DRAFT 

MEMORANDUM 

TO: Misha Adamantiades, CAMD 

FROM: Bansari Saha, Bibhakar Shakya, Kelsey Read, ICF International 

DATE: February 25, 2011 

RE: Employment Estimates of Direct Labor in Response to the Proposed Toxics 

Rule in 2015 – DRAFT 

Introduction 

This technical support document (TSD) presents estimates for the direct job impacts of the 

proposed Utility Air Toxics Rule (Toxics Rule). The focus of the employment analysis in this 

study is only on the short-term direct jobs related to the compliance actions of the affected 

entities within the power sector. It does not include the ripple effects of the estimated direct job 

impacts on the broader economy (the “multiplier” effect), nor does it include the wider economywide effects of the changes to the energy markets (such as higher electricity prices). Moreover, 

this study provides only a static snapshot of the impacts for 2015 and does not account for the 

dynamic adjustments of the affected entities as they adapt to the Toxics Rule, such as those 

arising from technological innovation and learning-by-doing. 

The estimates of the job impacts are divided into several categories: job gains due to the 

increased demand for pollution control equipment; job losses due to retirements of fossil 

generation; and job shifts due to changes in demand for fuels. Results indicate that the Toxics 

Rule has the potential to provide significant short-term employment opportunities, primarily 

driven by the high demand for new pollution control equipment. The job gains due to new 

pollution control requirements are likely to be tempered by some job losses due to plant 

retirements, although, as discussed below, many of these workers who lose their jobs due to 

plant retirements could find replacement jobs operating the new pollution controls at nearby 

units. Finally, job losses due to reduced coal demand are likely to be neutralized by job gains 

due to increased natural gas demand, resulting in small positive net change in jobs due to fuel 

demand changes. Overall, the preliminary results indicate that the Toxics Rule could support a 

net of about 40,000 to 50,000 job-years in 2015. These results are summarized in Table 1 

below. 

Table 1: Net Employment Changes (Job-years in 2015) 

New Pollution Control Equipment 45,058 ‐ 55,501

Retirements of Generating Units (5,720)

Changes in Fuel Use 427

Net Effect 39,765 ‐ 50,208

The job-years estimated here is a snapshot of the direct employment effect of the Toxics Rule in 

1 
DRAFT 

2015. While there is no temporal dimension to this study, most of these jobs are likely to last 

over an extended time period, some more than the others. Most of the construction related 

jobs, for example, are expected to provide a short-term, temporary boost to employment that 

could last a few years, along with any multiplier effects that are not included in these job-year 

estimates. Most of the operational jobs are likely to be more long term. Thus, in terms of the 

impacts of the Toxics Rule on economy-wide employment over time, this study shows there 

could be a significant temporary spurt to employment levels starting before 2015, which would 

likely recede thereafter as the construction phases for the needed pollution controls wind down. 

Over time, the operational jobs will continue to provide a small boost to employment over 

“business as usual” baseline employment levels. Note that this synopsis does not account for 

other employment impacts of the Toxics Rule, like those resulting from higher energy prices. 

Overall Approach 

The estimates for direct employment effects of the proposed rule utilize basic methodologies to 

estimate these job impacts relying on approaches used in prior EPA studies on similar issues. 

The basic approach involved using power sector projections and various energy market 

implications under the Toxics Rule from the Integrated Planning Model (IPM), along with data 

from secondary sources, to estimate the first order job impacts for 2015. Throughout this 

analysis, incremental employment is measured in job-years, since there is no temporal 

dimension to the analysis currently.1

 Also, this TSD does not include estimates of total direct 

employment impacts over time, though there is a distinction between short-term construction 

jobs and more long-term operational jobs for new pollution controls (though these operational 

jobs are also measured in 2015 job-years only). 

Jobs gains due to new pollution control equipment 

IPM projections for the proposed Toxics Rule policy case were used to estimate the incremental 

pollution control demand. These are shown in Table 2 below:2

 

Table 2: Increased Retrofit Demand due to the Toxics Rule, 2015 (GW) 

Retrofit Type IPM Projected Additional 

Pollution Control 

Scrubbers (FGD) 22

Selective Catalytic 

Reduction (SCR) 3

Activated Carbon 92

 

1

 A job-year is defined as the amount of work that can be performed by the equivalent of one full-time 

individual for one year (or FTE). 

2

 According to IPM, there is a fair amount of overlap between the different types of pollution control 

equipment demand at individual facilities. To the extent that there could be some efficiency gains at 

plants installing multiple controls due to economies of scale, the job estimates presented here could 

overstate the impacts. 

2 
DRAFT 

Injection (ACI) 

Dry Sorbent Injection 

(DSI) 55

Fabric Filter (FF) 108.5 ‐ 158.5

Incremental fabric filter (FF) capacity is defined by a range because in the IPM policy case 

modeling, EPA assumes FFs are necessary for all coal and solid-oil derived fuel-fired electric 

generating units (EGU) to meet the standard for particulates (PM). EPA believes this could be a 

conservative assumption, and the data collected under the Information Collection Request (ICR) 

suggests that some EGUs may be able to meet the total PM standard without installing FFs. 

Based on this data and the PM factors used in IPM, EPA estimates potentially 50 GW of 

existing capacity may not actually require this pollution control for compliance with the proposed 

Toxics Rule. Therefore, the IPM-based estimate which requires FF at all affected units (158.5 

GW) may overstate the employment estimates. Hence, this study also included a lower bound 

FF estimate (50 GW less to 108.5 GW) and a corresponding lower bound of the pollution control 

job impacts using this lower FF estimate.3

 The range of job-year estimates discussed below are 

thus all defined as a function of which FF requirement is assumed. 

The job impacts due to increased pollution control demand are divided into four categories: 

short-term labor needed for constructing and installing the pollution controls, which were further 

subdivided into types of installation labor (such as boilermakers, engineers and other installation 

labor) and steel manufacturing labor. Additional estimates are also provided for longer-term 

operational requirements for the pollution controls, including jobs in sectors that supply 

resources needed to run these pollution control equipment (e.g., reagents) and utility sector jobs 

to operate the pollution controls. The following sections discuss the approach for each: 

• For the installation related construction labor, per-unit labor needs were taken from an 

extensive 2002 EPA resource analysis for multi-pollutant strategies that analyzed the 

resource requirements for installing various pollution control equipment (FGD, SCR, and 

ACI).4

 For those equipment that were not included in the 2002 EPA study (DSI and FF), 

additional information was supplied by Andover Technology Partners (ATP), which was 

also one of the contributors of the 2002 EPA study. Using the same resource 

requirement approach as done in the 2002 EPA study, ATP provided estimates of unit 

labor needs based on scaling the labor requirements for ACIs (to derive estimates for 

DSI) and SCRs (to derive estimates for FFs).5

 Thus, all of the unit labor needed for 

different pollution control installations can be traced back to the 2002 EPA study, with 

appropriate engineering adjustments. The installation labor was sub-classified into 

 

3

 As these costs may be overstated, the IPM results may also overstate natural gas and retail electricity 

impacts, as well as plant closure decisions. Those changes are not studied in the lower bound job 

estimate, only changes in pollution control equipment were adjusted. 

4

 “Engineering and Economic Factors Affecting the Installation of Control Technologies for Multi-pollutant 

Strategies”. EPA/ORD, 2002. 

5

 DSI and Fabric Filter System Installation Labor Estimate. Memorandum by Andover Technology 

Partners to ICF International. January 26, 2011. 

3 
DRAFT 

different labor categories, such as boilermakers, engineers and a catch-all “other 

installation labor”, using information from the 2002 EPA study, adjusted for the new 

pollution controls (FFs and DSIs). 

• In addition to construction labor, it was assumed that installing the pollution controls 

requires labor for steel as the primary raw material, leading to jobs in the steel 

manufacturing industry. Again this approach is consistent with the 2002 EPA study. 

The increased steel demand is estimated using the per-MW steel demand from the EPA 

study along with the estimated increase in pollution controls. For DSI and FF, the same 

proportionality assumption is taken from ATP for installation labor to estimate the steel 

needed for installation. 

• For the longer term direct jobs associated with operating the pollution controls, per-unit 

estimates of the main resources needed for these equipment (see Table 3 below for a 

list of the resources) are taken from the 2002 EPA study, augmented by DSI resource 

use estimates from ATP. Resources needed for FF were estimated from the 

incremental Variable Operation and Maintenance (VOM) costs from IPM.6 7

 These were 

then multiplied by the incremental GW for each pollution control to obtain the total 

(physical) quantity of resources needed.8

 Total tonnage for each resource was then 

converted to dollars of increased economic output for these resources using price 

estimates obtained from publicly available sources (see Table 3). Finally, the labor 

productivity for each particular sector was used to estimate the number of job-years 

these would likely create in 2015. Labor productivities for each sector were adjusted to 

account for increased worker productivity in 2015. Data for baseline worker productivity 

and corresponding growth rates to account for future productivities came from the 

Economic Census and the Bureau of Labor Statistics (BLS) estimates.9

 

• The final jobs vector estimated was related to the utility sector jobs required to operate 

these pollution control equipment. This estimate was based on the incremental Fixed 

Operation and Maintenance (FOM) costs from IPM outputs, excluding costs due to 

retirements.10 The assumption in this TSD was that the FOM costs – which, in IPM, are 

defined as the maintenance costs incurred by the utility irrespective of whether the 

equipment is operated (such as those for payroll) – are a good proxy for estimating the 

incremental demand for jobs that would be needed to operate these pollution controls. 

The FOM costs were then translated into employment based on estimates of payroll per 

 

6

 Because FF requirements are not endogenously determined in IPM, it required a different approach 

than the other controls. 

7

 For the lower bound job-year estimates, the FF VOM cost was scaled down proportionately from the 

VOM cost estimate for 158.5 GW. 

8

 Except for Ammonia, where the usage was calculated based on the total predicted NOx reduced, 

consistent with the 2002 EPA study approach. 

9

 Total value of shipments in 2007 and total employees were taken from 2007 Economic Census, 

Statistics by Industry for Mining and Manufacturing sectors. The average annual growth rate of labor 

productivity was taken from the Bureau of Labor Statistics. Average growth rate calculated for years 

1992-2007, applied to 2007 productivity to determine 2015 estimates of productivity. For steel, limestone, 

ammonia and SCR catalyst, the value of shipments and employment estimates were taken from the 2000 

Survey of Manufacturers. 

10 For the lower bound job-year estimates, the FOM cost used for the operating labor calculations was 

scaled down proportionately to reflect the lower level of FF pollution controls (50GW out of 330 GW). 

4 
DRAFT 

worker for the power sector taken from the 2007 Economic Census and BLS. 

estimates.11 

Table 3: Estimated Pollution Control Resource Needs (Quantity and Prices Used)

Amount of Resource Used   Price Used  ($/unit)

Steel (tons)               364,287 – 435,365 $                               550

Limestone, FGD (tons)                             7,157,631 $                                7512

Ammonia, SCR (tons)                                   57,860 $                               150

Catalyst, SCR (m3)                                     3,874 $                            8,475

Activated Carbon, ACI (tons)                                   50,701 $                            1,120

Sodium Bicarbonate, DSI (tons)                          12,254,403 $                               120

Price Sources: Steel: Platts, Steel Markets Daily, Vol 3 Issue 209, October 29, 2009. 

Limestone: FGD Tech Evaluation, March 2007. 

Ammonia: Development of Supply Curves for Abatement of GHG from Coal-fired Utility 

Boilers, Air Pollution Prevention and Control Division, US-EPA, RTP and NC State 

University, 2009. 

Catalyst: EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002. ; 

Activated Carbon: Preliminary Cost Estimate of ACI for Controlling Hg Emission, US DOE, 

NETL, November 2003. 

Sodium Bicarbonate: Communication with Andover Technology Partners, Feb 7, 2011.

Results 

Table 4 presents the estimated job impacts in 2015 resulting from the additional pollution 

controls needed to meet the Toxics Rule requirements. The Toxics Rule is estimated to lead to 

a total capital investment of about $55 to $60 billion in order for the regulated entities to meet 

the limits under the proposed rule (This capital cost will be amortized over many years). 

According to this analysis, these investments could provide the opportunity to create or support 

about 45,000 to over 55,000 job-years to design, construct, and operate the needed pollution 

control equipment in 2015. Note, some of these jobs are expected to start before, and continue 

beyond 2015 (such as the resource related job-years), but this analysis only provides a 

snapshot for 2015. 

Table 4: Jobs Due to Pollution Control Retrofits under the Toxics Rule 

(Job-years in 2015) 

Jobs for Construction Incremental Employment

1. Boilermakers 13,804 - 18,110 

2. Engineers 3,412 - 4,082 

3. General Construction 14,189 - 18,782 

 

11 Same sources as other productivity estimates (2007 Economic Census and BLS), however, uses 

employees and total payroll rather than revenue or value of shipments. 

12 The limestone price used is for a dry FGD. This price is significantly greater than the wet FGD price. 

This price was used because IPM predicts only 1 GW of incremental wet FGD compared to 26 GW of dry 

FGD. 

5 
DRAFT 

4. Steel Manufacturing 430 - 514 

Sub-Total: 31,835 - 41,592 

Jobs for Operation 

Jobs from Increased Operating 

Resource Use 

1. Limestone (FGD) 2,130 

2. Ammonia (SCR) 18 

3. Catalyst (SCR) 104 

4. Activated Carbon (ACI) 90 

5. Sodium Bicarbonate (DSI) 6,138 

6. Baghouse material (FF) 62 - 90 

Sub-Total: 8,542 - 8,571 

Jobs for Retrofit Operation 4,681 - 5,443 

Total Labor: 45,058 - 55,501 

The number of job-years estimated for pollution control installation is driven in large part by the 

very high demand for new FFs used in IPM. As shown in Table 1, up to 158.5 GW of new FF 

capacity is projected to come online in 2015 due to the Toxics Rule, which is about 66 GW more 

than ACI, the next highest. This high demand for new FFs is estimated to contribute between 

about 65 and 75 percent of the new jobs resulting from the installation of pollution controls, 

depending on the range for incremental FFs shown in Table 1. Moreover, of the jobs due to 

increased resource use, the sodium bicarbonate required for DSI is estimated to support 

significantly higher number of jobs than the other resources. This is because the DSI 

technology requires significantly higher quantities of reagents than the other pollution controls, 

according to the ATP report. The second highest resource-related job gains would likely come 

from the limestone requirements for the scrubbers in response to the Toxics Rule. 

Of the 45,000-56,000 job gains estimated in Table 4, roughly 10 percent are estimated to occur 

within the utility sector for labor needed to operate the pollution controls. The rest of the labor 

demand will benefit the pollution control industry and other economic sectors. The increased 

demand for resources and chemicals needed to operate the pollution controls will provide a 

boost to employment in sectors such as mining, chemicals, and other manufacturing sectors. 

The majority of the direct jobs, however, are likely to benefit construction-related sectors, such 

as construction boilermaker, heavy engineering and other heavy construction sectors, due to 

the needs for constructing and installing the new pollution controls. 

Job losses due to coal retirements 

Job losses due to plant retirements were estimated by first identifying the retiring units13 from 

 

13 Oil and gas steam unit emissions requirements, and potential retirements, were not directly included in 

IPM modeling under the Toxics Rule policy scenario. An analysis of these units was conducted 

6 
DRAFT 

IPM results (for the base and the Toxics Rule policy cases). EPA projects that there will be 

roughly 10.2 GW of additional coal retirements by 2015 with the Toxics Rule in place.14 

In order to convert the retired capacity into potential job losses, it was assumed that changes in 

the operating costs for electricity generation can be used as a proxy for the lost economic output 

due to fossil retirements. Thus, the changes in the O&M costs (both FOM and VOM) for these 

particular retiring units were derived using IPM outputs, and converted to lost jobs using data 

from the Economic Census and BLS output/worker estimates for the utility sector.15 Table 5 

shows those results. 

Table 5: Job Losses due to Coal Capacity Retirements 

O&M Decrease from Retirements ($MM) 658 

Workers Per Million$ in payroll 8.7 

Workers lost due to retirements (man-year): 5,720 

Results indicate there could potentially be about 5,700 job losses (measured in job-years for 

2015, but any net job losses under this category are likely to be permanent), due to coal 

retirements. However, two mitigating factors could reduce the negative job impacts due to 

retirements. First, many of the retiring units are at plants that are likely to have other units 

operating under the policy scenario. In such cases, some of the excess labor pool at the retiring 

units could well be absorbed at other units within the same firm.16 

Second, as Table 4 indicates, utilities are expected to have the need to fill over five thousand 

additional job slots to operate the pollution controls needed to meet the requirements of the 

Toxics Rule. If workers with experience at existing coal facilities become available through plant 

retirements, it would seem logical for many of these workers to be absorbed in operating these 

new pollution controls. While it is not possible to determine how many of these workers from 

particular coal retirements could be employed to operate the new pollution controls, it is likely 

that a significant portion of them could find gainful employment at nearby units. 

Job losses due to changes in fuel use 

Two types of job impacts due to projected fuel use changes are estimated from IPM. First, job 

losses due to reductions in coal demand were estimated using an approach similar to EPA’s 

 

separately, and to the extent that there may be some retirements of oil and gas units, then the estimates 

of potential job losses due to retirements provided here will understate job losses. 

14 Retirement estimates are based on IPM System Summary Reports. Where applicable, data from IPM 

parsed outputs were adjusted to account for partial retirements reported in the parsed outputs. 15 As before, the same sources but using workers and total payroll. 16 According to the IPM results, about 70 percent of the coal retirements (in terms of capacity) occur at 

plants with other operating units under the Toxics Rule policy case. 

7 
DRAFT 

coal employment analyses under Title IV of the Clean Air Act and the Clear Skies Act.17 18 

Using this approach, IPM projected coal demand changes (in short tons) for various coal 

supplying regions were converted to job-years using EIA data on regional coal mining 

productivity (in short tons per employee hour), using 2008 labor productivity estimates.19 20 

Results of the coal employment impacts of the Toxics Rule are presented in Table 6 below. 

 

Table 6: Employment Due To Changes in Coal Use 

Coal by Region Change in Coal 

Demand (MM Tons)

Labor 

Productivity 

Job-year 

Change

 Appalachia (17.0) 2.91 (2,812)

 Interior 10.7 4.81 1,071

 West (13.3) 19.91 (321)

 Waste Coal (0.7) 5.96 (58)

Net Total (20.3) -- (2,120)

Note: Used US national coal productivity for waste coal. 

For natural gas demand, the incremental expenditure on natural gas from IPM projections was 

used as the basis for employment estimates, combined with productivity data for the oil and gas 

industry taken from the 2007 Economic Census. Those estimates were used as a proxy to 

estimate changes in production amounts in physical quantities into jobs estimates for the oil and 

gas mining sector. In addition, the projected capital cost estimates for new pipeline capacity 

needed to meet the 2015 demand levels from IPM were also used, and translated into 

employment using worker productivity estimates for the pipeline construction sector.21 These 

results are summarized in Table 7 below. 

 

Table 7: Total Employment Impact due to Changes in Fuel Use (2015) 

Fuel Type Employment

Coal Job Years Lost (2,120) 

Natural Gas 

 

17 CSA Technical Package, Section D. Projected Impacts on Generation and Fuel Use. 

18 Impacts of the Acid Rain Program on Coal Industry Employment. EPA 430-R-01-002 

March 2001. 

19 From US Energy Information Administration (EIA) Annual Energy Review, Coal Mining Productivity 

Data. Used 2008. 

20 Unlike the labor productivity estimates for various equipment resources which were forecasted to 2015 

using BLS average growth rates, we used the most recent historical productivity estimates for fuel 

sectors. In general, labor productivity for the fuel sectors (both coal and natural gas) showed a 

significantly higher degree of variability in recent years than the manufacturing sectors, which would have 

introduced a high degree of uncertainty in forecasting productivity growth rates for future years. 21 Same Economic Census 2007 source as used previously. Because BLS does not have growth rate 

data for the construction sector, and to maintain consistency with coal and natural gas data, we did not 

forecast this productivity but used the most recent available 2007 value. 

8 
DRAFT 

 Change in Fuel Expenditure ($MM) 3,427

 Worker Per Million in Revenue 0.65

 Job-years gained                       2,242

Gas Pipeline 

 Capital Cost for New Pipeline Capacity 

 (US total: MM $/year) 59.2 

 Workers/million $ in Pipeline Construction 5.1 

 Job-years gained 305 

Net Employment Effects of Fuel use changes 

 

427 

About 2,100 job losses in the coal mining sector are likely to be more than outweighed by the 

gains in the production and transportation-related jobs in the natural gas related sectors. Thus, 

net employment impacts of fuel use changes in 2015 are likely to be minimal, because of shifts 

in demand for particular fuels. 

Conclusion 

Overall, the Toxics Rule is expected to provide a significant boost to short-term employment 

resulting from substantial investments in new pollution control equipment. The Toxics Rule is 

estimated to lead to a total pollution control-related capital investment of about $55 to $60 

billion, and results for 2015 indicate this could support or create around 40 to 50 thousand jobyears, driven primarily by the need to design and construct the needed equipment. While there 

are expected to be some job losses due to coal retirements that will likely have a negative effect 

on some utilities and the coal mining sector, job gains in pollution control operation activities and 

the natural gas sector are likely to offset some of those losses. As previously discussed, this 

assessment does not account for the long run economy-wide effects of the proposed Toxics 

Rule. 

The employment impacts estimated in this study are mostly based on approaches in prior EPA 

studies on similar topics. The main source for resource estimates used here is the 2002 EPA 

multi-pollutant resource analysis, which was also the basis for subsequent EPA labor analyses, 

such as the 2005 Clean Air Interstate Rule (CAIR) TSD on boilermaker labor.22 Thus, results 

presented here are consistent with EPA’s assessment from the 2002 and the 2005 studies. 

 

 

22 CAIR Technical Support Document. Boilermaker Labor Analysis and Installation Timing. March 2005.

9 
DRAFT 

Appendix 

This Appendix provides further details on the inputs and methodology used in the labor 

calculations presented above. The Appendix begins with the pollution control labor section, 

presenting the inputs for the four primary sections of equipment labor and describing the 

process by which the labor estimates were obtained from the available data, followed by similar 

discussions for coal retirements and fuel use change employment analysis. 

Pollution Control Equipment Labor 

• Installation Labor 

Table A-1: Installation Labor Requirement 

Retrofit 

Type 

Incremental 

GW Installed 

Manhours/MWBoilermakers 

(%) 

Engineers 

(%) 

Others 

(%) 

FGD 22 760 40 20 40 

SCR 3 700 45 7 48 

ACI 92 10 50 17 33 

DSI 55 44 50 17 33 

FF 158.5 398 45 7 48 

Source: EPA Multi-pollutant Strategies 2002 report; DSI and FF adjustments based on Andover 

Technology Partners. 

Installation labor is estimated by using the incremental GW installed for each pollution control 

type from IPM. This was then converted into total man-hours needed for installation using 

estimates of man-hours/MW from the 2002 EPA study, supplemented by information from ATP. 

Total man-hours for each pollution control type were then converted into man-years assuming 

2080 working hours per year. 

Total man-years for each pollution control type were then broken down into various sectors 

using the percentages, shown in Table A-1. These percentages were estimated from the 2002 

study and supplemented by ATP information for DSI and FF. 

 

• Installation Resource Labor 

Table A-2: Installation Resource Needs 

Retrofit Type Steel 

(Tons/MW) 

FGD 2.25 

SCR 2.5 

10 
DRAFT 

ACI 0.35 

DSI 2.2 

FF 1.42 

*Direct workers per $Million in Output forecast to 2015. 

(Sources: Steel and Catalyst Usage: EPA Multi-pollutant Strategies 2002 report; Steel Price: 

Platts, Steel Markets Daily, Vol 3 Issue 209, October 29 2009; Productivity: 2000 Economic 

Census, BLS for Productivity Growth Rate 

For installation resource labor, steel is the primary resource input used for new pollution control 

installations, consistent with the 2002 EPA multi-pollutant study. The first step used the 

incremental installed pollution control capacity and estimates of steel usage (tons/MW), as 

shown in Table A-2 above, to calculate the total steel needed in tons, by pollution control type. 

Steel usage estimates were used from the 2002 EPA study, supplemented by ATP information 

for DSI and FF. The total amount of steel was then converted into a dollar value for steel 

expenditure using an average steel price ($550/ton), using data from Platts Steel Markets Daily 

(see notes to Table A-2 above). Resulting total steel expenditure was then converted to labor 

using the productivity estimates calculated from the Economic Census data using direct workers 

per $ Million in total output for the iron and steel manufacturing industry (= 2.1 

workers/$Million).23

• Operating Resource Labor 

Table A-3: Resources Needed for Operation

Retrofit 

Type 

Incremental 

Total GW 

(Includes 

Existing Units) 

Resource 

(Units in 

parenthesis) 

Usage 

Estimates

Price 

($/unit) Productivity* 

FGD 27 Limestone 

(Tons/MWh) 0.036 75 4.0 

SCR 

4.5 

(NOx reduction: 

296,731,400 

lbs) 

Ammonia 

(lbs/lb NOx 

Reduced) 

0.39 150 2.1 

Initial Catalyst 

(m3/MW) 1.2 

Operational 8,475 3.2 

Catalyst 

(m3/MWh) 

0.00002 

ACI 92 

Activated 

Carbon 

(Tons/MWh) 

0.000074 1,120 1.6 

DSI 55 

Sodium 

Bicarbonate 

(Tons/MWh) 

0.03 120 4.2 

 

23 In general, the productivity estimates for various sectors were derived using data from the 2000 or 2007 

Economic Census. These were then forecasted to 2015 using corresponding average growth rates 

estimated using data from the Bureau of Labor Statistic (BLS) information on productivity growth rates. 

11 
DRAFT 

FF 158.5 Bag-house 

Resources 

*Resource Labor 

determined Using 

VOM cost for FFs 

0.6 

*Direct Workers/$Million in Output, Forecasted to 2015 

Sources: Usage: EPA Multi-pollutant Strategies 2002 report, DSI from Andover Technology 

Partners; 

Prices: Limestone: FGD Tech Evaluation, March 2007 

Ammonia: Development of Supply Curves for Abatement of GHG from Coal-fired Utility Boilers, 

Air Pollution Prevention and Control Division, US-EPA, RTP and NC State University, 2009 

Catalyst: EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002. 

Activated, Carbon: Prelim. Cost Estimate of ACI for Controlling Hg Emission..., NETL. November 

2003 

Sodium Bicarbonate: Communication with Andover Technology Partners, Feb 7 2011; 

 Productivity: 2000 and 2007 Economic Census, Productivity Growth rates from BLS. 

Labor related to resources used in operating pollution control equipment was estimated using 

the total incremental GW of pollution control capacity which was first converted to total MWh of 

incremental capacity assuming 85 percent capacity factor. For each pollution control type, the 

next step involved choosing the primary operating resource, except for SCRs for which two 

resources – ammonia and catalyst – were chosen. 24 This approach is consistent with the 2002 

EPA study. The next step involved estimating the resource needs by each control type, 

generally in tons of material (m3 for catalyst), using the resource usage estimates as shown in 

Table A-3. 25 Using the total usage for each pollution control input (in tons or m3) and 

associated average prices, total expenditure by each resource type was then calculated. This 

total expenditure was then converted to labor using direct workers per $Million in total output for 

the industry associated with producing each respective input material.26

• Operating Labor 

Table A-4: Operating Labor Assumptions

Incremental FOM from IPM Parsed ($ Billion) 4.35 

FF Capital Cost Included in FOM ($ Billion) 2.99 

FGD Improvement included in FOM ($ Billion) 0.73 

Remaining FOM used to find O&M Labor ($ Million) 626.2 

Productivity* 8.7 

*Direct Workers per $Million in Payroll for Electricity Generating Sector, Forecast to 2015 

Sources: Productivity from 2007 Economic Census and Growth Rate from BLS. 

Labor requirement to operate the controls is estimated for all equipment types combined, using 

the incremental FOM costs from IPM. The IPM incremental FOM cost estimate included capital 

 

24 SCRs have an operational input of catalyst as well as an initial input needed when the unit is first 

installed. While the initial value is calculated using only the installed new control capacity, that number 

and the associated labor needs are included to estimate the total volume of catalyst required. 

25 Ammonia has a usage rate based on lbs of NOx reduced, so we estimated our ammonia usage using 

the total NOx reduced between the base and policy cases. 

26 Fabric filters follow a different pattern. Instead of a resource usage estimate, we used the VOM cost for 

FFs and converted this to jobs using the direct workers per million dollars output for the relevant 

manufacturing industry sector. 

12 
DRAFT 

costs for fabric filter and scrubber improvement costs, which were first subtracted to obtain the 

true FOM costs ($626.2 million). Resulting FOM cost estimate was then converted to labor 

needs using the direct workers/$ Million in total payroll for the Electric Generating Sector. 

 

Retirement Labor 

Table A-5: Inputs to Labor from Retirements 

O&M Decrease from Base to Policy Case From Parsed 

(BC_3e and BC_24) ($MM) 725.2 

Capacity of Incremental Retirements in Parsed (MW) 11,211 

Capacity of Incremental Retirements in SSR (MW) 10,173 

O&M Decrease scaled to SSR Retirements ($MM) (To 

account for Partial Retirements) 658.06 

Workers Per $Million in payroll, forecast to 2015 8.692 

Sources: Productivity from 2007 Economic Census and Growth Rate from BLS. 

Retirement labor was estimated by first identifying the retiring units from IPM parsed outputs 

(using incremental retirements in the policy case). The next step involved estimating the 

capacity of incremental retirements as well as the change in the O&M costs due to these 

retirements. Because of the discrepancies between partial retirements in IPM parsed outputs 

and System Summary Reports (SSR), O&M costs were scaled proportionately to reflect the 

lower SSR-based estimates, as shown in Table A-5 above. O&M cost decreases were then 

converted to job-years lost due to retirements using workers per $Million in payroll. 

Fuel Use Labor 

Table A-6: Inputs to Labor for Fuel Use 

Coal by Region 2015 Incremental Fuel USE (Tons) 2008 Short 

Tons/Employee hour

 Appalachia (17,020,000) 2.9

 Interior 10,720,000 4.8

 West (13,310,000) 19.9

 Waste Coal (720,000) 5.9

 

Natural Gas Change In Fuel Expenditure ($MM) Productivity *

 3,426.50 0.65

Pipeline Capital Cost of New Pipeline ($MM) Productivity *

 59.2 5.1

*Direct Workers per $Million in Output for Crude Petroleum and Natural Gas Extraction, and for 

13 
DRAFT 

14 

Pipeline Construction. 

Sources: Productivity from 2007 Economic Census, Short Tons per hour from US EIA, Coal 

Industry Annual. 

Fuel use related job impacts were estimated by using IPM results for incremental changes in 

coal and natural gas use (policy case over the base case). For coal, estimates of coal use in 

tons by region from IPM were used in conjunction with labor productivity estimates from the EIA 

for each region (in short tons/ employee hour), to calculate the change in job-hours needed. 

These were then converted to job-years, assuming 2080 working hours per year. As discussed 

in the main report above, because of the high variability in coal mining labor productivity in 

recent years, no attempt was made to forecast coal (and natural gas, for consistency) 

productivities, instead the most recent historical estimates were used in this TSD (which was the 

2008 labor productivity for coal). 

For natural gas, incremental change in fuel costs from IPM (policy case over the base case) 

was used, along with 2007 Economic Census data on productivity in workers per $million in 

output for the natural gas industry. These were then used to estimate the increased labor 

demand for natural extraction services. For pipeline capacity, a similar approach was applied, 

using the capital cost of new pipeline (from IPM) and labor productivity for the pipeline 

construction sector to estimate the labor needs. For both cases, to be consistent with coal and 

again because of the variability, most current confirmed productivity estimates from 2007 were 

used in the job-year calculations.