[Washington, D.C.] Ted Cromwell, Senior Principal for Environmental Policy, gave the following statement at the Environmental Protection Agency’s (EPA) listening session on reducing carbon dioxide emissions from existing power plants.
Thank you. I represent the National Rural Electric Cooperative Association – NRECA.
NRECA represents more than 900 not-for-profit rural electric utilities that provide service to about 42 million people in 47 states. Co-ops are private, consumer-owned utilities and they generate 5% and sell around 11% of the nation’s power. Residential customers account for almost 60% of co-ops’s power sales. Their average annual income is $8,000 lower than the rest of the nation. These customers are also the co-op owners and they will foot the bill for EPA’s regulation.
This is why co-ops are working to ensure EPA follows their legal mandate to set a facility’s emission limit for carbon dioxide based upon what that facility can achieve using adequately demonstrated technology.
Given the limited control technologies available for carbon dioxide, we want to be sure that EPA does not construe their 111(d) authority under the guise of providing added flexibility. We support flexibility, but that flexibility has to be applied correctly through the individual state programs and based upon emission limits for each generating facility.
In 2012, 70% of co-op power generation and 57% of all power sold to our consumer-owners was from coal – so we have much at stake.
Why so much coal? Federal mandates.
Between 1975 and 1987, Congress banned natural gas use for electricity generation under the Oil Embargo and Fuel Use Act. Co-ops built 70% of our coal-fired plants during that period. They installed state of the art pollution controls on the plants and they’ve continued to upgrade and meet new environmental obligations. EPA simply cannot ignore the remaining useful life of these plants, or the repayment of loans that are outstanding on these facilities. And Co-ops can’t afford another Federal program ban on a reliable energy source.
Co-ops have also taken action. We diversified by adding natural gas over the past 20 years and over 5,000 MW of renewable resources in the past 10 years – equal to 20% of our coal-fired capacity.
To summarize, EPA needs to craft a rule where emission limits are set based on what each facility can achieve and state-wide limits are based on the aggregate of emission limits from those facilities. Once these limits are set, states can consider flexibility in how they achieve the emission reductions.
NRECA looks forward to working with EPA to establish a 111(d) program that recognizes the unique characteristics of electric co-ops and allow these co-ops to continue providing affordable, reliable electric power for our consumer-members.
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