DB03/0504745.0013/10046506.1 RG19 

Statement of Kansas City Board of Public Utilities 

November 4, 2013 

Lenexa, KS Public Listening Session To Solicit Ideas and Input 

About The Best Clean Air Act Approaches 

To Reduce Carbon Pollution from Existing Power Plants

Good evening. I am David Mehlhaff, Chief Communications Officer of the Kansas City Board of Public 

Utilities (or BPU). BPU appreciates the opportunity to share our ideas about the best approaches to 

reduce carbon emissions from existing power plants as well as our concerns about the potential economic 

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 benefit of residents, businesses and industries in Wyandotte 

County, for the public water supply in Johnson County, Kansas, and for the Kansas Municipal Electric 

Association. BPU serves approximately 65,000 residential, commercial and industrial electric customers. 

More than 20% of the people served live below the poverty level, many of them having disabilities or 

relying on fixed incomes; for these people especially reliable and affordable electric power is a necessity. 

BPU urges EPA to factor the potential economic burden on these struggling customers of spending 

hundreds of millions of dollars that will be required for BPU alone, and comparable amounts for other 

utilities, to meet the guidelines and EPA’s other recent power plant rules . 

BPU uses renewables such as wind, hydro, landfill gas, and energy efficiency programs, but its coal-fired 

power plants generate substantial amounts of low cost electricity that keep BPU’s rates affordable. Two of 

BPU's coal units will fuel switch to natural gas under the MATS regulation. If additional new regulations 

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 develop 

plans founded on a cost benefit analysis of what realistic carbon reduction goals can be achieved in light 

of each State's existing circumstances, including the potential effects on end users. 

For existing power plants, BPU urges EPA to adopt demand side and supply side energy management as 

the most appropriate Best System of Emission Reduction (BSER). Currently, no technology can control 

GHG emissions at existing power plants, and theoretical controls are unproven. On the other hand, 

demand side and supply side policies have already helped to lower overall and peak electricity usage, and, 

consequently, power plant emissions. EPA should promulgate guidelines that allow States to integrate 

those polices with GHG emissions reductions for existing power plants in a flexible manner that considers 
 

DB03/0504745.0013/10046506.1 RG19 

each State’s unique mix of electric generation sources, anticipated energy usage, its human and economic 

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 plants as a means to encourage utilities’ interest and 

ability to upgrade existing facilities. Allowing waivers will enhance energy efficiency and/or reduce GHG 

emissions from existing power plants. 

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