SCOTT WALKER OFFICE OF THE GOVERNOR P.O. Box 7863 STATE OF WISCONSIN MabisoN, WI53707 May 21, 2015 ‘The Honorable Barack Obama President of the United States The White House 1600 Permsylvania Avenue, NW Washington, DC 20500 Dear Mr. Pr ident, As you are aware, the Environmental Protection Agency's (EPA) Clean Power Plan seeks to reduce carbon dioxide emissions from existing power plants and a final rule is expected this summer. The State of Wisconsin has deep concerns regarding our ability to develop a state plan to comply with the proposal. The proposed rule is riddled with inaccuracies, questionable assumptions and deficiencies that make the development of a responsible state plan unworkable for Wisconsin. One of the most troubling aspects of the proposal is that the EPA does not recognize the $10.5 billion investment made by Wisconsin utilities, businesses and consumers over the past decade that has dramatically reduced carbon emissions and increased energy efficiency. ‘This investment has resulted in 10 million tons of avoided carbon dioxide emissions ~ a 20% reduction since 2005. Rather than applaud this good work, the EPA proposal perversely penalizes our state for its past efforts. Setting aside the failings of the rule making process, the biggest concern with the proposed plan is the staggering costs it would inflict on Wisconsin’s families and businesses, The Public Service Commission of Wisconsin (PSCW) has estimated the cost of compliance with the proposal to be $3.3 to $13.4 billion for Wisconsin alone, ‘The PSCW is predicting at least a 29% increase in electricity rates. Such an increase would be very difficult for many Wisconsin families to absorb, but also nearly fatal for our energy-intensive manufacturers already operating on tight margins. There is no question in my mind that significant job loss will be a byproduct of this rule if itis not withdrawn or corrected. In addition to the technical flaws contained in the proposal, Wisconsin has also identified several legal concerns that we believe must be remedied in the final rule, These concerns range from the EPA's authority to promulgate the rule under Section 11.1(d) of the Clean Air Act to the EPA exceeding its authority by regulating beyond stationary sources and attempting to regulate the entire electric generating system. FISCONSIN IS OPEN FOR BUSINESS: WWW.MISGOV.STATE,WILUS * (608) 266-1212 « Fax: (608) 267-8983,Absent significant and meaningful changes in the final rule, itis difficult to envision how Wisconsin can responsibly construct a state plan that can comply with the requirements of the Clean Power Plan without ignoring our responsibility to ensure safe, affordable and reliable electricity for the people of Wisconsin. WISCONSIN IS OPEN FOR BUSINESS \WWW.WISGOV.STATE.WLUS + (608) 266-1212 + Fax: (608)267-8983