EPA’s clean power plan needs major rework

Members can send in comments until December 1

BETWEEN NOW AND December 1 of this year, stakeholders and the public have an opportunity to submit comments to the EPA about its proposed rule for carbon dioxide emission limits for existing coal-fired power plants. December 1 is the last day the EPA will accept comments about this onerous rule, called Clean Power Plan (CPP). The agency plans to issue a final rule for CPP in June 2015.

Just as the EPA essentially blocked the construction of new coal-fired power plants with a rule requiring unachievable emission levels, the agency’s Clean Power Plan now seeks to constrain the operation of plants that are currently generating electricity.

These regulations clearly run counter to President Obama’s promise of an “all of the above” energy policy. Their net effect is to push coal out of the energy mix — not include it.

By the EPA’s estimates, the Clean Power Plan will result in 41-49 gigawatts of generating capacity losses within six years. Another 50-60 gigawatts could be lost by 2020 thanks in substantial part to the EPA’s Mercury and Air Toxics Standard (MATS). As much as one-third of the coal-fired power fleet could be shut down by 2040.

We are faced with rules that pose a real threat to Boilermaker jobs, pensions and healthcare. More broadly, EPA rules threaten the reliability of the nation’s energy grid; they threaten hundreds of thousands of well-paying energy-related jobs; and they threaten our economic recovery.

For these reasons — and while the agency’s comment period remains open — I call upon all active and retired Boilermakers and their families to send the EPA a clear message: Fix the Clean Air Plan. We must insist that the EPA change its approach to controlling greenhouse gas emissions so that the power industry is allowed to upgrade their coal-fired plants with the latest emission control technology available on a schedule that is feasible and at a price that is affordable — without forcing plants to shut down prematurely.

Legal challenges to the CPP may ultimately undo the regulation, but we cannot count on that happening. In the meantime, it is imperative that we convey our concerns directly to the EPA.

Proposed rule would have devastating consequences

THE EPA’S PROPOSED rule would slash CO2 emissions from coal-fired plants by 30 percent (based on 2012 baseline levels) by 2030. To achieve this aggressive goal, the agency would rely on states to develop their own approaches, to be approved by the EPA.

The approaches could include “building blocks” such as fuel switching from coal to natural gas and developing more renewable energy.

By some estimates, 52,000 direct jobs in the electric utility, mining, and rail sectors will be put at risk due to the Clean Power Plan. More than 100,000 indirect jobs, including those in affected communities and allied industries, will also be at risk.

We are concerned about the consequences the rule holds for all Americans. Not just the Boilermakers and other trades who maintain, repair and upgrade coal-fueled power generation facilities. Not just the Boilermakers who mine coal in the West. Not just the Boilermakers who repair locomotives that move coal trains. Not just the Boilermakers who forge metal or make cement or manufacture goods — all of which require large, uninterrupted amounts of affordable electricity.

These regulations clearly run counter to President Obama’s promise of an “all of the above” energy policy. Their net effect is to push coal out of the energy mix — not include it.

And not just our friends in the United Mine Workers of America, whose very existence depends on extracting coal.

The consequences of which I write are real and they are disturbing. Americans could see alarming increases in their home electric bills. Power-intensive industries like cement making, steel making and aluminum smelting could see escalating electricity bills threatening their profit margins. Spiking electric bills could pressure industries to cut back, shut down or move their operations overseas, resulting in further job losses and weakening our economy.

All segments of our economy that experience rising electric rates would likely pass those added costs onto the consumer in the form of higher priced goods and services. Across a range of industries, among them power generation and mining, thousands of jobs could be lost — many of them good blue-collar jobs. Smaller communities that rely on power plants for their tax base could be devastated. And power interruptions could threaten wide swaths of our population, especially in the Northeast and Midwest, where electricity from fossil fuels has been a mainstay for many generations.

These dire warnings are not mine alone. They come from many responsible leaders of labor and industry as well as from political leaders at all levels.

CPP places coal at a disadvantage

AS MENTIONED PREVIOUSLY, the CPP offers states a menu of “building blocks” to draw from in order to lower their overall carbon dioxide emissions. These building blocks are largely detrimental to the future of coal.

One such building block is to reduce the output of coal-fired plants in favor of natural gas combined-cycle units — in other words, favor natural gas over coal. There are inherent problems with such a scheme, particularly since fuel prices fluctuate. Decisions on dispatching power according to the fuel source should be left to power providers so the cost of producing electricity is kept in check.

Another such building block is to require efficiency improvements of up to six percent for coal-fired power plants. This requirement does not adequately consider efficiencies that power providers have already paid for, including those who have invested heavily in supercritical and ultra-supercritical units.

The CPP also interferes with programs that are better left to the states, such as renewable energy and energy efficiency. Infringing on programs and practices already in place or being considered removes the flexibility and authority of states to tailor their approaches based on their own needs, abilities, and circumstances.

There are numerous other problems with the CPP as well, including the adequacy of how it calculates grid reliability and the premature implementation of the rule before we even know whether other nations will commit to serious carbons dioxide reductions of their own. If they do not, we are wasting precious resources while providing virtually no net benefit to the climate.

The Brotherhood will continue to challenge EPA emission regulations which hurt our jobs and the industries where we are employed. Our legislative and political efforts have been ongoing and concerted. Lodge leaders, retirees and active members have entered the fight and made our presence known at conferences, through media contacts and at rallies and marches (see related stories in this issue).

In a valiant stand for those who depend on coal mining and coal-fired power, our own IVP Dave Haggerty joined in an act of civil disobedience during a July 31 sit-down with Mine Workers President Cecil Roberts and other UMWA leaders in Pittsburgh. The willingness of these leaders to face arrest served as an inspiration to the thousands of union members who participated in the march.

It is at times such as these that the meaning and the purpose of unionism are strongest. Brothers and Sisters, I respectfully ask that you do your part in this important work, that you add your voice and make your feelings known to the EPA. Tell them the Clean Power Plan, as devised, is an approach that won’t work for the Boilermakers and is bad for our nation.

You can send a comment to the EPA online, by regular mail or by fax.

Thanks in advance for your participation. EPA needs to hear us loud and clear.