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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