Submitted Testimony by Fredrick D.

Peabody Energy Senior Vice President of Government Relations
U.S. Environmental Protection Agency Clean Power Plan Proposed Rule
Washington, D.C.

Docket ID No. EPA-HQ-OAR-2013-0602

July 29, 2014

Peabody Energy
701 Market St.
St. Louis, MO 63101


My name is Fred Palmer. I am Senior Vice President for Government
Relations at Peabody Energy. Thank you for allowing me to submit

Using coal for electricity enables people to live longer and better and
drives the lowest U.S. electricity costs for any major fuel.

Peabody has a profound disagreement with EPA’s approach on carbon
under the Clean Air Act. We are opposed to any proposal that would
punish electricity consumers, have no material benefit under climate
theory and act outside the bounds of the law.

This proposal must be withdrawn.

Access to clean, affordable energy is essential at a time when a record
115 million Americans qualify for energy assistance
and 48 million
Americans live in poverty.

Last week the Washington Post put a face on this very real daily struggle. It
brought to light the story of a single mother of five children from Pueblo,
Colorado, struggling to pay for power.”

And I quote:

“Why do you need to turn the lights off?” Sharon Garcia asks her son.

“Because otherwise there’s no money,” he replies.

“And when there’s no money?”… “You can’t feed us…”

No matter how deep she rations, Sharon can’t get ahead of rising costs. A
major cause of the state’s increase in energy costs is attributed to the
shutdown of coal plants and an aggressive transition to renewables.

U.S. Energy Information Administration, March 2014.
U.S. Department of Health and Human Services, LIHEAP Home Energy Notebook, September 2011;
U.S. Department of Commerce, U.S. Census Bureau.
U.S. Department of Commerce, U.S. Census Bureau, 2014.
The Cost of Climate Change: How Not to Shut Down Coal Plants, Washington Post, July 24, 2014.

Yet perhaps the most extreme and disturbing example is California, a state
the EPA lauds as its energy model. California has exacerbated energy
inequality and turned away business based on high renewable mandates
and energy taxes.

California power prices are 40% higher than the U.S. average,
are exiting at a 3:1 ratio, and 700,000 manufacturing jobs have been lost
since 2000.
Is this really our model?

EPA’s proposal is symbolic at best and would have no significant benefit
under climate theory. An entire shutdown of America’s coal fleet – which is
not proposed – would result in a 1/20
of one degree temperature change.

EPA also shows deep misunderstanding about the relationship of states to
the federal government under the Clean Air Act.

The proposal is outside the bounds of law and, if finalized, is likely to be
heavily litigated. Widespread opposition is evident by actions in the
people’s House, opposition in the U.S. Senate and state legislative actions.

 In mid-July, the House Appropriations Committee passed a spending
bill prohibiting EPA from using funds for carbon standards.

 In March, the House passed Whitfield-Manchin to repeal the
proposed new source rule and stop 111(d) without Congressional

 Forty-one Republican Senators have asked EPA to withdraw the rule,
and seven Democratic Senators have written the President about
new plant standards.

U.S. EIA, 2013 data March 2014. Average retail electricity prices per kWh.
U.S. Department of Labor, Bureau of Labor Statistics, “Manufacturing Jobs, California.”
American Coalition for Clean Coal Electricity, “’Climate Effects’ of Carbon Regulations for the U.S. Electric Sector,”
May 2014.

H.R. 3826 prohibits a 111(d) rule or guideline for existing facilities from taking effect unless Congress has passed a
separate law setting an effective date.

 Over 20 states passed legislation or resolutions stating greenhouse
gas emissions can only be regulated on a plant-by-plant basis “inside
the fence.”

 Citizen and business groups are activating, led by the Partnership for a
Better Energy Future, a business coalition representing 80% of the
U.S. economy.

Peabody proposes a better path that calls for investing in efficiency
improvements; deploying advanced supercritical coal plants and supporting
greater R&D toward next generation technologies, including carbon capture
and storage.

More and more nations are pushing back against flawed carbon policies.
Australia’s Prime Minister called the former carbon tax a “useless,
destructive tax, which damaged jobs, hurt families’ cost of living and didn’t
actually help the environment.”

Japan has stepped up support for coal fueled power plants both
domestically and overseas, saying it would rather break a promise than
its economy.

We must reject the Administration’s harmful carbon proposal and put in
place a technology path for long-term improvement in carbon emissions.
This is a far better path for a clean, secure energy future.

Thank you.

Australia Becomes First Developed Nation to Repeal Carbon Tax, Wall Street Journal, July 17, 2014.

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