Seventeen nonprofit, consumer-owned public power utilities write President Obama on EPA regulatory actions
September 28, 2011
The President
The White House
1600 Pennsylvania Avenue, N.W.
Washington, D.C. 20500
Re: Impact of EPA regulatory actions on smaller public power utilities
Dear Mr. President:
The undersigned represent a broad cross-section of nonprofit, consumer-owned public power utilities from across the country. We appreciate your leadership in directing the Administrator of EPA to withdraw the draft Ozone National Ambient Air Quality Standards.
We write today to express concern at the pace and stringency of other expanded EPA regulation of our electric generation resources, which more directly jeopardize our ability to provide affordable, reliable electricity. We take pride that emissions from these resources have declined significantly over the last forty years. This progress is the result of EPA, electric utilities, and other stakeholders working together to achieve that decline in a cost effective manner that provided adequate lead time to develop compliance technologies. Unfortunately, that is no longer the case as EPA moves precipitously in a number of rulemaking processes that will impact electric reliability, resource adequacy and impose significant cost on electric consumers.
We believe it is critically important that EPA fully evaluate, through a rigorous and transparent process verified by independent peer review, all of the impacts that may be expected from its entire aggressive regulatory agenda and to assure the public that benefits do in fact exceed costs. We do not see this happening. Asserted costs often fail to comport with our operating experiences. Without greater transparency it is impossible to know whether this results from analytic problems or reflects harsh regional impacts masked by national averages. In any case, cost impacts within our communities will intensify some consumers’ difficult choices between food, shelter, health care, and rapidly rising energy costs.
Our concern is exacerbated by the fact that EPA does not appear to have done a broad and cumulative assessment of the impacts of all of its various rulemakings taken together. We need to understand all of the requirements as well as their impacts before we can undertake prudent planning for cost effective compliance. We believe that EPA also, in the interest of a fair and transparent process, would want to know, and seek broad public input, on the impacts of its entire regulatory agenda on consumers before implementing its agenda.
The speed of EPA regulatory action prevents careful consideration of the impacts. The expectation that the power sector may comply with new requirements in as few as three years is simply not realistic given our operating experience with the lead times necessary to develop and acquire the required hardware for compliance.
We ask that the EPA regulatory process include a full and transparent study, in which all stakeholders and the public have the ability to provide input, of the impacts of the agency’s full power sector regulatory agenda prior to its implementation. We request a fully independent peer review and an open, full public discussion of the EPA regulatory agenda and its costs to consumers.
Sincerely,
Fred D. Clark, Jr.
Alabama Municipal Electric Authority
Montgomery, Alabama
Duane S. Dahlquist
Blue Ridge Power Agency
Danville, Virginia
Barry Moline Dan Hodges
Colorado Association of Municipal Utilities
Colorado Springs, Colorado
Florida Municipal Electric Association
Tallahassee, Florida
Mike McDowell
Heartland Consumers Power District
Madison, South Dakota
Raj G. Rao
Indiana Municipal Power Agency
Carmel, Indiana
Robert Haug
Iowa Association of Municipal Utilities
Ankeny, Iowa
Colin Hansen
Kansas Municipal Utilities
McPherson, Kansas
Austin Carroll
Kentucky Municipal Utilities Association
Frankfort, Kentucky
Jim Weeks
Michigan Municipal Electric Association
Lansing, Michigan
Duncan Kincheloe
Missouri Association of Municipal Utilities
Columbia, Missouri
Geoffrey Wilson
Municipal Energy Agency of Mississippi
Jackson, Mississippi
J. Gary Stauffer
Municipal Energy Agency of Nebraska
Lincoln, Nebraska
Jolene Thompson
Ohio Municipal Electric Association
Columbus, Ohio
Jeffrey Mehlhaff
South Dakota Municipal Electric Association
Ft. Pierre, South Dakota
Ted Rampton
Utah Associated Municipal Power Systems
Salt Lake City, Utah
Larry LaMaack
Wyoming Municipal Power Agency
Lusk, Wyoming
cc: Lisa Jackson, EPA Administrator
Congressional delegations of Alabama, Colorado, Florida, Indiana, Iowa, Kansas, Kentucky, Michigan, Mississippi, Missouri, Nebraska, Ohio, South Dakota, Virginia, Utah, and Wyoming
