Statement of Michael Zehr on behalf of Consumer Energy Alliance
U.S. Environmental Protection Agency Public Hearing:
“Proposed Rule for Carbon Pollution for Existing Electric Generating Units”
July 29, 2014
Washington, DC – My name is Michael Zehr, and I serve as a Vice President for the Consumer Energy Alliance. CEA is a nationwide association made up of both energy consumers and producers working to advance an all-of-the-above energy policy that will lower energy costs for every American.
Access to affordable energy is of utmost importance to our members, because every dollar spent on energy is a dollar that cannot be spent on capital investments, payroll, savings, groceries, or next year’s family vacation. In order to create economic growth, it is important for the government to implement policies that will ensure affordable, reliable energy supplies to America’s families, farms, factories and small businesses.
If finalized as proposed, regulations on existing electric generating units will undoubtedly cause reliability and affordability concerns for many states, particularly those that utilize coal for a large portion of their electricity generation. This is a particularly acute problem for many states in the Midwest and Southeast regions where a majority of states rely on coal-power generation for more than one-third of their electricity needs.
As proposed, these regulations would force states to enact policies which would require utilities and electric cooperatives to prematurely shut down coal-fired power plants – either through the implementation of fuel switching requirements or renewable fuel mandates – which will likely lead to higher electricity prices for energy consumers. Given the nature of our electric grid, abrupt changes in our energy mix – particularly ones that have not been contemplated throughout the development of the grid – will reduce dispatch options and disrupt the fuel diversification that has been critical to low electricity costs.
Additional plant closures will continue to have a real and negative impact on state and local economies. For the most vulnerable among us, including low-income families and seniors living on a fixed budget, higher electricity costs cannot easily be absorbed – in essence, they are a regressive tax.
While natural gas, nuclear, alternative and renewable electricity generation have become a much more important part of the fuel mix over the past several decades and are certainly capable of increasing their contributions to the grid, developing additional capacity from these sources and the necessary infrastructure to realize these expansions will take time and likely come with significant costs to consumers.
We would also like to point out that EPA’s aggressive timeline allows states only one year to develop a very complex plan that will need to address a series of adjustments to their electricity generation, consumption and energy infrastructure that will come from forcing a change in the energy mix.
States have historically been given several years to develop and implement regulations for criteria pollutants that are a tiny fraction of the size and scope of the proposed regulations that we are discussing today.
Forcing through regulations of this magnitude in such a short timeframe will limit the ability of states and stakeholders to thoughtfully prepare for the drastic changes that this rule will cause. If this Administration is comfortable spending more than five years evaluating the Keystone XL pipeline, it should feel comfortable taking its time to craft a thoughtful rule that fully evaluates the consequences of its proposed actions.
At a time when electricity consumption is projected to grow, it is important that government regulations and policies avoid electricity supply disruptions or unnecessary price increases. As EPA considers how to move forward, we urge the Agency to keep electricity consumers in mind and not promulgate rules that would adversely affect business and family budgets.
As a nation, we should strive to have more of all forms of energy, and not simply pit one energy resource against another. We hope that EPA will consider the potential economic impacts on consumers across the nation of these regulations as it takes the next steps in developing these regulations.
Consumer Energy Alliance
Executive Director – Florida
Offices in Jacksonville and Tallahassee
Phone – 904-806-1714