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 plantretirements 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 calculationwhen 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 ourcustomers 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