansas. BPU provides electric service for the benef it of residents, businesses and industries in Wyand otte County, for the public water supply in Johnson Coun ty, Kansas, and for the Kansas Municipal Electric Association. BPU serves approximately 65,000 reside ntial, commercial and industrial electric customers

. More than 20% of the people served live below the p overty level, many of them having disabilities or relying on fixed incomes; for these people especial ly reliable and affordable electric power is a nece ssity. BPU urges EPA to factor the potential economic burd en on these struggling customers of spending hundreds of millions of dollars that will be requir ed for BPU alone, and comparable amounts for other utilities, to meet the guidelines and EPA’s other r ecent power plant rules .

BPU uses renewables such as wind, hydro, landfill g as, and energy efficiency programs, but its coal-fi red power plants generate substantial amounts of low co st electricity that keep BPU’s rates affordable. Tw o of BPU's coal units will fuel switch to natural gas un der the MATS regulation. If additional new regulati ons force BPU to eliminate its mix of generation, incur additional costs, to reduce the plants' output, or to truncate their useful lives, the end result will be higher rates. BPU urges EPA to allow States to dev elop plans founded on a cost benefit analysis of what re alistic carbon reduction goals can be achieved in l ight of each State's existing circumstances, including t he potential effects on end users.

For existing power plants, BPU urges EPA to adopt d emand side and supply side energy management as the most appropriate Best System of Emission Reduct ion (BSER). Currently, no technology can control GHG emissions at existing power plants, and theoret ical controls are unproven. On the other hand, demand side and supply side policies have already h elped to lower overall and peak electricity usage, and, consequently, power plant emissions. EPA should pro mulgate guidelines that allow States to integrate those polices with GHG emissions reductions for exi sting power plants in a flexible manner that consid ersDB03/0504745.0013/10046506.1 RG19

each State’s unique mix of electric generation sour ces, anticipated energy usage, its human and econom ic resources, and its energy policies and objectives.

BPU submits that waivers from New Source Review and more stringent BACT limits be allowed for efficiency improvement projects on existing power p lants as a means to encourage utilities’ interest a nd ability to upgrade existing facilities. Allowing wa ivers will enhance energy efficiency and/or reduce GHG emissions from existing power plants.

Thank you for the opportunity to present BPU’s view s.