EPA Testimony 7/29/14

Laurent Meillon — 105 Hoyt Street, Lakewood, CO 80226 laurentmeillon@yahoo.com

Hello, I am Laurent Meillon. Since obtaining an MBA UW-Madison, my life-long focus across industries has been on new product development: "How does a product go from the anecdotic to general market adoption?" I am a jr. partner with Capitol Solar Energy, Harvesting sunlight for 33 years. I serve as policy committee member for CRES, and recently served as an elected board member, treasurer and VP for COSEIA. I am the co-author of the CO solar thermal roadmap, in cooperation with many parties from NREL to government, academia and industry. I am here to offer support for the new regulations internalizing some of the costs of carbon dioxide: These regulations are the most meaningful legislative or executive action to address climate change and limitations in natural resources in American history, perhaps since Mesa Verde collapsed.

- These regulations begin to address the external costs of fossil fuels, which are right now socialized at random, escaping the capitalist system which is the foundation of our economy.

- Throughout the history of the agency, industry has systematically overestimated the financial consequences of EPA regulations, and their claims must be dismissed — because they are entirely exaggerated, and because externalizing these costs stands on no other ground than habit and tunnel vision. In fact, recent NY Times articles show that the largest fossil fuel corporations already use an internal cost of carbon above the proposed EPA regulation - $60 per ton in Exxon/Mobil's internal accounting.

- Internalizing these costs will even the playing field between renewable energies and fossil fuels, opening a new era of sustainable economic growth. I am mainly here to ask that methane is given proper Cot equivalence and included in your regulations:

- There are two fast-growing, large scale energy industries in the US: fracking and renewables. In the US, 2/3 rd

to 3/4 th of the energy used by buildings is towards heating and cooling functions, dominantly addressed with natural gas, while renewable energy efforts have typically focused on electrical generation, which only touches a quarter of the energy usage of our buildings. The retail price of fracked gas in CO is around 60 cents per therm, or roughly 2 cents per KWh. Per energy content, this is 4 to 5 times cheaper than electricity, propane or gasoline.

- Market forces will make this industry boom!

- Fracked gas is a fossil fuel, with its myriad consequences on water, air, climate change, and health. At 2 cents/KWh, there is ample room to internalize the cost of externalities. Natural gas leaks across its chain of extraction, transportation and distribution.- Fracking casements leak! Cement casements cannot hold methane and other constituents of natural gas across geological layers without defying the laws of physics — see Cornell's professor Ingraffea work on this topic.

- The Environmental Defense Fund's model shows that 3.2% leak rates of methane make fracked gas as bad as coal when it comes to climate change. Yet recent NOAA & NASA publications and most peer-reviewed research points to leakage rates ranging from 4% to 8%.

- Furthermore, the EDF model is based on a 100-year horizon. Methane dissipates from the atmosphere over time, and this 100-year horizon shifts the math in favor of gas. Yet Climate Change science estimates the catastrophic turning point of 2 C rise is 22 years away, not 100 years. 22 years is likely the most pertinent horizon. On a 100-year horizon, a lbs of methane as 25 times more potent than 1 lbs of CO2. On a 20-year horizon, it is 72 times more potent. At this 22-year horizon, 1.5% to 2% leak rates make fracked gas as bad as coal for climate change. Again, current leak rate measurements are at 2 to 6-fold this threshold In Conclusion, because fracked gas is experiencing enormous growth, because fracked gas is worst than coal for climate change, and because cheap fracked gas can easily internalize the cost of its externalities, it is key that methane/CO2 equivalence be properly considered by the EPA, and that fracking be included in the application of the new carbon regulations. I leave you on this quote from Randy Udall, founder of the peak Coal Institute and brother of Senator Mark Udall. "we'll know we are serious about climate change when we stop talking about carbon and start talking about methane"