BEFORE THE U.S. ENVIRONMENTAL PROTECTION AGENCY 

Public Hearings on EPA's Proposed 

Clean Power Plan 

July 2014 

Comments of Utility Workers 

Union of America, AFL-CIO 

Utility Workers Union of America, AFL-CIO 

815 16' Street, N.W. 

Washington, DC 20006 

(202) 974-8200 (phone) 

(202) 974-8201 (fax) 

www.UWUA.net 
Comments of Utility Workers Union of America, AFL-CIO 

I wish to thank EPA for this opportunity to provide our views on the proposed 

Clean Power Plan and its likely impacts on utility workers, especially for the 

thousands of UWUA members employed in electric power generating facilities. 

The UWUA represents 50,000 employees in the electric generation, distribution, 

and other utility industries. The future of our members employed in power 

generating facilities — including the welfare of their families and their communities 

— will be vitally impacted by the final rule adopted by EPA in this matter. UWUA 

members will also be directly affected by the State Implementation Plans the states 

will ultimately adopt in order to comply with EPA's proposed rule. 

Given the enormous stake our members have in these decisions, we would like to 

offer our recommendations for how our nation can substantially reduce carbon 

emissions while also protecting existing jobs in the utility and related industries. 

First, we urge that the final rule should encourage the states to embrace in their 

State Implementation Plans concrete support for new technologies that will protect 

existing jobs while reducing emissions. 

We strongly support the flexibility given to the states in the proposed rule to 

determine how best to reduce carbon emissions. In addition, however, we believe 

the rule should specifically encourage the states to embrace policies that will 

support the modernization of the existing power generation infrasti -ucture so 

critical to many our states' economies. 

This should include a recognition that coal will continue to play an important role 

in meeting our essential power needs. In our view, technologies such as carbon 

capture and sequestration are essential not only to protect the thousands of familysupporting jobs associated with coal-fired generation, but also as an essential 

component of any workable plan to address climate change. 

With power demand surging around the globe, and with countries such as China 

and India expected to continue to build new coal-fired plants to power their 

growing economies, effective carbon capture and sequestration will be essential if 

we have any chance of reducing carbon emissions on a global level. 

And just as we believe the U.S. should play a leading role in developing and 

exporting renewable energy technologies such as wind and solar, the U.S. should 

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also take the lead in developing carbon capture and sequestration as well as other 

technologies to significantly reduce emissions from coal-fired power plants. 

With federal support, NRG Energy recently began construction of a$1 billion 

carbon capture project designed to remove 1.6 million tons of carbon dioxide a 

year from emissions from a power plant near Houston, Texas. This will be one of 

the largest carbon-capture projects operating at a commercial scale and is an 

important first step, but much more needs to be done. 

Other technologies are also available to increase the efficiency of existing coalfired plants so that total carbon emissions are reduced. Similarly, our nation's 

electric power grid desperately needs modernization. One important benefit of 

grid modernization is that transmission over the grid will become more efficient, 

which in turn will reduce overall emissions from power generation. 

In short, we urge that the final Clean Power Plan should encourage the states to 

include concrete support for technologies designed to modernize and sustain 

existing generation facilities as part of their overall plans to reduce carbon 

emissions, while also protecting jobs. 

Second, we urge that the final rule should encourage the states to conduct statespecific job impact assessments in their State Implementation Plans, and to provide 

detailed plans for mitigating any expected adverse impacts stemming from 

implementation of the rule on dislocated workers and their communities. 

In our view, federal and state regulators must plan in advance for the economic 

dislocations that will inevitably occur whenever new regulatory policies are 

introduced. This includes the need to identify adequate funding sources for 

programs to assist workers and communities that may find themselves the innocent 

victims of the shift toward low-carbon energy. 

In the proposed rule itself, EPA estimates that up to 50 gigawatts of coal-fired 

generation could be taken offline by 2030 as a result of implementation. The 

proposed rule also implicitly recognizes that, while this historic shift in national 

energy policy will create new jobs in new industries, there is no guarantee that 

workers who may lose their existing jobs in coal-related industries will be the 

beneficiaries of these new jobs. 

We believe that any regulatory policy that transfers the full cost of compliance 

onto stranded workers and communities is bad policy. 

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We therefore recommend that the final rule should urge the states to include in 

their State Implementation Plans state-specific job impact assessments, coupled 

with specific plans to mitigate any adverse job impacts. These should include 

transitional programs and designated sources of funding to support: 

• Wages, benefits, and retraining for utility workers, mine workers, and others 

who may become displaced as a result of the shift toward lower-carbon 

energy; 

• Expansion of existing economic development programs to enable 

communities to respond to power plant closures or downsizing; and 

• Support for the development of new energy projects and technologies in the 

communities most impacted by this shift in national policy, and guarantees 

that displaced workers will be able find new, sustainable jobs in our new 

energy future. 

Beyond simple notions of fairness, mitigating these adverse job impacts would 

provide critical economic benefits. An effective transition plan for workers and 

communities would foster new economic development strategies to replace lost tax 

revenues, and would also help ensure that the skills needed to compete in a 21y` 

Century economy will remain available. 

In summary, the UWUA supports the need for bold action to address the 

challenges of climate change, but in the process we must avoid creating another 

Rust Belt that would result from a new wave of power plant closures caused by illconceived regulations. We believe this can be done while also substantially 

reducing carbon emissions, if we combine sensible regulatory policies with a 

sound plan to assist affected workers and communities in the transition. 

In our view, the best way forward is to adopt policies that support the 

modernization of our existing power generation and transmission infrastructure, 

including the continued use of responsible coal-fired generation, coupled with 

concrete, long-term support for the workers and communities who may become 

stranded in the process. 

Thank you again for giving us the opportunity to comment on EPA's proposed 

Clean Power Plan. 

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