Support of a Reasonable Transition to Cleaner Sources of Energy for South Bend

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• Midwest Cooperative [Michigan] offers LED street lighting rates that reflect lower energy use and higher up -front costs. • Area REMCs- Members of Wabash Valley Power Association [Indiana] offer efficiency incentives for schools and farms, and new - construction programs. E. Coal - fined Generation Although we have seen significant improvement in the quality of our air in the past several decades, generation of coal power does still negatively impact human health and air quality and land and water resources. U.S. EPA measurement protocols identified significant greenhouse gases and toxins from Indiana's coal -fired power plants when compared to other generation facilities, both coal -fired and non -coal. 18,19 The U.S. and Indiana are currently in a period of uncertainty where regulatory action, such as the Clean Power Plan or potential carbon caps, and market forces, such as instability in the mining industry, increase the financial and operational risks of burning coal. We also understand that some coal burned in Indiana power plants is imported from out -of- state. F. Turning Point for I&M and its Customers in South Bend Council recognizes that I &M is legally required to provide reliable and affordable electricity to customers while balancing demands of shareholders, federal and state regulators, and federal and state lawmakers, adapting to regulatory uncertainty, and managing ageing infrastructure and significant past investments. I &M is continually reviewing its generating facilities to produce affordable, reliable and cleaner energy to its customers — including the 2015 retirement of its Tanners Creek coal - fueled plant that was capable of generating 995 megawatts of electricity. Such a review, held in 2015 with public input, included an analysis of options to phase out large portions of its coal generation capacity and replace it with other forms of energy, including renewable sources. According to I &M's integrated resource plan (IRP), partially replacing coal generation with lower- emissions options such as wind, solar, or natural gas could be less expensive than I &M's preferred plan which continues to utilize all current coal -fired assets, 20 requiring the addition of $3 billion in pollution controls. Industry studies suggest that investments in demand -side management are more cost - effective than investments in traditional generation capacity"', however the proposed IRP indicates only 2% of system capacity will be provided by energy efficiency and I &M's investment in its efficiency programs will remain at current levels. 22 18 https: / /iaspub.epa.gov /triexplorer /tri release.facility 19 https : / /gh-qdata.epa.4ov /gh- p /main.do 20 https: / /drive.google.com /file /d /0B37orMi -Cq JWmlBeEdgTldTRFk /view ?usp = sharing 21 http: / /in.gov /iurc/files /ACEEE Attachment G ACEEE Cost of Saved Energy Report.pdf 22 Indiana Michigan Power. (November 2, 2015). Integrated Resource Planning Report to the Indiana Utility Regulatory Commission (Pg. 130, Pg. 50).