http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/maines-rule-to-implement-rggi-the-regional-program-to-cut-power-plant-pollution http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/maines-rule-to-implement-rggi-the-regional-program-to-cut-power-plant-pollution Wed, 26 Sep 2007 13:50:04 -0500 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/statement-of-support-for-the-stetson-wind-project The organizations of the Maine Global Warming Action Coalition, listed above, have joined together to support a strong and effective global warming action plan for the state of Maine. We are committed to advocating for the implementation of solutions to global warming here in Maine on behalf of our constituencies, and the people of Maine as a whole. Global warming is real and there is scientific consensus that burning fossil fuels, an unsustainable process, is a major contributor. Global warming is expected to have negative impacts on Maine including, but not limited to: • Sea-level rise may endanger economic activities, coastal communities, tourism, ecosystems and endangered species; • Losses to spruce-fir forests, and losses to alpine and sub-alpine zones, driven by new climate and new parasites, and the associated economic and wildlife impacts; • Public health consequences: increasing incidence of insect-born diseases and a rising number of poor air quality days, coupled with Maine’s already high asthma rates; and • Potentially serious effects on winter recreation. Maine needs a comprehensive policy to curb its global warming pollution. In 2001, the Governor set a target of returning to 1990 levels of atmospheric CO2 by 2010, yet Maine’s emissions have grown 20% since that time. If we further delay taking action to reduce emissions we risk not being able to stop the most serious effects of global warming. Global warming pollution from power plants accounts for approximately one quarter of total emissions in the region. Mining, drilling, processing, transporting and burning fossil fuels, which account for two thirds of our power, impose significant harmful effects on our health and on the environment. In concert with an effective commitment to use power more responsibly, a significant shift to clean, renewable electricity is an essential component to our energy strategy. Wind power is currently the most technologically and economically viable source of new renewable power in Maine. Every source of generating power has environmental impacts; however, the status quo is unacceptably harmful. When sited appropriately, when conflicts with sensitive ecological and recreational resources are minimized, we support construction of wind power projects in Maine. The project’s developers have worked hard to substantially reduce risks the project posed to wildlife and natural areas. Operation of the Stetson project will avoid significant amounts of global warming pollution and help protect Maine from climate disruption. For these reasons, the Maine Global Warming Action Coalition urges the Maine Land Use Regulation Commission to approve the Stetson permit application. Members of the Coalition American Lung Association of Maine * Conservation Law Foundation * http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/statement-of-support-for-the-stetson-wind-project Wed, 12 Sep 2007 16:03:18 -0500 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/ld-1851-an-act-to-establish-the-regional-greenhouse-gas-initiative-act-of-2007 I would like to thank Chairman John Martin, Chairman Phil Bartlett, Chairman Ted Koffman, Chairman Larry Bliss and distinguished members of the Natural Resources and Utilities and Energy Committees for the chance to testify in favor of LD 1851, An Act to Establish the Regional Greenhouse Gas Initiative Act of 2007. Environment Maine is a statewide environmental group advocating clean air, clean water and open spaces on behalf of over 3,500 members statewide. The historic agreement between the Northeast states embodied in the Regional Greenhouse Gas Initiative (RGGI) is important for many reasons, starting with the reductions in global warming pollution from power plants. Although global warming is a huge problem, the banding together of the Northeast states has meant the program will address a significant contribution of the United States’ total global warming emissions. Starting with the power sector, one of the biggest sources of global warming pollution in the Northeast, and the biggest source in the country, means that these states from Maryland north to Maine will be tackling a big chunk of the problem. According to Environment Maine Research & Policy Center’s recent report, The Carbon Boom, the states of Maryland, Delaware, New Jersey, New York, Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire and Maine released 625.4 million metric tons of CO2 equivalent in the year 2004, an increase from 577.3 in 1990. This ranks our ten-state region seventh in the world for total global warming emissions, beating out Canada and the United Kingdom. The increased global warming pollution from power plants over this period of time accounted for about 37 percent of the total global warming pollution increase. This clearly debunks the arguments of some detractors of RGGI who claim that Maine contributes little to the problem of global warming, or how little this agreement will deal with the emissions of the United States. The RGGI region is a big contributor of global warming emissions, and by joining the group, Maine is helping put more pressure on other states to join, cut emissions or join other alliances in their region. The Northeast RGGI agreement has also set the tone for other regional efforts, and stimulated other governors to band together to tackle emissions of global warming pollution. Governors of both the West Coast, and the Rocky Mountain West are developing collaborations inspired by and pressured by the action of the Northeast under RGGI. Meanwhile, the Northeast states’ agreement is also helping drive Congress to act. Implementing RGGI here in Maine will have positive repercussions beyond our state and beyond our region. I would like to reiterate Environment Maine’s support of LD 1851 and the implementation of RGGI here in Maine, and thank the committees for the opportunity to speak. http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/ld-1851-an-act-to-establish-the-regional-greenhouse-gas-initiative-act-of-2007 Wed, 12 Sep 2007 15:57:21 -0500 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/comments-on-the-rggi-model-rule The RGGI Model Rule, if designed to ensure meaningful reductions from the power sector, will set an important precedent and will show that the region is committed to begin reducing emissions from one important source of greenhouse gas emissions. Since the emission reductions envisioned by the program are quite modest (10% reduction from 2009 levels by 2019), it is critically important that the program maximize reductions from global warming emission sources in the power sector as was envisioned in the original principles established at the beginning of the process: “The program shall start simply and develop over time. The initial phase of the cap-and-trade program will entail the allocation and trading of carbon dioxide allowances to and by sources in the power sector only. In a subsequent phase of the program, states and stakeholders will work together to develop reliable protocols for offsets (i.e., creditable reductions outside the power sector) that may be used to achieve compliance with the cap. States may be able to achieve greater emissions reductions as the number of sources covered and the variety of compliance options increases, thereby reducing compliance costs” Regional Greenhouse Gas Initiative (RGGI) - Goals & Guiding Principles Unfortunately, the draft model rule threatens to violate these key principles on several counts. In order to uphold the promise made by the Northeast Governors nearly three years ago substantial changes must be made. The number of “flexibility” mechanisms in the draft model rule makes the program anything but simple. Two-thirds of the text of the model rule is devoted to ways in which generators can avoid reducing CO2 emissions from power plants. It is not difficult to envision a scenario in which the liberal use of offsets exacerbated by low safety valves, the erosion of the cap due to exemptions, and a failure to address the potential for leakage combine to form a “perfect storm” that would allow increases in carbon dioxide emissions from sources covered under this program. The draft model rule must be modified to, a) ensure the stringency of the cap, b) ensure that the use of offsets to meet the modest reductions in this program is limited, c) explicitly include the five criteria (real, additional, quantifiable, permanent and enforceable), and d) include language that directs environmental regulators to, at a minimum, do the appropriate data collection to enable them to cooperate with other agencies to address the potential for leakage. Failure to do so will reduce RGGI to little more than a symbolic exercise. Stringency of the Cap We are very concerned that some of the flexibility mechanisms and design elements in the model rule will further inflate the cap and make the program less effective at reducing the region’s greenhouse gas emissions. The current model rule already sets the initial cap at a level higher than current levels. Any further erosion of the cap is unwarranted. The states should limit exemptions and loopholes by: 1) Not exempting the behind the meter generation of large industrial power generators. This is a power sector carbon cap and the program should cover all sources that would otherwise be eligible for the program. This is of particular concern since we believe that some behind the meter facilities were included in the inventory that led to the development of the cap levels. Either way, all fossil burning electric generating units should be included. 2) Ensuring that the fossil portion of a plant that also burns biomass remains regulated. The current proposal, establishing an arbitrary threshold of 50% under which a plant would not be covered, should be rejected. 3) Ensuring that early reductions do not inflate the cap and that facilities do not get credit for early reductions occurring as a result of enforcement orders or settlements that occurred prior to the finalization of the model rule. Only actual reductions, rather than the purchasing of offsets, should be eligible for early reduction credits. 4) Revisiting the safety valve trigger at its current level. At worst, the safety valve could erode or suspend the cap. And, at a minimum, it will undermine the ability of the program to force the kinds of investments necessary to make the energy transition we must make to begin reducing global warming pollution from the power sector. Offsets To meet the modest reductions (10% by 2019) required by the first phase of RGGI, significant offsets are not called for. Offsets should be limited to keep focus on real reductions from CO2 emitting power plants and to keep the program from being too cumbersome. For the public to have confidence in offsets it must be shown that the pollution avoided or reduced by offsets is real and lasting and that the projects or activities eligible for offsets would not have happened as a result of other factors. Throughout the stakeholder process we had been assured by state officials that any offsets program would be bound by the so-called five point test (real, surplus, verifiable, permanent, and enforceable) with language that is similar to that included in the Massachusetts 310 CMR 7.29 regulations. We were pleased to see that the MOU contained the following language: “at a minimum, eligible offsets shall consist of actions that are real, surplus, verifiable, permanent and enforceable”. We were surprised and disappointed not to see this same language in the model rule. These criteria must be clearly spelled out in the model rule for the public to have confidence that any offsets used in the RGGI program are equal to on-system emissions reductions, and to ensure our support for the program. Offsets must not cause collateral damage or risks to the environment or public health. The final model rule should have explicit language to ensures that “offsets do not support projects or activities that pose a significant risk to public health, public safety or the environment”. All five proposed offset categories will need rigorous accounting to ensure credit only for the extent that the offset overcomes a genuine market or financial barrier, and to discount for any “leakage” of emission reductions to other locations. Developing and implementing accounting standards will be time- and resource-intensive, with no guarantee of accuracy. Two of the offsets categories should be rejected by the state working group; the fossil fuel efficiency category and the SF6 category. The fossil fuel efficiency category should be rejected for many of the same reasons that the natural gas infrastructure category was held in reserve. The challenges associated with quantifying the reductions are great. But, more importantly building energy efficiency outside of the electric sector can be achieved at much lower cost to society through other mechanisms and policies. The proposed criteria for inclusion of SF6 offsets under RGGI reward bad actors who have failed to adequately reduce their emissions of SF6 in the past. Under the proposal, to qualify for an offset, the SF6 reduction measure cannot be part of a “previously established” SF6 reduction effort. Such a distinction is necessary to meet the “additionality” requirement, since projects that began prior to the application for an offset should never receive consideration for offset credit. However, this distinction, in effect, penalizes utilities that have made good-faith, voluntary efforts to reduce SF6 emissions in the past by allowing their competitors to receive a greater amount of offsets. Consumer Allocation & Strategic Energy Purposes 100% of the allowances should be allocated to consumers. There is ample evidence that the model rule establishes unjustifiably low minimum percentages for the consumer allocation. We have seen no credible refutation of the data presented throughout the RGGI process which shows that there will be significant windfalls to generators at the direct expense of consumers unless the predominant share of allowances is reserved for consumers. To the extent that the final model rule does not allocate all allowances to consumers, it should make clear that the percentage reserved for consumers is a minimum which each state is free to raise, and that the percentage allocated to consumers should increase over time. We also have serious questions about the scope of the strategic energy purposes provision in the allocations section. There must be much better definition of this term. At a minimum, we recommend that the model rule clarify that all of the “consumer benefit or strategic energy purpose” allowance value must be used to: (1) reduce the costs of the RGGI program to the state’s electricity ratepayers; (2) provide additional benefits for activities or projects that would not have occurred anyway and not replace existing programs or investments; and (3) support programs and activities that do not pose a significant risk to human health and the environment. Leakage “Leakage” has the potential to undermine the integrity of the RGGI program, by leading to increases in dirty power outside the region which could offset reductions achieved within the region. The states will need to develop a policy which ensures that the RGGI program reduces emission from in-region power plants and places the same requirements on imported power from outside the region, leading to net reductions in emissions associated with electric power use to achieve the 10% by 2018 target. At a minimum, the model rule should direct environmental agencies to do the gathering and sharing of data that is necessary to assist other agencies that might be called on to ensure that the program results in a net reduction of emissions. In conclusion, we appreciate all hard work that has gone into this effort so far and the opportunity to have participated in the stakeholder process. We stand ready to work with you to achieve the objective of reducing global warming emissions from the power sector in the Northeast and to set a precedent for the nation to follow. http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/comments-on-the-rggi-model-rule Wed, 12 Sep 2007 16:01:27 -0500 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/chapter-127-new-motor-vehicle-emission-standards-regulation-green-house-gas-vehicle-emission-standards-public-hearing-record Dear Director Brooks, Environment Maine Research & Policy Center would like to thank the Baldacci Administration and the Department of Environmental Protection (DEP) for proposing the adoption of the next piece in the clean cars program. We strongly support the Department’s proposal to adopt global warming vehicle emission standards as a key piece of Maine’s clean air and global warming reduction strategies. The global warming emissions standards before the Board of Environmental Protection (BEP) are the next step for keeping Maine on track to clean our air and reduce global warming pollution. Maine and eight other states have already adopted strong standards for tailpipe pollution and this program will allow our state to continue to reduce air pollution and global warming pollution. Auto emissions threaten our environment; automobiles are the largest single source of global warming pollution in Maine. Global warming has the potential to totally change the ecosystems of our state. We have already started to see its effects, with a severe drought three summers ago, a 3.4 degree increase in the average temperature in Auburn and a slowly rising sea level. Maple syrup production has decreased in the region and the trend will continue if the winters are warmer or drier. The ski industry has to rely more on snowmaking to provide reliable cover on the slopes. To our south in Connecticut, Rhode Island and Massachusetts, recent research points to increased water temperatures as the cause of the shell disease and abrupt decline in the lobster population. Global warming-induced changes in Maine’s climate would alter our state’s environment, cultural heritage and economy. Enacting global warming emission standards for vehicles would provide the second largest reduction in global warming pollution, according to policy rankings in A Climate Action Plan for Maine. This option has a cost savings of $48 per metric ton of CO2 reduced, ranking as the seventh most cost effective policy. In fact, it is likely that the savings for Maine and vehicle owners now would be even higher, considering the recent increase in gasoline prices. The technology to make cleaner cars is here. Various technologies currently available enable gasoline vehicles and hybrid gas-electric vehicles to easily meet the global warming emission standards. The current generation of hybrid-electric vehicles—such as the Toyota Prius and the Honda Civic—are approximately 90 percent cleaner than the average vehicle in Maine today. Not only are these vehicles much cleaner than conventional vehicles, but also they are approximately 30 percent more efficient at using gasoline. The five model-year 2005 hybrid-electric vehicles (Toyota Prius, Honda Insight, Civic and Accord, and Ford Escape) achieved an average EPA-rated fuel economy of 46.6 miles per gallon —significantly more than the nearest gasoline-powered vehicle. Consumers are buying cleaner cars faster than they can be shipped to Maine. Auto dealers in Maine report that they have a waiting list for certain hybrids between four and eight months long. Often, people looking to buy a hybrid settle for some other car because they cannot wait for a hybrid to become available. There is plenty of circumstantial evidence about the high demand for hybrids, such as consumers who do not attempt to bargain the price down and simply sign up at list price, and car manufacturers that do not have to offer special deals to sell these vehicles. Auto manufacturers are producing even more hybrid models to choose from. In addition to the seven hybrids already available – the Toyota Prius and Highlander, Lexus RX 400h, the Honda Insight, Accord and Civic, and the Ford Escape – consumers will be able to purchase a number of different hybrid vehicles in upcoming years, including the Toyota Sienna, Dodge Ram, Saturn VUE, and Nissan Altima. Also, vehicles are now available in which components of hybrid technology—such as idle shut-off and regenerative braking—are employed to add to the vehicle’s performance and reduce emissions. The GM Silverado, for example, uses these technologies to provide power to four 110 volt outlets and cuts global warming emissions by about 10 percent. Hybrids are not the only vehicles with cleaner technology; conventional gasoline vehicles can cut global warming emissions with a host of available technology. These technologies include: • variable valve timing, installed in most Toyotas and the Ford F-150, which improves air/gasoline mix for better combustion by permitting different valve compression times; • cylinder deactivation, used in Dodge Hemi v8 and GM Vortec v8 engines, which allows half of the cylinders to stop firing when the engine is not accelerating; • turbocharged engines, mounted in most Saabs, Volvos and some Chryslers, which enable drivers to get better performance and acceleration out of smaller engines; • five- or six-speed automatic transmissions, in most Audis and some BMWs and Chryslers, which increse gearing choices and allow the engine to work closer to its optimal speed; • continuously variable transmissions, in the Saturn Ion and Vue, and Nissan Murano, which provide infinite choices of “speeds” using belts instead of gears and optimize engine speed; • automatic shift manual transmissions, available in most Subarus, which eliminate the loss of energy from mechanically shifting gears as you would in a standard manual transmission; • integrated starter generators, in all hybrids and the GM Silverado and Sierra, which can start the engine instantaneously so the engine does not have to idle when the car is stopped; • 42 volt electrical systems, available in the Toyota Crown Royal and some hybrids, which run integrated starter generators and reduce engine load from air conditioners and other systems; • low-leakage air conditioning units, which eliminate leakage of refrigerants such as HFC-134a, thought to be 1000 times more potent a global warming gas than carbon dioxide. The fact that these technologies are available in mass-produced vehicles currently on Maine’s car lots undermines the auto manufacturers’ claim that these vehicles are impossible or too expensive to build. To meet the standards of reducing emissions by about 22 percent by 2012, a car manufacturer might only have to install two or three of the technologies listed above. According to the California Air Resources Board, the average retail price increase for passenger cars and light trucks would be $367 for the 2012 standard and $1064 for the 2016 standard, compared to the 2009 baseline vehicle. For large trucks and SUVs the average price increase is estimated to be $277 in 2012 and $1029 in 2016. This modest increase in cost is expected to be more than offset by operating cost savings in three years. In addition, there are new technologies being designed and tested to further decrease emissions and boost engine performance. In April of this year, automakers signed an agreement with the Canadian government to cut vehicle global warming emissions to levels similar to those called for in the Chapter 127 standards. In the Memorandum of Agreement with Canada, automakers agreed to use technologies, which they claim are too expensive or infeasible to use in cars sold in the U.S., in order to cut global warming pollution from cars and light trucks in 2007. Similar agreements are in place in the European Union. Despite the availability of the global warming pollution-reducing technology, agreements with other countries to reduce emissions and the widespread public popularity of cleaner vehicles, most automakers are dragging their feet and fighting laws to reduce vehicle emissions. Automakers are needlessly suing California for regulating global warming emissions from cars, using tactics similar to those they used in fighting catalytic converters and air bags. At the public hearing, lobbyists representing some automakers and auto dealers made a number of misleading statements that are in direct conflict with factual evidence. Primarily, the arguments of the auto industry lobbyists were based on the false claims of insignificant reductions in air pollution, increased cost of vehicles and decrease in vehicle choice. Both representatives made false claims that these regulations would do nothing to improve air quality or global warming. On the contrary, reducing global warming pollution from cars by 30 percent by 2016 would have a significant impact on Maine’s contribution to global warming. The amount of carbon savings from these standards was estimated to be 933.6 thousand metric tons of carbon dioxide equivalent by 2020, the second largest amount of reductions from a single policy in A Climate Action Plan for Maine. Cars that emit reduced global warming pollution will emit fewer smog-forming pollutants and air toxics. As evidence of this, one only needs to look at the North East States for Coordinated Air Use Management (NESCAUM) analysis of the California emissions standards that reported that 30 percent of the pollution reductions in Vermont could be attributed to the Zero Emission Vehicle (ZEV) standard. The ZEV standard is similar to the global warming emission standards in that both programs require the sale of more hybrid and advanced technology vehicles. The second specious argument employed by the auto industry is that the price of cars will increase drastically, up to $3,000 per vehicle. An analysis by the California Air Resources Board estimates an increase of $1064 in the price of a car in 2016, with a payback of two or three years in lower operating costs at 2005 gasoline prices. Even if cleaner more efficient vehicles stayed at $3,000 more than conventional vehicles in 2016, they would pay for themselves quickly in avoided operating costs. Currently, a Honda Civic Hybrid with manual transmission gets 45 city/ 51 highway miles per gallon and costs about $3,000 more than the conventional manual transmission Honda Civic LX, which gets 40 city/ 48 highway miles per gallon. If gas prices were $3.50 per gallon and the car was driven 15,000 miles per year, a hybrid owner would save money after 6 years. If the past few years are any indication of gasoline prices, one could easily argue that average gasoline prices over the next 5 years might be $5.00 per gallon, letting a Civic Hybrid owner cash in on savings after 4 years. Regardless of gasoline prices, premiums for hybrid vehicles will continue to drop and cleaner conventional vehicles will continue to be close in price to regular vehicles. Another fictitious argument of some automakers and auto dealers is that performance, size and hauling capacity would be limited by these rules. Despite these claims, roomy, sporty and hauling-capable cars and trucks with advanced technologies are currently available and already meet, or nearly meet, the standards. Some of these vehicles include the Saturn Vue, the Nissan Murano, the Ford Escape Hybrid, the Lexus RX400h, the Toyota Highlander, the GM Sierra, the Dodge Magnum and the Honda Accord Hybrid. In an effort to ‘greenwash’ the auto industry’s actions and intentions, their lobbyists asserted that cars are much cleaner, burn less gasoline now than they did before and that fuel economy “has doubled over the last generation of cars.” Although US fleet fuel economy went from 17.7 miles per gallon in 1977 to 24.6 miles per gallon in 1984, current fleet fuel economy is at its lowest since 1984. Also, the representative from the Maine Auto Dealers attempted to undermine the pollution reductions of advanced technology vehicles operated in Maine, inventing that “hybrids do not get good fuel economy on the highway,” and thus Mainers, driving on highways or rural roads would not reduce global warming emissions. This is also untrue: the Honda Accord Hybrid uses cylinder deactivation on the highway, making it run on three cylinders and cutting emissions over city driving. Other standard gasoline vehicles such as the Dodge Magnum use this technology as well, improving highway emissions and efficiency. Finally, opponents alleged that Maine does not need to adopt the standards to remain in the California emissions program and that the state should not adopt a rule that is being held up by an auto industry lawsuit. The opposite is true – Maine is legally bound to adopt this standard before the end of the year to remain consistent with California and retain strong emissions standards. On the second point, an auto industry lawsuit is nothing new, will likely be struck down by the courts and should not keep the state from moving forward. In conclusion, Maine must approve the program by the end of the year to stay on track with other Northeast states and retain strong emissions standards for new cars. Environment Maine encourages the BEP to approve this program for the sake of cleaning our air and slowing global warming. Sincerely, Matthew Davis Advocate http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/chapter-127-new-motor-vehicle-emission-standards-regulation-green-house-gas-vehicle-emission-standards-public-hearing-record Wed, 12 Sep 2007 16:05:06 -0500 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/statement-on-nuclear-energy-and-global-warming As national and local environmental, consumer, and safe energy organizations, we have serious and substantive concerns about nuclear energy. While we are committed to tackling the challenge of global warming, we flatly reject the argument that increased investment in nuclear capacity is an acceptable or necessary solution. Instead we can significantly reduce global warming pollution and save consumers money by increasing energy efficiency and shifting to clean renewable sources of energy. For at least thirty years, the public, policymakers and private investors have viewed nuclear power as uneconomical, unsafe, and unnecessary. As a result no new reactors have been ordered in this country. With respect to these serious concerns, nothing has changed. While we urgently need to reduce our global warming emissions, nuclear power still remains the least attractive, least economic, and least safe avenue to pursue. *Nuclear Power is Unnecessary: We can meet our future electricity needs and reduce global warming pollution without increasing our reliance on nuclear energy. For example, a 2004 study by Synapse Energy Economics found that the US could reduce carbon dioxide emissions from electricity generation by more than 47% by 2025 compared to business as usual and meet projected electricity demand, while saving consumers $36 billion annually. In fact, we can do this while cutting our reliance on nuclear power by nearly half. The states are moving forward with clean energy solutions. Nineteen states have passed renewable electricity standards requiring an increasing percentage of energy to be generated by renewable energy sources. Replicating this effort nationally would increase our ability to reduce global warming emissions, while benefiting public health, consumers and the environment. Several states are working to increase efficiency standards for appliances, while many are working to reduce global warming pollution from cars. The states are demonstrating that there is an effective arsenal of clean energy solutions that can significantly curb our global warming emissions; it is these ideas that we need to draw upon. *Nuclear Power is Too Expensive: The economics of nuclear power remain so unattractive that without additional federal subsidies, no new plants will be built. Despite fifty years and more than $150 billion in federal and state support, the nuclear power industry is still seemingly incapable of building a new plant on its own. In fact, the U.S. DOE’s Energy Information Administration stated in its 2005 Annual Energy Outlook that “new [nuclear] plants are not expected to be economical.” Dominion CEO & Chairman Thomas Capps has stated that: “If you announced you were going to build a new nuclear plant, Moody’s and Standard & Poor’s would assuredly drop your bonds to junk status, hedge funds would be bumping into each other trying to short your stock.” Not surprisingly, private investors have shown such disinterest in supporting new nuclear power plants that the industry is, yet again, at the mercy of federal handouts. Last year, Senator Domenici included extensive federal incentives in his original energy bill, including loan guarantees and power purchase agreements covering up to half the cost of building a new plant, as well as clean air credits and federal lines of credit. Despite this, Standard & Poor’s concluded: “Standard & Poor’s Ratings Services has found that an electric utility with a nuclear exposure has weaker credit than one without and can expect to pay more on the margin for credit. Federal support of construction costs will do little to change that reality. Therefore, were a utility to embark on a new or expanded nuclear endeavor, Standard & Poor’s would likely revisit its rating on the utility.” Due to the lack of private investment, it is the inevitable that any new nuclear construction will result in significant public cost to taxpayers. Between 1950 and1998, the federal government spent 56% of the energy supply research and development on nuclear energy, while only 11% was invested in all renewable technologies. If the federal government is going to spend any money on energy, those dollars should be focused on clean and safe technologies. *Nuclear Energy is Too Dangerous: Nuclear energy has never been safe, but post 9-11 nuclear power plants and radioactive waste storage facilities y have become terrorist targets as well. Al-Qaeda operatives were surveying nuclear power plants as potential terrorist targets; in the post 9-11 world these risks are only elevated. The National Academy of Sciences has raised serious concerns about the safety of irradiated nuclear fuel storage facilities from terrorist attacks in its report entitled “Safety and Security of Spent Nuclear Fuel Storage.” Furthermore, protecting the fuel from terrorists as it is moved to longer term storage facilities, if they are ever built, will be nearly impossible. Reactors in the U.S. are also deteriorating with age and inadequate oversight by the Nuclear Regulatory Commission provides further reason for concern. Just three years ago, for example, a nuclear reactor in Ohio came within one-fifth of an inch of stainless steel from a rupture that would have vented radioactive steam into the reactor’s containment building and could have led to a meltdown. *Nuclear Power is Too Polluting: Beyond operating concerns remains the unsolved and disturbing issue of waste disposal. Some 95% of the radioactivity ever generated in the US is contained in the nation’s civilian high-level atomic waste. Despite almost two decades of pushing to make Yucca Mountain in Nevada the nation’s high-level waste repository, it has not been shown scientifically to be suitable to safely store the waste. The Yucca Mountain project is further thrown into doubt by the recent revelations of the falsification of scientific data by USGS scientists, as well as the court ruling that found EPA’s public health standards for the site to be illegal. No country in the world has solved its nuclear waste problem. It makes little sense to begin building new reactors when we don’t know what to do with the lethal waste from the ones we have. *Using Nuclear Power to Address Climate Change Would Exacerbate the Problems: Major studies, such as those by MIT, agree that using nuclear power to have any significant effect on climate change would require building at least 1,000 new reactors worldwide. This would exacerbate all of the problems of the technology: more terrorist targets, more cost (potentially trillions of dollars), less safety, need for a new Yucca Mountain-sized waste site every 4 or 5 years, more proliferation of nuclear materials and technologies, dozens of new uranium enrichment plants, and even then, a severe shortage of uranium even within this century--while displacing the resources needed to ensure a real solution to the climate change issue. *Conclusion: We believe that the financial and safety risks associated with nuclear power are so grave that nuclear power should not be a part of any solution to address global warming. There is no need to jeopardize our health, safety and economy with increased nuclear power when we have cleaner, cheaper solutions to reduce global warming pollution. Signers to date: National: Center for Health, Environment and Justice, Clean Water Action, Friends of the Earth, Greenpeace, Nuclear Information and Resource Service, Public Citizen, Sierra Club, U.S. Public Interest Research Group (U.S. PIRG) Maine: Matthew Davis, Environment Maine, 39 Exchange St., Ste 301, Portland, ME 04101; Sue Jones, Natural Resources Council of Maine, 2 Wade St, Augusta, ME 04330; Raymond Shadis, Friends of the Coast, Post Office Box 98, Edgecomb, Maine 04556; Saskia Janes, Maine Public Health Association, 11 Parkwood Drive, Augusta, ME 04330; Ed Miller, American Lung Association of Maine, 122 State Street, Augusta, ME 04330; Peter Alexander, New England Coalition, PO Box 545, Brattleboro, VT 05302 http://www.environmentmaine.org/legislature/testimony/oceans-testimony/oceans/statement-on-nuclear-energy-and-global-warming Wed, 12 Sep 2007 15:58:52 -0500