Public Comment on the 2nd Draft State Energy Strategy for Georgia
David Kyler, Executive Director
Center for a Sustainable Coast
September 26, 2006
These comments were submitted in writing to the Governor's Energy Policy Council in September 2006 during the Council's review process for the second draft of their State Energy Strategy. Excerpts of these written comments were also read into the record at a public meeting hosted by the Council in Savannah on September 26, 2006.
Background on the Commenter
David Kyler is a veteran environmental
analyst and advocate who has served as a regional planning analyst for
the Coastal Georgia Regional Development Center (1982 - 1996), and is
the founding executive director of the Center for a Sustainable Coast.
The Center is a membership-supported non-profit organization established
in 1997, which is registered in Georgia and serves the state's coastal
region. The mission of the Center is to advance the responsible use and
conservation of coastal Georgia's economic, historic, and natural
resources. The Center's board members, staff, and members support the
use of education, technical assistance, advocacy, and legal action to
improve the refinement and protection of the public interest in issues
related to our mission. Kyler has lived in coastal Georgia since 1977.
Highest Priorities Our highest priorities are to (1) accelerate adoption
and use of environmentally responsible and efficient energy sources,
practices, and technologies, using appropriate incentives such as tax
exemptions, tax credits, public grants and low-interest loans, as well
as pro bono technical expertise, and (2) use state policies to create
strong disincentives for activities in resource extraction, energy
generation, distribution, and use that produce unjustified pollution,
public health risks, and disproportionate adverse impacts on other
resources such as water, land, and air. These energy sources to be
discouraged through public policy include fossil fuels (especially coal)
and nuclear power. We also oppose the exploration and development of
fossil fuels offshore, since the prospective benefits do not justify the
risks to natural resources, both terrestrial and marine, and the many
existing economic benefits that are derived from them, valued in the
billions annually. The vital relationships between our economic
prospects and Georgia's natural resources demand a more systemic,
integrated approach to public policy so that state programs affecting
natural resources, land use, transportation, economic development, and
energy are more consistent and mutually supportive. Our ultimate
objective is to achieve a sustainable environment and economy in
Georgia, based on the rational use of our resources.
Specific Comments
The Governor's Energy Policy Council and GEFA deserve
our thanks for preparing such an exhaustive analysis of Georgia's energy
alternatives and recommending at least some of the foremost strategies
needed to advance the public interest through energy policy.
We are encouraged to see support for energy efficiency and the use of
alternative energy sources that will help reduce adverse environmental
impacts and public health threats caused by energy production,
conversion, and use. In light of the clearly significant problems
linked to the use of fossil fuels and nuclear power, both regionally and
globally, we strongly urge the Council to revise the plan to include
greater incentives for accelerating transition of energy production to
renewable alternatives. At the same time, for various environmental,
political, and economic reasons, we advocate policies that discourage
the expansion in use of both fossil fuels and nuclear power.
We are in the midst of a truly critical period in our use of resources,
and energy policy is at the heart of the momentous need for a transition
away from fossil fuels. Fossil fuels add mightily to the state's burden
of air emissions, and are linked to respiratory illnesses being suffered
by increasing numbers of our citizens, now in the tens of thousands.
Most significantly for the coastal region of our state, use of these
fuels is also a major source of greenhouse gases that are
well-documented as a contributing factor in climate change. Warming
trends brought by this global phenomenon threaten sea level rise that
could have catastrophic impacts on our coast within our lifetime.
At the same time, climate change is widely believed to be the cause of a
long-term trend in the frequency and intensity of coastal storms, which
is a major threat to this region, much of which lies at elevations below
20-feet Mean Sea Level and would be devastated by a major storm surge.
A local hurricane modeling expert estimates that damage here by a storm
of comparable intensity would be equivalent to that suffered in the Gulf
states as a result of Hurricane Katrina last year - some 200 billion
dollars.
Because of the overwhelming importance of these concerns, we favor the
implementation strategies for alternative transportation fuels and
renewable energy sources for electricity and heat described in Chapter 2
of the State Energy Strategy. However, to achieve the accelerated
transition of energy policy that we are recommending, these and other
strategies must be given the highest priority. To attain their benefits
as soon as possible, we also support the proposal to develop a dedicated
funding source for implementing strategies for development and
application of alternative fuels.
Further, we emphasize our special interest in exploring and applying the
use of tidal power, which is noted in the Strategy as an idea for
further consideration. Given that Georgia has one of the highest tidal
amplitudes on the east coast of the nation (an average of about eight
feet), we strongly believe that the potential for harvesting this energy
source has great promise and therefore we underscore the urgent need to
develop it.
Georgia's economic prospects and environmental quality are fundamentally
interconnected and public policy must serve both to be effective.
Because of this, we cannot afford to indiscriminately support
development and exploitation of virtually all energy sources. Not only
would such an approach add further to problems of human health and
environmental stability and quality, but producing excessive amounts of
energy without regard to the consequences of the source or use would
propagate the profligate consumption of energy that has resulted in
Georgia's rate of energy use outpacing the state's population growth
significantly. And overly abundant supplies would work against the very
worthy efforts to achieve higher energy efficiency, as outlined in the
Strategy.
Beyond incentives for businesses and consumers providing or using
renewable and green energy sources (including tax credits, deductions
and exemptions, grants, and low-interest loans), the state should
consider creating a surcharge to be applied to both new and existing
power plants that contribute to air pollution, greenhouse gases, and/or
other adverse environmental effects, including intensive use of water.
The amount of the surcharge should be proportional to the estimated
adverse effects compared with other energy alternatives. Revenues
accumulated from collecting the surcharge should be used to subsidize
the preferred alternatives and to improve protection of air, water and
land-based resources that have been degraded by conventional energy
production and use.
Due to its extensive and well-documented array of objectionable impacts,
from mountaintop removal and stream-bed filling to mercury contamination
in the blood of children, pregnant women, and fish, coal deserves
special scrutiny as an objectionable energy source. To fulfill
Georgia's obligation to act in the public interest of our citizens, the
Energy Policy Council should recommend policies that actively discourage
power producers from using coal, including adoption of strong financial
disincentives intended to minimize and ultimately eliminate coal as a
fuel source used to generate power in our state. The mining and
distribution of coal alone have enormous environmental costs, not to
mention coal combustion, which we should do everything possible to
avoid.
It should also be underscored that there are vital relationships between
water policy and energy policy that MUST be reconciled if Georgia is to
realize a sustainable future that balances economic potential with
environmental quality. As I recently advised a legislative study
committee evaluating desalination, relationships between energy, water,
land use, transportation, and economic development must be more
thoroughly evaluated as they are affected by state policies. For the
legislature to be currently supporting the construction of two nuclear
power plants, with enormous commitments of water needed for cooling, at
the same time state policies are advocating prudent improvements in
water-using efficiencies is in direct conflict with public interest.
Nuclear is the most water-intensive of all power sources per kilowatt
hour, is extravagantly subsidized by federal funding, and poses
virtually permanent threats to public health and safety - due to
handling and storage of radioactive materials as well as potentially
catastrophic impacts linked to human error, operation or equipment
failure, or acts of terrorism.
Finally, we are concerned about the development of fossil fuels offshore
due to the adverse implications of risk to coastal resources, both
terrestrial and marine. As I have commented previously, such risks to
highly valuable and productive natural resources and the thousands of
existing jobs they support cannot be justified for this purpose. This
is especially true given the many more sustainable energy alternatives
available in our state. Moreover, even the most liberal estimates of
offshore reserves will not provide the energy independence and long-term
economic benefits of these new alternatives.
I hope that the Council is willing to clarify and strengthen priorities
within the strategy in a way that reflects the rationale I've outlined.
One of the best ways to do this is to create strong financial incentives
directing investors and consumers toward environmentally responsible
alternatives and away from those that are not. We also urge aggressive
pursuit of foundation support and the use of government grants and
subsidies to improve state energy policy, consistent with the principles
and recommendations I have presented.
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