1220 N. Fillmore Street 

Suite 410 

Arlington, VA 22201 

Telephone 703-812-4811 

www.icac.com 

David C. Foerter, Executive Director

Email: dfoerter@icac.com Senator Thomas Carper 

513 Hart Building 

Washington, DC 20510 

November 3, 2010 

Dear Senator Carper: 

Thank you for your letter of October 6, 2010 requesting the Institute of Clean Air 

Companies’ (ICAC) insights and perspective regarding the questions of labor availability and the 

capacity of the electric power industry to install air pollution control systems on a timely 

schedule and the types of jobs these installations create. As you recognize in your letter, this is 

not a new concern. In fact, industry stakeholders raised this exact concern when EPA proposed 

the NOx SIP Call rule in 1998 and, again, when EPA proposed the Clean Air Interstate Rule 

(CAIR) in 2005. Notably however, these were concerns raised primarily in advance of the 

finalization of rules, and in both cases proved unfounded as the stationary source air pollution 

control and measurement (APC) industry satisfied demand for labor and other resources placed 

upon us and related industries. These concerns and doubts are being raised again; however, based 

on a history of successes, we are now even more resolute that labor availability will in no way 

constrain the industry’s ability to fully and timely comply with the proposed interstate Transport 

Rule and upcoming utility MACT rules. Contrary to any concerns or rhetoric pointing to labor 

shortages, we would hope that efforts that clean the air also put Americans back to work. We 

appreciate your efforts to more fully understand this issue and we offer the following responses 

to the specific questions you raise: 

 The APC Industry is able to meet future demands for emission control technology due to our 

overwhelming experience in meeting requirements for selective catalytic reduction (SCRs) 

and flue gas desulfurization (FGDs) under the NOx SIP Call and CAIR. 

 Less resource and time-intensive technologies are available to be quickly deployed offering 

the electric generating industry the needed flexibility to comply with the proposed Clean Air 

Transport Rule and the upcoming utility MACT. For example direct sorbent injection (DSI) 

and dry scrubbing technology installation times are approximately 12 and 24 months, 

respectively. 

 The design and construction of NOx, SO2 and HAPs control technologies require engineers, 

skilled craft labor such as boilermakers and creates upstream and downstream employment 

and economic benefits. 

 We estimate that over the past seven years, the implementation of CAIR Phase 1 resulted in 

200,000 jobs in the APC industry. 
Is labor availability likely to constrain the industry as it seeks to comply with the interstate 

transport and utility MACT rule? 

The simple answer is that labor availability has never jeopardized overall industry compliance 

requirements, nor is there any reason to assume that it would prevent the power generation 

industry from effectively complying in a timely way with requirements. As an industry, we 

respond to whatever demand for products and services is placed upon us by affected industries 

complying with requirements. The corollary to this response is that the APC industry has proven, 

particularly in recent years, the dynamic nature of ours and related industries in meeting demand 

from the electric power generating industry. This has been demonstrated by repeatedly satisfying 

rapid and substantial increases in demand for services and products, working effectively with 

end-users to efficiently deploy resources to meet compliance deadlines, innovating then bringing 

those innovations quickly to market, and relying on inherent competitiveness within the industry 

to bring an ever broader range of economically reasonable solutions to our customers. The 

variable nature of our industry, including supporting and related industries, now finds us at a 

point where demand for products and services is low, so we are well-positioned to meet any new 

demand. 

We are extremely confident in the ability of our industry to deliver and satisfy, as we have so 

successfully in the past, the labor, materials and resources needed to meet the demand. Labor 

availability did not constrain the electric power industry’s ability to comply with CAIR and the 

NOx SIP Call. We based this observation on (1) recent and past decade of industry installation 

experience, and (2) the extent of controls already installed at existing coal-fired power plants. In 

addition, there are less capital intensive control technology options available to the industry that 

can be implemented in a shorter period of time. In these current market conditions the APC 

industry is in a period of underutilization as compared to the NOx SIP Call and CAIR Phase I 

years. 

Figure 1. Cumulative SCR and FGD Installations by Year 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

1999200020012002200320042005200620072008200920102011

Online Year

Capacity (MW)

SCR 

FGD(wet/dry)

CAIR Phase I

NOx SIP Call

Source: US EPA NEEDs database 4.10 v 

2
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Many of the technologies that will be needed to be installed to comply with the requirements of 

the proposed interstate Transport Rule and the as yet-to-be-proposed utility MACT rule are 

likely to be the same technologies installed in recent years for other successful and more laborintensive programs. In fact, over the past decade (as illustrated in Figure 1) our industry has 

already successfully met the challenge of installing what were substantially new technologies on 

a significant portion of the electric power industry. These technologies have been refined and 

are readily available, as are the resources needed to complete their installation. Today more than 

one-half of the coal-fired electric generation fleet currently operates reliably on some 

combination of these technologies. 

The trend in recent years has been to install the largest and most effective control systems such 

as FGD and SCR systems, which are also some of the most labor-intensive and time-consuming 

technologies available. The design and construction of a large ‘wet’ scrubber system may take 

36 months to complete. Wet scrubbers reduce SO2 emissions by more than 98 percent, and their 

construction and installation employ several hundred workers. Currently, more than one-half of 

the coal-fired electric generation capacity of the U.S. operates with FGD systems, with most 

having been installed over the past decade. We anticipate that FGD control installations from 

implementing the proposed Transport Rule will be radically less than our recent installation 

experience under CAIR Phase I. EPA projects that about 14 gigawatts (GW) of coal-fired 

generating capacity will be retrofitted with scrubbers and less than 1 GW with SCR controls by 

2014 to comply with the recently proposed interstate Transport Rule. This is substantially less 

than what was accomplished under CAIR. 

Going forward, ICAC expects a wide range of technologies will be available to provide 

flexibility for utility compliance strategies. In particular, we expect greater use of both DSI and 

dry scrubbing technologies, such as circulating dry scrubbers (CDS) and spray dryer absorber 

(SDA) technology, due to future backend water and disposal requirements. The added 

advantages of using these technologies are fewer resources required and shorter installation times 

– 12 months for DSI and 24 months for a dry scrubber. Moreover, the next round of EGU 

control installations will likely be on smaller coal-fired units, and DSI and dry scrubbing are 

well-suited to smaller footprints and high-sulfur bituminous coal applications. However, exact 

technology controls are chosen by electric power generating companies based on final 

requirements and in a context of multiple market variables. 

Recent Industry Experience 

The electric power sector has a demonstrated ability to install a large number of complex 

pollution control systems in a relatively short period of time, while coordinating outage 

schedules to maintain electric system reliability. Specifically, the industry’s recent experience 

with the CAIR and the NOx SIP Call clearly demonstrates that the industry has more than 

sufficient capacity to comply with the proposed interstate Transport Rule and upcoming utility 

MACT rules. 

The majority of coal plants have already installed NOx and SO2 controls. Of the 310 GW of coal 

capacity in the United States, 170 GW have installed FGD systems and another 55 GW have 

FGD controls planned. As a result, roughly two-thirds of the existing coal fleet will soon be 
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retrofit with FGD controls. Additionally, about one-half of U.S. coal capacity has installed or 

soon will be retrofit with advanced NOx controls. Many companies have also installed or 

optimized existing control systems for mercury reductions in response to state regulations, giving 

them a jump start on a future utility MACT rule. In the absence of a federal standard, almost 20 

states have adopted mercury regulations for coal-fired power plants over the past several years. 

Clean Air Interstate Rule. The Clean Air Interstate Rule (CAIR), limiting NOx and SO2

emissions in the Eastern U.S., created substantial demand for SCR and FGD systems. Between 

2008 and 2010, coal-fired power plants added approximately 60 GW of FGD controls and almost 

20 GW of SCR controls with a total of 80 GW of FGD controls installed under CAIR Phase 1. 

CAIR created unprecedented high demand for scrubber components and, lead times on key 

components, including large recycle pumps, motors, fans, chimney components and 

construction. Utilities managing large, multiple-scrubber programs, also used the compliance 

flexibility in the rule to stage and optimize use of personnel and other resources over longer 

periods than would have been needed were there just one scrubber. It is notable to point out that 

in a recently presented paper (Implementation Strategies for Southern Company FGD Projects; 

Wall, Healy & Huggins; Power Plant Pollutant Control “Mega” Symposium, September 2010), 

the Southern Company authors noted that company-wide planning for FGD installations started 

in 2003, while the CAIR rule was not final until 2005. 

Labor limitations are normally cited by the utility industry as the chief limiting factor in 

undertaking clean air retrofits, and boilermakers, in particular, are cited as the major source of 

concern because of their specialized skills. Other craft labor, such as iron and steel workers and 

carpenters, can be drawn from the broader construction industry. 

Prior to the implementation of CAIR, EPA and industry stakeholders, such as the Utility Air 

Regulatory Group, assumed that skilled labor would limit the industry’s ability to install air 

pollution control equipment. However, based on a retrospective review of actual experience by 

James Staudt, Ph.D., CFA, it was determined that EPA and industry dramatically underestimated 

the ability of the air pollution control industry to support the utility industry in responding to 

CAIR1

. According to Staudt: 

“The assumptions regarding the availability of labor were demonstrated in this White 

Paper to be too limiting and, by imposing a “hard cap” on labor availability, did not 

take into account the dynamic nature of U.S. labor markets, which US EPA had 

acknowledged in the past. Also, assumptions by US EPA and the representatives of 

the utility industry regarding the timing of orders relative to the finalization of the 

CAIR proved to be incorrect. As a result, both US EPA and representatives of the 

utility industry underestimated the ability of the [air pollution control] industry to 

support the utility industry in its response to the CAIR.” 

Staudt offers several reasons for why EPA and industry underestimated the capabilities of the 

labor market: (1) boilermakers will work overtime during periods of high demand; (2) 

1 “Availability of Resources for Clean Air Projects”, James Staudt  PH.D., CFA, Andover Technology Partners,

October 2010
5

boilermakers frequently travel to different locations for work, supplementing local available 

labor; (3) boilermakers work in fields other than power, such as refining/petrochemical, 

shipbuilding, metals industries and other construction trades, and workers can shift industry 

sectors with appropriate training; and (4) new workers will enter the field between 1999 and 

2001 - for example, in advance of the NOx SIP Call, boilermakers increased their ranks by 35 

percent mostly by adding new members. 

NOx SIP Call. Between 2001 and 2005, the electric industry successfully installed more than 

96 GW of SCR systems in response to the NOx SIP call thus adding NOx controls to roughly 

one-third of the U.S. coal fleet. During this same time period, the industry was simultaneously 

adding a record amount of new generating capacity. Between 2001 and 2004, the electric 

industry built more than 180 GW of new generating capacity, including natural gas combined 

cycle power plants, coal-fired power plants, and renewable energy facilities. 

Alternative Control Options 

Much of our discussion has focused on scrubbers and SCR systems that may be used for 

compliance with the proposed interstate Transport Rule and upcoming utility MACT rule. These 

technologies may require longer installation times, however, there are other less resource and 

labor-intensive alternatives that will also be used for compliance. For example, DSI is a 

technology that reduces SO2 through injection of trona, sodium bicarbonate or hydrated lime 

upstream of a particulate control device. DSI does not generally provide the high rates of SO2

control achieved with a scrubber, but the technology can achieve significant levels of control and 

can be implemented very quickly—typically within one year. DSI and other dry scrubbing 

systems also are effective in reducing some hazardous air pollutants that would be controlled 

under MACT, such as hydrochloric acid (HCl). These systems are likely to preferentially reduce 

HCl in the flue gas. With regard to NOx control, selective non-catalytic reduction (SNCR) is a 

widely used technology that can also be implemented in under a year. The levels of NOx control 

are less than what can be achieved with SCR, but the technology can be installed quickly with 

fewer labor resources. Again, industry choices prevail in complying with requirements, and 

there are now approximately 18 GW of generation with SNCR NOx controls. 

Even if the upcoming utility MACT were to require the level of control achieved by wet 

scrubbers, it is unlikely that this technology would then be applied to all of the remaining 

unscrubbed fleet. We can see that the already installed pollution control systems, along with 

potential coal plant retirements, will change the future demand for equipment orders. When 

anticipating outcomes of the yet to be proposed utility MACT, it is important to recognize that 

wet scrubbers are placed into service to substantially eliminate SO2 emissions, while the 

hazardous air pollutants may rely on a different set of less labor intensive technologies. One 

observation, is that the demand for large equipment orders on the scale of wet scrubbers, may 

diminish significantly for the near future when driven by the transport rule and utility MACT; 

and be largely supplanted by alternative technologies that demand less labor and shorter 

installation time. Historically, affected industry will comply with requirements by utilizing a 

suite of reasonably economic technology solutions. 
6

 

It may also be possible to improve the scrubber performance of many older scrubbers that were 

installed in the 1970’s and 1980’s. For example, limestone forced oxidation wet scrubber system 

upgrades at the Vectren Culley Station Units 2 & 3, E.On’s Trimble County Unit 1, and 

Michigan South Central Power’s Endicott Station resulted in increased removal efficiencies in 

the range of 98 percent. Upgrades such as these can also be implemented quickly and at lower 

cost versus the installation of a new scrubber. 

Preserving these compliance alternatives will require that EPA allow a degree of compliance 

flexibility in its regulatory design. For example, EPA has proposed a hybrid cap-and-trade 

approach under the proposed interstate Transport Rule that would allow companies to take 

advantage of these alternative control strategies. In addition, the Clean Air Act MACT program 

allows a state-granted one year compliance extension, if needed, to complete installation of 

controls. 

What types of engineering and construction skills are required to design and construct NOx, 

SO2, and HAPs controls? 

This is an extremely relevant question, such that dollars spent on air pollution control not only 

result in avoided health costs including avoided premature mortality, but these same dollars are 

plowed back into the U.S. economy as good and green jobs. Adding pollution control equipment 

to existing power plants requires engineers to design the systems and specialized construction 

labor, particularly boilermakers, to build and install the equipment. When operational, these 

control systems rely on a continuous supply of manufactured and processed reagents resulting in 

jobs in related industries. FGD and SCR systems require: (1) construction materials, such as 

steel plate, alloy steel, fabricated steel components, structural steel, and concrete; (2) engineered 

equipment and specialty materials, such as slurry pumps, fans, motors and catalyst; and (3) 

reagents, especially limestone and ammonia. These requirements are examples of direct and 

indirect employment opportunities resulting from the environmental drives for new and 

retrofitted air pollution control systems. 

Looking back over the past seven years as industry installed SCR and FGD controls in readiness 

for the CAIR Phase I requirements, we estimate that this work required approximately 200,000 

person-year jobs in direct and indirect labor. Specifically, a typical turnkey installation of a 500 

MW scrubber is estimated to employ approximately 200 people, with about 80 percent dedicated 

to construction and 20 percent for engineering and project management2

. The installation of SCR 

controls creates a similar number of jobs over a shorter time period and employs a greater 

number of boilermakers. As we near the end of installing this latest phase of beneficial control 

projects, these workers are readily available and trained to continue this level of activity. 

Boilermakers are an important trade in terms of the installation of pollution control equipment. 

It is a specialized trade, serving the electric power, refining/petrochemical, shipbuilding, and 

metals industries, and boilermaker supply, represented by both union and non-union labor, is 

2

Engineering and Economic Factors Affecting Installation of Control Technologies for Multipollutant Strategies; U.S.

EPA; October 2002
dynamic in responding to demand. Other crafts can be and have been drawn from the broader 

construction labor market. 

We are not aware that engineering labor has ever been raised as an issue that might limit the 

industry’s ability to install air pollution control equipment. There are numerous suppliers of air 

pollution control equipment. If one supplier becomes busy, there are several other options. 

Also, companies that are building multiple scrubbers will often adopt standardized equipment 

designs, reducing the need for engineering support, as supported by Southern Company’s 

experience referenced above. 

In addition to the amplified employment demands of major clean air initiatives such as CAIR 

and the NOx SIP Call, our industry provides a continuous and enduring stream of good and 

green jobs related to the manufacturing, installation and servicing of air pollution control and 

measurement technologies. 

If labor is in short supply among any of these trades are there actions that we should be taking 

today in order to ensure that we have the skilled labor needed to comply with the Clean Air 

Act? 

We are extremely confident in the ability of the industry to deliver and satisfy, as we have so 

successfully in the past, the labor, materials and resources needed to meet the demand. While we 

do not believe that skilled labor will be in short supply, proactive steps to provide more clarity 

sooner to industry on the full suite of requirements for air, water, and waste regulations that they 

are facing, will in turn provide the needed investments and assist our industry in meeting 

demand. EPA’s efforts to move forward expeditiously with the proposed interstate Transport 

Rule and the upcoming utility MACT rules will be helpful in this regard. We believe early and 

continuous installations are needed to promote job security in ours and other industries, as well 

as ensure more efficient application of resources to meet longer term challenges. As discussed 

throughout our response, labor availability has not and is not an impediment to industry 

compliance, and we are already at a high level of industry readiness. In closing, ICAC shares 

your enthusiasm that now is the time “to put American workers back on the job of modernizing 

our electric generating fleet” and give America the clean healthy air they deserve. 

 Sincerely Yours, 

 

 David C. Foerter, ICAC Executive Director 

7