My name is Michael Hutcheson and I am an environmental engineer for 

Ameren Corporation. Ameren Corporation is a public utility holding 

company with electric and gas utility operating subsidiaries serving over 

3 million customers in Missouri and Illinois. 

Ameren believes the proposed rule is legally and technically flawed, will 

result in significant cost increases to our customers and businesses, 

cause job losses and damage the economy. However, before I discuss 

our concerns, I will describe what Ameren has been doing to protect 

the environment, and our plans going forward. 

For many years Ameren has been taking steps to reduce emissions with 

the goal of transitioning our fleet to a cleaner more diverse portfolio. 

We have installed scrubbers and other pollution control devices, 

improved unit efficiency, converted landfill gas to energy, contracted 

for wind power, expanded our nuclear capacity, promoted and are 

installing solar power, increased hydro capacity and implemented 

significant energy efficiency programs in both Illinois and Missouri. We 

have made progress in reducing our carbon footprint, and are executing 

a 20-year plan designed to reduce emissions even further in a 

responsible manner. Our plan involves adding more renewables and 

combined cycle natural gas, increasing energy efficiency, retiring coal 

plants at the end of their useful lives and replacing them with cleaner 

resources, as well as retaining options for greater levels of nuclear 

generation. Our plan can achieve a 30% reduction from 2005 emission 

levels over a slightly longer timeframe at a cost to consumers that we 

currently estimate at nearly 4 billion dollars lower than the cost of 

EPA's proposed rule for Ameren customers alone. 
Turning now to EPA's proposal, Ameren recommends that EPA define 

and limit the emission standards based solely on what is achievable at 

existing power plants. States should then be given the flexibility to 

develop any programs that achieve an equivalent emissions reduction. 

If EPA rejects this proposal, numerous other changes should be made. I 

will highlight a couple of them now. 

First and foremost, EPA should eliminate the aggressive interim goals 

that start in 2020. Failure to make this adjustment will cost Ameren 

customers nearly $2 billion dollars by 2020. We recommend you 

replace the interim requirements with a directive to states to develop 

non-binding emission reduction milestones that are reasonably 

achievable and reflect the state's view of the appropriate glide path to 

the final state reduction goal. This single action will greatly reduce the 

cost of the rule and will provide greater flexibility to the states. We 

also believe the target compliance date should not be set in stone at 

2030. Rather, states should be given the flexibility to extend the date in 

order to allow the orderly transition of generation fleets. This will help 

mitigate the potential for reliability concerns and rate shock, which 

would be particularly harmful to our fixed and low income customers. 

For Ameren, the compliance date would be 2035, yet significant 

reductions would occur prior to that time. These changes would save 

Ameren's customers nearly $4 billion dollars when compared to the 

proposed EPA rule and still achieve similar GHG reductions. 

Ameren also believes the rule will not properly credit coal plant 

retirements that are not replaced with new generation under a ratebased compliance program. It is assumed that under a rate-based 

program, both the emissions of CO2 and the MWhs generated from 

retired coal plants are removed from the emission rate calculation 
when determining compliance. This approach does not properly reflect 

the emission reduction gained because it produces only a minor 

reduction in the overall emission rate. In order to properly reflect the 

benefits of coal plant retirements, these units should be treated as 

zero-emitting units whereby the associated MWhs remain in the 

denominator, similar to the treatment of energy efficiency. 

In addition, Ameren believes the rule suffers from over-aggressive 

assumptions about the reduction potential in each of the four building 

blocks contained in the rule. However, I will focus on just two of them. 

With respect to building block three, the level of renewable generation 

assumed is excessive because it assumes Coops and Munis in both 

Missouri and Illinois must comply with the relevant Renewable Energy 

Standards ("RES")—but they do not. Moreover, the Missouri and 

Illinois RES programs contain rate impact caps of one and two percent, 

respectively. Thus, the rule should, but does not respect state RES 

programs. 

Finally, with respect to building block four, the proposed rule 

overestimates the amount of energy efficiency available. Moreover, 

each state has methods to determine the cost-effectiveness of energy 

efficiency, as well as methods for verifying the levels of reduction that 

should be, but are not respected by the rule. Additionally, companies 

can offer a full menu of efficiency programs, but if the end user does 

not implement them the efficiency targets will not be reached. Thus, 

the proposed rule does not respect existing state efficiency and 

demand response rules. 

In conclusion, Ameren believes the proposed rule is legally and 

technically flawed, will result in significant cost increases to our 
customers and businesses, cause job losses and damage the economy. 

We will be filing comments which will provide greater detail on all 

issues of concern and we urge EPA to read them carefully and give due 

consideration. 

Thank you