Supply Chain and Outage Analysis of

MISO Coal Retrofits for MATS

May 2012

Metin Celebi

Kathleen Spees

Quincy Liao

Steve Eisenhart

Prepared for

Midwest Independent Transmission System Operator

Copyright © 2008 The Brattle Group, Inc.
i

TABLE OF CONTENTS

Executive Summary.......................................................................................................................1

I. Background............................................................................................................................4

A. Purpose of Study............................................................................................................4

B. MISO’s Assessment of MATS Retirement and Retrofit Challenge ..............................4

II. Review of Previous Retrofit Supply Chain Studies............................................................7

A. EPA Study of the Feasibility of MATS Retrofits (December 2011)...........................10

B. EPA Study of Boilermaker Supply for CAIR (March 2005).......................................11

C. Andover Retrospective on Retrofits for CAIR (October 2010)...................................11

D. Southern Company Comments on Feasibility of MATS (August 2011).....................12

E. Cichanowicz Estimate of FGD and SCR Retrofit Timelines (October 2010).............12

III. Time and Labor Needs for New Build and Retrofit Projects..........................................13

A. Labor Inputs.................................................................................................................13

B. Outage Duration Associated with Environmental Coal Retrofits................................14

C. Project Timelines.........................................................................................................17

IV. Historical Maximum Levels of Construction and Retrofits ............................................19

A. Environmental Controls Retrofits................................................................................19

1. National Historical Control Retrofits....................................................................19

2. Control Retrofits in the Midwest ..........................................................................20

B. Generation Construction ..............................................................................................21

1. National Historical Generation Construction .......................................................21

2. Generation Construction in the Midwest..............................................................23

C. “Soft Cap” on Industry Capability Based on Historical Maximums...........................23

1. Retrofits on a Wet FGD Equivalent Basis............................................................24

2. New Generation Construction on a CC Equivalent Basis ....................................27

3. Retrofits and New Generation on a Wet FGD Equivalent Basis..........................29

V. Projection of MATS Compliance Impacts ........................................................................31

A. Timeline for MATS Compliance Relative to Construction Timelines........................31

B. Needs Relative to “Soft Cap” on Industry Capability .................................................32

1. Projected National MATS Requirements on a Wet FGD Equivalent Basis.........32

2. Projected Midwest MATS Requirements on a Wet FGD Equivalent Basis ........34

3. Comparison of Projected MATS Requirements to “Soft Cap” ............................35

C. Demand from MATS Relative to Labor Supply..........................................................37

D. MISO Retrofit Outage Analysis...................................................................................41

VI. Summary of Findings..........................................................................................................42

Bibliography .................................................................................................................................45

List of Acronyms..........................................................................................................................48

Appendices....................................................................................................................................49

Appendix A. Timelines for Typical Environmental Retrofit Projects..............................50

Appendix B. Projected Retrofits and New Generation Plants in MISO...........................51

Appendix C. Estimated Labor Requirements for Retrofit Projects ..................................52
ii

Copyright © 2012 The Brattle Group, Inc. This material may be cited subject to attribution.

About the Authors

Metin Celebi is a Principal, Kathleen Spees is an Associate, and Quincy Liao is a Research 

Analyst of The Brattle Group, an economic consulting firm with offices in Cambridge 

Massachusetts, Washington D.C., San Francisco, London, Rome, and Madrid. They can be 

contacted at www.brattle.com. Steve Eisenhart is President of VATIC Associates.

Acknowledgements

The authors would like to thank Eric Laverty and Ryan Westphal of MISO for their cooperation 

and responsiveness to our many questions and requests. We would also like to acknowledge the 

research and analytical contributions of Khanh Nguyen. Opinions expressed in this report, as 

well as any errors or omissions, are the authors’ alone.
1

EXECUTIVE SUMMARY

The Environmental Protection Agency’s (EPA’s) new Mercury and Air Toxics Standard 

(MATS) will require the coal and oil fleet in the U.S. to comply with certain emissions standards

by April 2015, with a potential 1-year extension from permitting authorities. This standard will 

require much of the U.S. coal fleet to install retrofit controls for compliance or face retirement.

Nation-wide estimates project that 93-248 GW of coal (measured in Wet Flue Gas 

Desulfurization (FGD) equivalent GW) will require environmental controls upgrades, while the 

Midwest Independent Transmission System Operator (MISO) projects 51-58 Wet FGD 

equivalent GW will require upgrades in the Midwest alone. Many coal units will retire rather 

than make the required capital investments, with about 30 GW having already announced 

retirement plans nationwide. To replace this retiring generation and meet load growth 

requirements by 2015, another 30-84 GW of new generation may be needed nationally, while 5-

26 GW may be needed in MISO.

MISO asked us to help evaluate the feasibility of the large number of simultaneous 

environmental retrofits and new generation that may be needed in conjunction with the MATS 

rule. In particular, MISO asked us to:

 Evaluate the scale of the retrofit and new build requirements for MATS by 2015/16 

relative to the capability of the retrofit and construction industry; 

 Identify potential labor supply chain bottlenecks to meeting these requirements;

 Estimate the level of outages needed on the existing fleet for installing and testing new

environmental retrofits; and

 Evaluate the extent to which these retrofits, new generation, and required outages can be 

implemented by the MATS compliance date of April 2015 with possible extensions to 

2016.

To evaluate these questions, we surveyed existing literature, interviewed retrofit project 

developers and electric utilities, evaluated historical simultaneous project installations, and 

examined retrofit outages. With respect to the timeline needed for retrofits, we find that some 

types of upgrades can be implemented before 2015 without difficulty, including activated carbon 

injection (ACI) and dry sorbent injection (DSI), which can be implemented within approximately 

a year and a half. However, most projects have a longer lead time of approximately 3-4 years,

including wet and dry FGD, baghouse, electrostatic precipitator (ESP), and selective catalytic 

reduction (SCR), as well as new gas combustion turbines (CTs) and combined cycles (CCs). 

Some of these long-lead projects will be able to come online prior to the MATS deadline, 

particularly as many of them are already under development. Many plant owners have already

announced upgrade plans, although many others are likely still in the scoping phase. For the 

retrofit projects that need state commission approval of cost recovery to move forward, their 

ability to meet the MATS deadline will in part depend on the states’ speed of approval when 

evaluating a large number of projects at once. These long lead times introduce a substantial 

concern for any long-lead projects that are initiated late, both due to the timing constraint and 

due to the potential for difficulty in obtaining the necessary engineering and construction support 

during a period of very high demand.
2

To evaluate the scale of the supply chain demands from MATS, we compared projected retrofit 

and new build demands against the historical maximum for the industry in the U.S. and 

nationally. We separately looked at retrofits and new builds on a Wet FGD-equivalent basis, 

converting the MW of upgraded or built capacity into one equivalent unit based on capital costs. 

This approach reflects our assumption that capital costs are a reasonable indicator of the 

demands that a particular retrofit will impose on labor and equipment supply chains. We find

that MATS will require retrofit and new build activities that exceed the historical industry 

maximum in the Midwest by 51%-162% based on MISO’s projected retrofit requirements and 

individual plant owner announcements. For the nationwide retrofits, the needs imposed by 

MATS could be substantially below historical maximums if the EPA’s projections are correct, or 

up to 93% above historical maximums if industry estimates are more accurate. We believe that 

the EPA estimates may be optimistic while industry estimates may be pessimistic, especially in 

the highest retrofit cases. 

It appears that MATS will require a ramp up in labor, engineering, equipment, and construction 

that is likely to introduce substantial bottlenecks locally or nationally. These bottlenecks are 

likely to introduce delays or cost escalation, for example, if certain craft labor categories or 

qualified engineering, procurement, and construction (EPC) firms are in short supply. The 

competitive marketplace will find opportunities to mitigate such concerns (e.g., by increasing 

labor supply with training, relocation, and overtime) but such measures are costly and timeconsuming. 

We evaluated the potential for craft labor to become a bottleneck that could introduce project

delays. Based on our estimates of typical craft labor requirements for retrofits and new 

construction, we projected a time profile of craft labor required for MATS compliance. 

Comparing projected labor needs against the current labor supply for each craft revealed that

boilermakers are the most likely bottleneck. As many as 7,590 boilermakers (or 40% of 

boilermakers currently employed nationally) could be needed to complete the projected retrofits 

and new generation construction by 2015. This potential demand is more than four times the 

number of boilermakers (1,850) currently employed in the Utility System Construction Industry.1 

Therefore, meeting the projected demand for boilermakers will likely require a combination of 

adjustments on the supply side, including training new labor, relocation, extending work hours, 

and attracting craft labor from other industries.

Finally, we examined the potential impacts of MATS on MISO’s outage scheduling process by 

examining the length of planned outages that coal units need in typical years compared with the 

duration of outages associated with plant retrofits. Based on our interviews with project 

developers and electric utilities, we understand that most of the construction and installation 

associated with retrofits can be completed while the plant is operating, although final tie-in to 

major plant systems can only be done during a plant outage. These tie-ins will usually be 

scheduled concurrently with other standard maintenance during a planned outage but will require 

a longer than typical outage for completion. Based on an analysis of historical plant operations 

for coal plants, we estimate that some upgrades such as Dry FGD, DSI, SNCR, and ACI require 

that the outage duration need only be extended a few days or a week, although some types of 

 

1 According to the Bureau of Labor Statistics definitions, the Utility System Construction Industry includes 

utility construction activities in power, communication, oil, gas, water and sewer sectors, see U.S. Census 

Bureau (2012).
3

upgrades impose much longer outages. Wet FGD, baghouse, and SCR retrofits are likely to 

require outages be extended by approximately three weeks. 

Considering the fleet-wide impacts of these outages, it appears that MISO may have to schedule 

approximately 45% more MW of coal outages per season for MATS compliance by Fall 2015 

(which assumes many plants will gain a 1-year compliance extension). The impact of these 

additional outages is further exacerbated by the fact that a substantial fraction of coal plants are 

likely to retire rather than comply with MATS, hence reducing the system’s ability to absorb 

additional outages. Based on MISO’s initial analysis of the fleet’s ability to absorb outages, it 

appears that the total quantity of outages for MATS could be easily absorbed and scheduled in its

low retirement scenarios. However, in MISO’s 12 GW retirement scenario, it appears that MISO 

may only be able to absorb these outages by extending its typical 6-month (fall and spring) 

outage season to a 9-month (fall, winter, and spring) season. In MISO’s even higher 19 GW 

retirement scenario, it appears likely that the RTO would not be able to schedule all of the 

needed outages even in a 9-month window without facing reliability concerns or gaining an 

additional 1-year reliability extension to 2017. 

Overall, meeting MATS will be a major challenge for the industry, states, and MISO for a 

number of reasons. The industry will need to install retrofits at a pace and scale that exceeds the 

historical demonstrated capability, while the system operator is likely to experience a substantial 

operational challenge in the transition. 
4

I. BACKGROUND 

A. PURPOSE OF STUDY

The Midwest Independent Transmission System Operator (MISO) asked us to assess the 

feasibility of a large simultaneous deployment of environmental retrofits and new generation

prior to the compliance deadline of the Environmental Protection Agency’s (EPA’s) new 

Mercury and Air Toxics Standards (MATS). Specifically, MISO asked us to:

 Evaluate the scale of the retrofit and new build requirements for MATS by 2015/16 

relative to the capability of the retrofit and construction industry; 

 Identify potential labor supply chain bottlenecks to meeting these requirements;

 Estimate the level of outages needed on the existing fleet for installing and testing new 

environmental retrofits; and

 Evaluate the extent to which these retrofits, new generation, and required outages can be 

implemented by the MATS compliance date of April 2015 with possible extensions to 

2016.2

MISO asked us to evaluate the implications for the Midwestern system, as well as nationally, to 

help inform their and stakeholders’ planning activities over the coming years. We do not present 

here an independent estimate of the retrofit, retirement, and new build impacts of MATS, which 

is a substantial analytical effort beyond our scope. Instead, we rely on the previously-completed 

studies of MISO, the EPA, and Edison Electric Institute (EEI). As we document in the following 

sections, MISO has analyzed a range of potential impacts on its coal fleet from MATS, while for 

national MATS impacts we draw on EPA and EEI studies that represent relatively low and high 

impact estimates respectively.

B. MISO’S ASSESSMENT OF MATS RETIREMENT AND RETROFIT CHALLENGE

MISO has screened the characteristics of the current coal fleet to project the likely retirement and 

retrofit impacts of MATS. MISO has also projected the total new generation capacity that will

be needed to replace projected coal retirements. MISO assessed these questions under four 

retirement scenarios through 2016: (i) a no retirement case; (ii) a 3 GW retirement case; (iii) a 12 

GW retirement case; and (iv) a 19 GW retirement case. In all cases, except the 19 GW 

retirement case, MISO also assumed that none of the units would need to install Selective 

Catalytic Reduction (SCR) control equipment to comply with MATS or the Cross State Air 

Pollution Rule (CSAPR). We supplemented MISO’s projections of needed retrofits with the 

most recent owner announcements of environmental control equipment installations to be online 

by 2016.

3

 

2

The compliance deadline is 60 days plus 3 years from the date of publication in the Federal Register, 

which was February 16, 2012. See Federal Register (2012), p. 9407.

3

In addition, because coal units smaller than 25 MW are not covered by MATS, we eliminated coal units 

smaller than 25 MW from the list of units that MISO had initially projected to need retrofits. Additional 

information on MISO’s retrofit, retirement, and new build projections is available in MISO (2011).
5

Figure 1 summarizes MISO’s projected environmental retrofits and new generation in the 

Midwest by 2016 under the four scenarios. Out of MISO’s existing 71 GW coal generation fleet,

49-63 GW are expected to install at least one environmental retrofit by 2016. A large fraction of 

these coal units (28-38 GW) are projected to require two or more controls systems for 

compliance. In addition, MISO expects 5-26 GW of mostly gas-fired new generation capacity 

will need to be built by 2016 to replace the retiring coal units and to meet load growth. A more 

detailed summary of the projected retrofits and new generation plants in MISO region is 

provided in Appendix B.

Figure 1

MISO Projection of Midwestern Retrofits and New Builds in Four Scenarios

(Existing Coal Fleet in Blue; Projected New Generation in Red)

Sources and Notes:

Data from MISO (2011) and Ventyx (2012).

New generation includes all plants currently under construction as well as all MISO-projected new builds.

Original MISO projected retrofits updated with most recent plant owner announcements.

Figure 2 shows the breakdown of projected environmental control retrofits in MISO by type of 

control and number of control systems required. Data from announced retrofit projects 

combined with MISO’s predictions indicate that 49-63 GW of coal capacity is likely to require at 

least one control retrofit to comply with MATS. These projections include dry flue gas 

desulfurization (FGD) on 17-22 GW, wet FGDs on 7 GW, baghouses on 41-57 GW, dry sorbent 

injection (DSI) on 1-11 GW, activated carbon injection (ACI) on 2-11 GW, SCRs on 5-30 GW, 
6

and selective non-catalytic reduction (SNCR) on less than 1 GW of coal capacity. Note that 

MISO’s screening study did not explicitly evaluate whether SNCR, Wet FGD, or electrostatic 

precipitator (ESP) upgrades would or should be installed. For this reason, the summary in Figure 

2 includes only announced upgrades for those types of controls.4

Single-equipment retrofits are expected to be in the range of 17-26 GW, with the majority of the 

coal fleet requiring multiple equipment installations for compliance, including: 15-24 GW 

installing two controls, 7-17 GW installing three controls, and less than 1 GW installing four 

controls. 

Figure 2

Estimated Breakdown of Coal Retrofits by Control Type in MISO

Sources and Notes:

Data from MISO (2011) and Ventyx (2012).

Original MISO projected retrofits updated with most recent plant owner announcements.

 

4

For controls such as Wet FGD and Dry FGD that would be redundant between MISO’s original projection 

and more recently-announced upgrades, we relied on the owner’s announcements. 

Type of Control 

Retrofit Needed

Number of Controls 

Needed per Plant
7

II. REVIEW OF PREVIOUS RETROFIT SUPPLY CHAIN STUDIES

As a starting point to our analysis, we summarize the findings from existing studies and industry 

positions on industry’s capability to install all needed controls in time to comply with MATS.

5

We summarize these “capability” assessments in two key dimensions. The first is a comparison 

of estimated timelines for installing various individual retrofits against the regulatory compliance 

timeline. The second is the capability of the supply chain in the environmental retrofit industry 

with respect to available labor force in key occupations and manufactured equipment to meet the 

large simultaneous demand for retrofits. 

The EPA finalized the MATS rule in December 2011, requiring coal and oil-fired power plants 

to reduce emission rates of mercury, acid gases, and non-mercury metals below specific limits by 

April 2015.6In addition to the three-year statutory requirement, the EPA allows a potential 1-

year extension of the deadline if approved by state permitting agencies, and a further 1-year 

extension under the circumstances where a power plant would need to continue operations in 

order to maintain reliability.7 

The MATS rule will require coal plants to install various combinations of controls depending on 

the unit’s existing controls, boiler type, type of coal used, and economic factors. The control 

equipment needed to comply with MATS may include Wet or Dry FGD, SCR, fabric filter (or 

baghouse), DSI, or ACI. The estimated mix and number of the needed retrofits is uncertain for

two reasons. First, it is uncertain which coal units will be retired to avoid investing in retrofits. 

Second, the estimated removal efficiency of certain equipment such as DSI to meet the MATS 

requirements is not yet fully known because this equipment has not yet been widely used. 

 

5

See EPA (2011a).

6

The compliance deadline is 60 days plus 3 years from the date of publication in the Federal Register, 

which was February 16, 2012. See Federal Register (2012), p. 9407.

7

EPA states that it expects that few or no reliability exceptions of this type to be needed, see EPA (2011d).
8

We reviewed the studies listed in Table 1 on the estimated capability of the environmental 

retrofit industry to install the control equipment necessary to comply with EPA regulations, and 

summarize the major findings from these studies in the following sections.

Table 1

Reviewed Literature on Feasibility and Timelines of Environmental Retrofits

Study Author Title Date

EPA (2011b) U.S. EPA An Assessment of the Feasibility of Retrofits for the Mercury and Air 

Toxics Standards Rule

December 2011

DOE (2011) U.S. DOE Resource Adequacy Implications of Forthcoming EPA Air Quality 

Regulations

December 2011

IEc (2011) Industrial Economics, 

Inc.

Employment Impacts Associated with the Manufacture, Installation 

and Operation of Scrubbers

March 2011

Southern (2011a) Southern Company Southern Company’s Comments on EPA’s Proposed Utility MACT Rule August 2011

Southern (2011b) Thomas Fanning 

(Southern Company)

Recent EPA Rulemakings Relating to Boilers, Cement Manufacturing 

Plants, and Utilities

April 2011

Cichanowicz (2010) Edward Cichanowicz Implementation Schedules for Selective Catalytic Reduction (SCR) And 

Flue Gas Desulfurization (FGD) Process Equipment

October 2010

URS (2011) URS Corporation Assessment of Technology Options Available to Achieve Reductions of 

Hazardous Air Pollutants

August 2011

ICAC (2010) Institute of Clean Air 

Companies

Letter to Senator Carper on Labor availability and the Capacity of the 

Electric Power Industry to Install Air Pollution Control Systems

November 2010

Andover (2010) James Staudt 

(Andover Technology

Partners)

Availability of Resources for Clean Air Projects October 2010

EPA (2005a) U.S. EPA Feasibility of Installing Pollution Controls to Meet Phase I 

Requirements of Various Multi-Pollutant Legislative Proposals

October 2005

EPA (2005b) U.S. EPA Boilermaker Labor Analysis and Installation Timing March 2005

EPA (2002) U.S. EPA Engineering and Economic Factors Affecting the Installation of Control 

Technologies for Multipollutant Strategies

October 2002
9

Estimates of the “typical” timelines for design, construction. and installation of environmental 

retrofits vary considerably. As shown in Figure 3, a typical Wet FGD installation is estimated to 

take as little as 27 months according to the EPA, or as long as 54 months according to Southern 

Company. Similar differences among estimates apply to typical timelines for other control 

equipment: 21-30 months for Dry FGD, 21-40 months for an SCR, 18-40 months for a 

baghouse, 11-18 months for DSI, and 15 months for ACI. A more detailed description of these

estimated timelines from the literature is available in each of the source studies.

Figure 3

Estimated Months to Design, Permit, Construct, and Install Retrofit Equipment

Sources and Notes:

EPA (2002) and EPA (2011b); URS (2011); ICAC (2010); Cichanowicz (2010); Southern Company (2011a) and Southern 

Company (2011b).

There is disagreement among existing studies with respect to the feasibility of meeting all needed 

MATS upgrades, including the potential for shortages in in key labor occupations and 

manufactured equipment. On one side of this debate, studies by the EPA and Andover 

Technology Partners argue that the required retrofits are lower than the historical deployments of 

retrofits and new generation plants, and that installation timelines necessary to complete these 

projects are short enough to bring the projects online before the MATS compliance date in 2015 

(or 2016 with a one-year extension). 

On the other side of the debate, studies by EEI, Southern Company, and Edward Cichanowicz 

argue that the EPA has severely underestimated the number of expensive and resource-intensive 

retrofits that will be required including scrubbers, baghouses and SCRs. These studies project 

that a larger share of the coal fleet will retire and that more new generation capacity will be 
10

needed to maintain system reliability. In addition, these studies estimate substantially longer 

timelines necessary to bring the retrofit equipment and the new generation plants online.

We more fully summarize the primary arguments in select studies that we consider 

representative of these two differing viewpoints in the remainder of this Section.

A. EPA Study of the Feasibility of MATS Retrofits (December 2011)

The EPA conducted a study on the feasibility of retrofitting coal plants for compliance with 

MATS, and concluded that the majority of needed retrofits can be completed by January 2015 

with some coal plants potentially needing an additional year for compliance.

8

 The study 

approach was to compare maximum historical simultaneous retrofits and new coal builds against 

the quantity of retrofits that the EPA projects will be needed for MATS. The EPA estimated that 

simultaneous installations of new and retrofit SCR and FGD installations over 1990-2011 

reached an approximate maximum of 38 GW in 2009. The EPA also converted historical 

equipment retrofits and new coal generation addition to a single metric (“equivalent wet FGD 

capacity”) based on the ratio of capital costs for each type of retrofit. This calculation resulted in 

an annual maximum of approximately 70 GW in 2009 for the simultaneous deployment of 

environmental retrofits and new coal units.

9

 The EPA also noted that there were large additional 

deployments of new gas combined cycles (CCs) during the period 2009-2011, relying on some 

of the resources that are used in retrofit projects. Finally, the EPA commented that the historical 

data on retrofit deployments show the industry was able to ramp up retrofit activity by 45% per 

year over 2006-2009.

In comparison to these data on historical total retrofits and new coal generation, the EPA projects 

that a total 64 GW (wet FGD equivalent) of coal retrofits will be needed nationally. The EPA’s 

estimated mix of retrofit projects include: 85 GW of baghouses, 44 GW of DSI, 99 GW of ACI, 

20 GW of dry FGD with baghouse, 63 GW FGD upgrades and 34 GW ESP upgrades. We also 

note that the EPA does not include any wet FGD upgrades in its projection. Since the industry’s 

historical demonstrated capability of 70 GW wet FGD-equivalent exceeded the MATS 

requirement of 64 GW, the EPA concluded that meeting MATS is likely feasible even if nearly 

all MATS retrofits must be installed in the same year.

In addition, the EPA argued that other factors work in favor of the power sector’s ability to meet 

MATS compliance deadlines. These include the EPA’s expectation that many coal unit owners 

have already done retrofit planning for their units, and that some “early movers” will start 

retrofitting their plants before others to avoid potential increases in retrofit costs. In addition, the 

EPA expects that the construction timeline for retrofits can be substantially accelerated compared 

to historical experience, and result in wet FGD and dry FGD projects being completed in 27 

months and 21 months, respectively. Finally, the EPA expects owners of coal units to be bettermotivated to move early on retrofit decisions compared to historical experience with other 

environmental regulations because MATS does not offer trading flexibility and requires plantlevel compliance unlike the Clean Air Interstate Rule that was applicable until 2011.

 

8

EPA (2011b).

9 Note that this comparison covered the shorter period of 2005-2011, compared to the SCR and FGD 

comparison that covered the longer period of 1990-2011.
11

B. EPA Study of Boilermaker Supply for CAIR (March 2005)

The EPA released a study in March 2005 that assessed the feasibility of installing control 

equipment retrofits for SO2 and NOX control as required by Clean Air Interstate Rule (CAIR).10 

That study focused on the likely availability of boilermakers, which were considered a potential 

bottleneck in completing the required retrofits. In order to complete the projected retrofits of 70 

GW of FGDs and 46 GW of SCRs by 2010 in one of the scenarios (over approximately four 

years), the study estimated that the required boilermakers would exceed available boilermakers 

by about 25%.

11

 The number of boilermakers available for the environmental retrofits (26,185 

boilermaker-years) was derived by assuming 35% of the total projected boilermakers in the 

nation would be available to be employed for retrofits, supplemented by labor from Canada, nonunion sources, and from the estimated additional boilermakers due to fewer projected new 

generation plants. The assumed boilermaker requirements for retrofits on 1 GW of coal capacity

were 260 boilermaker-years for FGDs and 343 boilermaker-years for SCRs. 

In retrospect and with the benefit of hindsight, this study appears to have over-estimated the 

scale of the problem of boilermaker bottlenecks at that time. While the EPA’s estimate of 70 

GW of FGD installations was very close to the realized retrofits over 2005-2010, the SCR 

estimate of 46 GW was approximately twice the realized number as shown in Figure 7 below. 

Further, according to labor data from the Bureau of Labor Statistics (BLS), while the number of 

boilermakers employed in the “utility system construction” industry increased almost threefold 

from 680 in 2006 to 1,850 in 2011, this maximum employment is still far below the level 

originally estimated by the EPA.12 Further, utility system construction has never drawn more 

than 11.7% of the total national employment of boilermakers.13

C. Andover Retrospective on Retrofits for CAIR (October 2010)

Dr. James Staudt of the Andover Technology Partners authored this study to compare projections 

against actual performance regarding the ability of power plants to install retrofit equipment for

CAIR.14 The projected combined retrofits of FGDs and SCRs were in the range of 73-89 GW 

over a five-year period to meet the CAIR I deadline in 2010. Staudt’s whitepaper provides a 

summary of various projections by the EPA and industry organizations such as the Utility Air 

Resources Group (UARG) and the Institute of Clean Air Companies (ICAC) on retrofit project 

timelines and potential resource bottlenecks.

The study concludes that the actual performance of the retrofit supply-chain to meet CAIR 

deadlines exceeded most of the projections without being constrained by the assumed “hard 

 

10 EPA (2005b).

11 We should note that the estimated mix of 70 GW of FGDs and 46 GW of SCRs in the scenario described 

above would correspond to about 78 GW in Wet FGD-equivalent measure by using the equivalency 

factors we derive in Table 5 below.

12 Note that the EPA’s estimate of 26,185 boilermaker-years would amount to 6,546 on average over four 

years or almost three times the number actually employed in the utility system construction industry. See 

BLS (2011).

13 In 2010, 2,220 boilermakers were employed in the utility system construction industry while the national 

employment of boilermakers was 19,030. Note that national employment of boilermakers in 2010 was 

actually down in 2010 from the higher employment of 22,400 in 2009. See BLS (2010).

14 Andover (2010).
12

caps” in some studies on the total labor force in specialized construction labor such as 

boilermakers. The whitepaper argues that there are no “hard caps” on boilermakers that can be 

employed in retrofit projects since the market for labor is dynamic. Staudt attributes the dynamic 

nature of the labor market to: (i) the ability to work overtime during periods of high demand; (ii) 

the availability of non-union labor to supplement boilermakers from unions; (iii) the option of

relying on non-local boilermakers including from Canada; (iv) the possibility of shifting

boilermakers from other sectors such as refining, petrochemical, shipbuilding, etc.; (v) new 

boilermakers joining the labor force as demand picks up; and (vi) alternative fabrication methods 

such as off-site construction. 

D. Southern Company Comments on Feasibility of MATS (August 2011)

The Southern Company submitted comments to the EPA in August 2011 on the initial proposed 

version of MATS.

15

 With respect to the feasibility of complying within the three-year 

compliance period, Southern argued that the proposed timeline is unachievable and unrealistic 

for three reasons. First, that the electric industry will face the challenge of complying with 

multiple and overlapping environmental regulations in addition to MATS. Second, that 

implementing the retrofits that the EPA estimated as necessary for compliance is not feasible in 

three years because these projects typically require more than three years to complete. For 

example, Southern pointed to its own experience with FGD retrofits that took an average of 54 

months (over a range of 40-69 months) to complete. Similarly, Southern expects that baghouse 

retrofits would need 40 months to complete (over a range of 34-48 months) based on 17 

baghouse projects that Southern is considering. 

Third, Southern argued that the EPA under-estimated the number of retrofits that would be 

needed for compliance. Southern pointed to studies that estimated far higher numbers of retrofits 

and new generation needs than the EPA projected, and argued that this scale of retrofits and new 

generation could not be completed at any cost within the three-year deadline. For example, 

Southern pointed to the results of an EEI/ICF study in 2011 estimating more than 80 GW of 

scrubbers, over 160 GW of baghouses, and 80 GW of new generation capacity would be needed 

to comply with EPA regulations.

E. Cichanowicz Estimate of FGD and SCR Retrofit Timelines (October 2010)

In a study prepared for UARG, Edward Cichanowicz provided typical schedules for recently 

implemented projects, including 22 FGD retrofits and 14 SCR retrofits.

16 According to these 

data, Mr. Cichanowicz concluded that the average time to retrofit FGD on a single unit would be 

48 months (over a range of 40-64 months), and the average time to retrofit an SCR on a single 

unit would be 40 months (over a range of 28-50 months). Mr. Cichanowicz challenged the 

substantially shorter timelines estimated by the EPA (27 months for FGD and 21 months for 

SCR) on the grounds that the sample projects that the EPA relied on were constructed a long 

time ago when the total demand for retrofits was low and permitting was easier.

 

15 Southern (2011a).

16 Cichanowicz (2010).
13

III. TIME AND LABOR NEEDS FOR NEW BUILD AND RETROFIT PROJECTS

As an input to our supply chain and outage analysis, we examine the labor, timing, and outage 

duration requirements for implementing each of a number of different types of coal retrofit and 

new generation projects. To evaluate labor inputs and project timelines, we conducted 

interviews with ten electric utility companies and eight engineering and equipment 

manufacturing companies. To evaluate outage needs for retrofit installations, we analyze

publicly-available data on outage timing and duration for plants during normal conditions and at 

times when new controls were being installed.

A. LABOR INPUTS 

Retrofit and new generation projects require various types of labor throughout the permitting, 

design, construction and installation phases. Based on interviews with ten electric utility 

companies and eight engineering and equipment manufacturing companies, we identified the 

categories of labor (consistent with the definitions in the Bureau of Labor Statistics databases) 

that are typically employed in environmental retrofit and new generation projects. The 

categories of labor we evaluated include boilermakers, design engineers, plumbers, electricians, 

and welders among others. 

We compiled information on full-time equivalent labor-months necessary from each labor 

category in each phase of the projects. This information is based on our interviews with utility 

companies and engineering and equipment manufacturing companies, and is supplemented with 

information compiled by the Electric Power Research Institute (EPRI).

17

 In addition to labor 

data, we tracked plant sizes on which the retrofits were implemented in order to specify a typical 

plant size consistent with our estimated labor needs. We then normalized the estimated labor 

requirements on a plant sized at 1,000 MW. 

 

17 EPRI (2000), (2001), and (2007).
14

Table 2 shows our estimate of the person-months of labor required for a typical dry FGD retrofit 

project installed at a coal plant with 1000 MW capacity. As shown in Table 2, this project would 

require a total of 217 person-months from design engineers, 979 from plumbers, pipefitters and 

steam fitters, and 671 from boilermakers among others. Similar tables for each type of retrofit 

are provided in Appendix C.

Table 2

Person-Months Needed for a Typical Dry FGD Project

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

B. OUTAGE DURATION ASSOCIATED WITH ENVIRONMENTAL COAL RETROFITS

One of the objectives of our analysis is to evaluate the scale of impacts from a large number of 

simultaneous retrofits on MISO’s outage planning for the MATS compliance years. A first step 

in this analysis is to determine the need for planned outages for a coal plant during normal years, 

and compare this with the longer outages needed when installing environmental retrofits. 

An important point to note when analyzing outages associated with coal retrofits is that most of 

the construction activities associated with these retrofits may be completed while the plant is 

operating. However, any portion of the upgrade that involves a tie-in to the facility’s major 

systems will need to be done during a unit outage. Most of these final installation steps will Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 3 38 18 46 112 0 0 217

Construction / Site Engineers 0 10 148 31 699 16 6 910

Licensing Engineers 4 7 12 31 56 0 0 109

Procurement Engineers 0 17 0 76 140 0 0 233

Project Managers 2 7 0 31 56 2 1 98

Construction Managers 0 7 0 0 224 3 0 233

First Line Supervisors 0 0 0 0 224 0 0 224

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 979 0 0 979

Boilermakers 0 0 0 0 671 0 0 671

Electronic and Control Systems Specialists 0 0 0 0 364 0 0 364

Pipe Layers 0 0 0 0 615 0 0 615

Electrician - In-House Systems 0 0 0 0 224 0 0 224

Electrician - Power Line Installers 0 0 0 0 224 0 0 224

Iron/steel Workers 0 0 0 0 419 0 0 419

Brickmasons and Blockmasons 0 0 0 0 615 0 0 615

Concrete Finishers 0 0 0 0 196 0 0 196

Operator Pile Drivers 0 0 0 0 112 0 0 112

Carpenters 0 0 0 0 531 0 0 531

General Construction Labor 0 0 0 0 1,566 0 0 1,566

Insulation Workers 0 0 0 0 224 0 0 224

Reinforcing Iron and Rebar Workers 0 0 0 0 224 0 0 224

Welders, Solderer 0 0 0 0 364 0 0 364

Construction Equipment Operators 0 0 0 0 280 0 0 280

Power Plant Operators 0 0 0 0 0 9 0 9
15

typically be scheduled at the same time as other major maintenance activities that would have 

required a normal planned outage in any case. Overall, we would not expect most upgrades to 

require an entirely new planned outage, but will likely require longer outages than in typical 

years.

To characterize the magnitude of this impact, we analyzed outage patterns in the U.S. coal fleet 

over the past decade using data from the EPA’s Continuous Emissions Monitoring System 

(CEMS) database.18 We identified outages that coincided with specific types of controls retrofits 

and those that were typical outages during which no retrofits were completed. Note that because 

the CEMS database that we used as our source does not distinguish between planned outages and 

other outages, we must assume that the outages in our sample will also include some quantity of 

maintenance outages and economic outages. We account for this inclusion of non-planned 

outages in Section V.D below by supplementing this analysis with average outage rates from the 

North American Electric Reliability Corporation (NERC) Generating Availability Data System 

(GADS). 

Figure 4 and Table 3 summarize the average and range of outage lengths for coal plants that 

were and were not installing retrofits. The figure shows that all types of outages can span a 

relatively large range of durations, but that retrofits can extend the outage durations for days or 

weeks depending on the control type being installed. For SNCR, ACI, DSI, and Dry FGD 

upgrades, the impact is relatively minor with the needed outage extending only up to 8 days 

longer than a typical outage. For SCR, baghouse, and wet FGD retrofits the impact is much 

more substantial in that these upgrades impose approximately 19-24 days of additional outages. 

 

18 The CEMS database does not identify outage hours, but instead reports the hourly generation output for 

every monitored facility. We identified planned outages as those data series for which generation output 

was zero for at least 10 consecutive days, and filtered out certain categories of plants that may have 

anomalous outage patterns including plants more than 56 years old, smaller than 75 MW or within a few 

years of online or retirement date.. Compiled from Ventyx (2012).
16

Figure 4

Historical Controls Retrofits in the U.S. on a Wet FGD Equivalent Basis

Sources and Notes:

Outage duration data compiled from EPA CEMS database, Ventyx (2012).

Outages ≥ 10 days’ duration included in summary. 

Outages associated with major equipment upgrades identified based on outage start/end dates and upgrade online date.

Table 3

Average and Incremental Average Outage Days Needed

For Each Type of Control Retrofit

Sources and Notes:

Data compiled from EPA CEMS database, Ventyx (2012).

Outage

Type

Average 

Outage Length

Incremental 

Outage Time

(days) (days)

Without Retrofit 30.4 n/a

With Retrofit

Wet FGD 50.5 20.1

Dry FGD 38.2 7.8

DSI 36.0 5.6

Baghouse 54.7 24.2

SCR 49.3 18.8

SNCR 31.8 1.3

ACI 36.4 6.0
17

C. PROJECT TIMELINES

We estimated the typical timelines needed for permitting and building new gas CCs and 

combustion turbines (CTs), as well as for retrofitting coal plants with various environmental 

controls. We compiled this timeline information from our interviews with ten electric utility 

companies and eight engineering and equipment manufacturing companies. Table 4 is a 

summary of our estimates for total months to complete each type of retrofit. Note that our 

approach to estimating these project timelines results in project durations that are closer to

industry estimates of retrofit lead time than to EPA estimates, putting our estimates on the higher 

end of the numbers that we compiled from literature and reported in Figure 3 above. Further, our 

estimates will tend to be on the high end compared to some other sources (including the EPA)

because they are compiled to the extent possible from industry participants’ experiences on a 

selection of actual projects, some of which have experienced various permitting, contracting, or 

installation delays.

Table 4

Estimated Duration of New Generation and Retrofit Projects

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, 

Dominion, Duke, First Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and 

Wisconsin Electric) and equipment manufacturing and construction companies (Babcock and Wilcox, 

Bechtel, Washington Group, Alstom, IHI Corporation, and Foster Wheeler).

Project Duration

(months)

New Generation

New CC 50

New CT 41

Retrofit

Wet FGD 56

Dry FGD 46

DSI 19

ACI 19

Baghouse 38

ESP 39

SCR 47
18

Figure 5 shows our estimate of the typical timeline for building new gas CC and CT plants. 

Starting with the permitting process, it would take approximately 50 months and 41 months to 

complete a new gas CC and a new gas CT respectively, according to our interviewees. 

Figure 5

Typical Timelines for New Gas CC and Gas CT Projects (Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First Energy, 

Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment manufacturing and 

construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, and Foster Wheeler).

For a Dry FGD retrofit project, we estimate that the total project duration starting with permitting 

would be 46 months, as shown in Figure 6 below. Similar detailed timelines for other retrofit 

projects are provided in the Appendix A.

Figure 6

Typical Timeline for a Dry FGD Project

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First Energy, 

Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment manufacturing and 

construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, and Foster Wheeler).

New Gas CC

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50

Permitting 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0

Construction 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0

New Gas CT

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50

Permitting 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 0 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0

Dry FGD

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0
19

IV. HISTORICAL MAXIMUM LEVELS OF CONSTRUCTION AND RETROFITS

To characterize the industry’s capability for a large simultaneous set of retrofit and new 

construction projects, we evaluate the maximum quantity of construction projects that have been 

implemented historically. If the demand on the supply chain that will be imposed by MATS is 

on a large scale far beyond historical maximums, then we expect that shortages and bottlenecks 

will arise in the supply chain that prevent some projects from going ahead on schedule. 

Even in the case of a shortage arising, we stress that this analysis is only indicative and cannot be 

considered a “hard cap” on the industry’s capability. All markets, including those representing 

the supply chain for retrofits and generation construction, have the ability to adapt and respond to 

market demands. For example, a shortage in skilled craft labor may be partially addressed by 

increasing labor availability through training new skilled workers, recruiting from other 

industries, moving individuals in from other regions, or requesting overtime work. However, 

such measures will likely increase project costs or cause delays relative to a typical timeline. For 

these reasons, we characterize the industry’s capability to construct a large number of projects 

simultaneously as a “soft cap” above which cost and delay concerns are likely to arise.

We report a summary of the total quantities of retrofits and generation plant construction that 

have been implemented in the U.S. and Midwest by type of project. We derive “soft caps” on 

the industry’s capability to construct similar projects in a single year based on the maximum of 

the annual historical retrofit and construction projects. Because some retrofit and construction 

projects are more resource-intensive than others, we report the caps for retrofits on a wet FGDequivalent basis, the cap for generation construction on a CC-equivalent basis, and a combined 

cap on a wet FGD-equivalent basis.19

A. ENVIRONMENTAL CONTROLS RETROFITS

Meeting the requirements of MATS is a major challenge for the industry, but comes after 

decades of environmental restrictions that required previous retrofits to existing units and tighter 

controls on new units. For our purposes, it is important to scale the impact of MATS relative to 

the quantity of retrofits achieved in response to earlier state and federal regulations. We show 

here the historical quantity of all types of retrofits installed for all fuel types in the U.S. and 

Midwest in response to various regulatory drivers. 

1. National Historical Control Retrofits 

Figure 7 shows the timeline of major controls retrofits added to the U.S. generation fleet since 

1990.

20

 The figure summarizes retrofits for all types of generation plants but excludes controls 

installations on new units. The MW of capacity impacted is represented based on the units’ 

installed capacity (ICAP) values; note that individual units may be represented more than one 

time in this figure if the unit was retrofitted with multiple types of controls. 

 

19 For calculating the FGD-equivalency factors, we used the relative estimated capital costs, according to the 

convention used by the EPA in its December 2011 study on the feasibility of retrofits needed to comply 

with the MATS rule. See EPA (2011b).

20 Compiled from Ventyx (2012).
20

The figure shows that relatively few retrofits were added in the early 1990s, with most control 

installations at the time being implemented on new units but not existing units. The vast 

majority of all the retrofits shown in the figure are on coal units, although a substantial minority

of the SCR upgrades in the early 2000s was on gas-fired units.21 Overall, the largest historical 

simultaneous retrofit efforts occurred in 2003 when a large number of SCRs were retrofitted on 

more than 40 GW of capacity and in 2009 when approximately 70 GW of capacity were 

retrofitted with a variety of different controls. The 2009 retrofits included approximately 29 GW 

of ACI retrofits and 19 GW of costly wet FGD systems. 

Figure 7

Historical Quantities of Controls Retrofits in the U.S.

Sources and Notes:

Data from Ventyx (2012). 

All generation fuel types are represented; individual units may be represented more than once if subject to multiple retrofits.

2. Control Retrofits in the Midwest

Figure 8 shows historical controls retrofits in the Midwest, defined according to MISO’s current 

footprint. The figure shows a similar pattern to the national retrofit trends with 2003 having 

more than 7 GW of SCR retrofits and 2009 having almost 15 GW of retrofits. In the Midwest,

however, a relatively greater proportion of the upgrades in 2009 were from ACI and relatively 

 

21 There are also a selection of gas units fitted with SNCR and oil units fitted with an ESP, SCR, or SNCR.
21

fewer from wet FGD systems. The year 2007 also stands out as having a relatively large number 

of upgrades including SCRs, baghouses, and wet and dry scrubbers.

Figure 8

Historical Quantities of Controls Retrofits in the Midwest

Sources and Notes:

Data from Ventyx (2012). 

All generation fuel types are represented; individual units may be represented more than once if subject to multiple retrofits.

B. GENERATION CONSTRUCTION

Many of the same engineering, contracting, and labor inputs needed for retrofitting plants are 

also needed for building new plants. To the extent that new generation construction must be 

completed at the same time as retrofit upgrades, there will be additional demands placed on a 

largely overlapping supply chain. For this reason, we examine historical trends not only in 

retrofits but also in new generation construction in the Midwest and nationally. 

1. National Historical Generation Construction

Figure 9 shows the total quantity of newly constructed plants in the U.S. over time, represented 

at plant nameplate capacity. We report these installations based on online date, although we 

recognize that large construction projects are multi-year efforts that will introduce substantial 

demands on the supply chain over several years. The most prominent feature of the new
22

construction chart is the large build-out of gas in the early 2000s and peaking in 2002.22 More 

than 38 GW of gas CCs and almost 22 GW of gas CTs came online in 2002. This large build-out 

of the gas fleet reflected the optimism of merchant developers as much of the U.S. wholesale 

electric industry deregulated and expanded opportunities for competition. 

Another important trend starting in the mid-2000s is an increase in wind construction in response

to demand introduced by states’ renewable portfolio standards (RPS). Wind plant construction 

was the highest in 2008 and 2009 with more than 9 GW of wind plants coming online nationally 

in those years. We expect construction of wind turbines to continue at high levels, with almost 9 

GW likely to come online in 2012 alone.23 

Figure 9

Historical Generation Construction in the U.S.

Sources and Notes:

Data from Ventyx (2012). 

 

22 Gas and oil CCs and CTs are plotted together because these technologies have very similar capital costs 

but almost all of these units rely on gas as their primary fuel source.

23 Based on the number of U.S. turbines that have already come online in 2012 plus the additional units that 

are already under construction and projected for completion this year.
23

2. Generation Construction in the Midwest

As shown in Figure 10, construction trends in the Midwest are similar to those nationally. The 

year 2002 showed a large quantity of gas-fired construction, with 2.5 GW of CCs and 2.9 GW of 

CTs coming online. Relative to the historical maximums, wind plant construction has been 

substantially more important in the Midwest than nation-wide. This is primarily because the 

Midwest has more sites that are attractive locations for wind development than other parts of the

country. Wind plant construction was the highest in the Midwest in 2008 at 3.2 GW, a year that 

had 5.2 GW total construction after accounting for gas and coal units that came online at the 

same time.

Figure 10

Historical Generation Construction in the Midwest

Sources and Notes:

Data from Ventyx (2012). 

C. “SOFT CAP” ON INDUSTRY CAPABILITY BASED ON HISTORICAL MAXIMUMS

As we explained previously, there is no hard limit on the industry’s capability to achieve a large 

number of simultaneous retrofit and new build projects. However, as the draw on skilled 

laborers, contractors, and equipment manufacturers becomes large, it is likely that the industry 

will reach some supply chain bottlenecks that can cause substantial delays or cost increases. To 

indicate the total capability of the industry to achieve a large quantity of simultaneous projects, 

we estimate a “soft cap” on the ability to achieve a large number of projects simultaneously

based on historical maximums. Simultaneous projects substantially in excess of these historical 
24

maximums will likely give rise to the types of supply chain bottlenecks that may concern 

suppliers attempting to meet the MATS compliance timeframe. 

Since some retrofit and new build projects are substantially more expansive in their scope, cost, 

and inputs than others, it is important to express all of these projects in a single metric so that we

can evaluate the overall implications. For this reason, we use the convention that the EPA has 

used in previous studies and evaluate all types of retrofits on a “wet FGD equivalent” basis. 

Generally, one MW of retrofits on this basis will impose the same capital costs (and 

approximately similar supply chain impacts) as one MW of a costly wet FGD upgrade. We also 

present a soft cap on new construction upgrades on a CC equivalent basis and a combined retrofit 

and new build cap on a wet FGD equivalent basis.

1. Retrofits on a Wet FGD Equivalent Basis

We convert all types of major retrofit projects into their wet FGD equivalent MW according to 

the conversion rates in Table 5. Following the convention used by the EPA in a recent study, we 

make this conversion based on the capital costs of each type of control upgrade as listed.24 Using 

these conversions, one MW of upgrades from any type of control technology would have the 

same capital cost and approximate supply chain implications. 

Table 5

Wet FGD Equivalence of Retrofit Technologies

Sources and Notes:

Capital costs of retrofit on coal plants from EPA (2010) and 

EEI (2011), pp. 33-34

Oil/gas costs from year 2004 estimate inflated by ratio of 

coal SCR and SNCR cost inflation between 2004 and 

2011 from the same sources.

1 MW of FGD Equivalent represents the same capital costs.

 

24 See EPA (2011b).

Retrofit 

Equipment

Capital

Cost 

Wet FGD 

Equivalent

(2011$/kW) (MW)

Coal

SCR $227 0.32

SNCR $51 0.07

Dry FGD $601 0.86

Wet FGD $702 1.00

DSI $41 0.06

Baghouse $366 0.52

ESP $70 0.10

ACI $27 0.04

Oil/Gas

SCR $66 0.09

SNCR $13 0.02
25

The total control retrofits reported in Section IV.A above can be converted into their wet FGD 

equivalent values as shown in Figure 11 for the U.S. and in Figure 12 for the Midwest. The 

figures show a smaller quantity of retrofit MW than the previous charts because most retrofits 

are less expensive than wet FGD upgrades. Additionally, some inexpensive upgrades such as 

ACI have a substantially lower impact when viewing on this basis, while the most expensive 

upgrades such as wet FGDs, dry FGDs, and SCRs are relatively more important. Nationally, the 

largest quantity of simultaneous retrofits occurred in 2009 with 28 GW of wet FGD equivalent 

retrofits. In the Midwest, the maximum simultaneous retrofits were in 2007 with 5.2 GW of wet 

FGD equivalent retrofits.

Figure 11

Historical Controls Retrofits in the U.S. on a Wet FGD Equivalent Basis

Sources and Notes:

Data from Ventyx (2012). 

Retrofitted MW converted into Wet FGD equivalent basis from Table 5.

All generation fuel types are represented; individual units may be represented more than once if subject to multiple retrofits.
26

Figure 12

Historical Controls Retrofits in the Midwest on a Wet FGD Equivalent Basis

Sources and Notes:

Data from Ventyx (2012). 

Retrofitted MW converted into Wet FGD equivalent basis from Table 5.

All generation fuel types are represented; individual units may be represented more than once if subject to multiple retrofits.
27

2. New Generation Construction on a CC Equivalent Basis

For new generation construction projects, we convert these projects into their CC equivalent MW 

according to the conversion factors presented in Table 6. Again, we develop these conversions 

based on the ratio of capital costs and therefore approximate supply chain impacts. We also 

present a conversion of these projects into their wet FGD equivalent MW for later use when 

evaluating the combined implications of retrofits and new construction.

Table 6

Wet FGD Equivalence of New Generation Technologies

Sources and Notes:

Capital costs from EIA (2011), p. 97.

“Other” category is small, and assumed at the coal equivalence factor.

1 MW equivalent represents the same capital costs.

Type of

Project

Capital

Cost 

CC 

Equivalent

Wet FGD 

Equivalent

(2011$/kW) (MW) (MW)

Wet FGD $702 n/a 1.00

New Construction

Coal $2,752 2.86 3.92

Gas/Oil CC $961 1.00 1.37

Gas/Oil CT $656 0.68 0.93

Nuclear $4,788 4.98 6.82

Hydro $2,117 2.20 3.02

Wind $2,360 2.45 3.36

Other n/a 2.86 3.92
28

Figure 13 and Figure 14 present historical new generation construction in the U.S. and Midwest,

respectively. While the figures show similar overall trends as presented previously, including 

substantial gas construction in the early 2000s, we note that the relatively high capital costs of 

wind and coal make these technologies more important here. This is particularly true for the 

Midwest chart, which shows the dominant importance of the large amount of wind capacity 

additions in recent years. Overall, the soft cap on new generation construction is 58.4 CCequivalent GW nationally based on year 2002 and 10.7 GW CC-equivalent GW in the Midwest 

based on 2008.

Figure 13

Historical Generation Construction in the U.S. on CC Equivalent Basis

Sources and Notes:

Data from Ventyx (2012).

CC equivalence factors from Table 6.
29

Figure 14

Historical Generation Construction in the Midwest on CC Equivalent Basis

Sources and Notes:

Data from Ventyx (2012).

CC equivalence factors from Table 6.

3. Retrofits and New Generation on a Wet FGD Equivalent Basis

By combining the total retrofit and new construction activities presented above, we can evaluate 

the total demand as presented in Figure 15 and Figure 16 below for the U.S. and Midwest. These 

figures are presented on a wet FGD equivalent MW basis. Because the capital costs of new 

construction are generally substantially higher than the costs of a retrofit, this conversion results 

in total quantities that are relatively high compared to the nominal capacity built. The higher 

capital costs of new construction also translate into a greater impact on the combined total. 

Overall, the historical maximum combined new build plus retrofit quantities were 89.0 GW wet 

FGD equivalent nationally in 2009, and 16.3 GW of wet FGD equivalent in the Midwest in 

2008. 
30

Figure 15

Historical Retrofits and New Builds in the U.S. on a Wet FGD Equivalent Basis

Sources and Notes:

Data from Ventyx (2012). 

Retrofit and new construction MW retrofitted converted into Wet FGD equivalent basis from Table 5 and Table 6.
31

Figure 16

Historical Retrofits and New Builds in the Midwest on a Wet FGD Equivalent Basis

Sources and Notes:

Data from Ventyx (2012). 

Retrofit and new construction MW retrofitted converted into Wet FGD equivalent basis from Table 5 and Table 6.

V. PROJECTION OF MATS COMPLIANCE IMPACTS 

In this Section, we evaluate the overall timing, labor, supply chain, and outage implications of 

MATS for the Midwest and nationally. We first examine the timeline needed to install retrofits 

relative to the MATS compliance deadline. We then examine projected retrofit and new 

installation impacts on the supply chain relative to historical maximums. Finally, we estimate 

the potential fleet-wide seasonal outage impacts from these retrofits.

A. TIMELINE FOR MATS COMPLIANCE RELATIVE TO CONSTRUCTION TIMELINES

Depending on the type of control retrofit that a particular coal unit will require to meet MATS, it 

may or may not experience difficulty in completing the project in time. Figure 17 shows the 

range of estimates for retrofit timelines against the MATS compliance window, assuming that 

the unit started its retrofit project in February 2012 when the final MATS rule was published in 

the Federal Register. However, many coal plant owners began their scoping and retrofit 

planning activities far earlier, including in the summer of 2011 when the proposed rule was 

announced or in December 2011 when the final version of the rule was published by the EPA. 
32

Other entities may not yet have decided what upgrades would be needed and most economic for 

their assets.

The figure shows that short lead-time projects such as ACI and DSI should be achievable within 

the 3-year MATS compliance deadline, even if those projects are not started immediately. 

However, all other types of retrofit projects are likely to have difficulty being completed within 

the MATS compliance deadline if industry representatives’ longer estimates of project lead times 

are more accurate than the shorter lead-time estimates of the EPA. For baghouse, SCR, and dry 

FGD upgrades, these upgrades should be achievable with a 1-year extension as long as they have 

already been started. Wet FGD upgrades are potentially more problematic. If the lower EPA 

estimates are correct then even these projects should be achievable with the 1-year extension, but 

the high-end estimates indicate a risk that even this extension may not be sufficient.

Figure 17

Retrofit Project Timeline Relative to MATS Compliance Deadlines

Sources and Notes:

Range of retrofit timelines from Figure 3 and Table 4.

Retrofit projects assumed to start the day that MATS was published in the Federal Register, or two months after the rule was 

finalized by EPA. The compliance deadline is 60 days plus 3 years from the date of publication in the Federal Register, 

which was February 16, 2012. See Federal Register (2012), p. 9407.

B. NEEDS RELATIVE TO “SOFT CAP” ON INDUSTRY CAPABILITY 

1. Projected National MATS Requirements on a Wet FGD Equivalent Basis

To evaluate total nation-wide MATS requirements, we rely on EPA and EEI studies projecting 

required retirement, retrofit, and new construction, with the EPA estimate forming a relatively 
33

low impact estimate and the EEI forming a high impact estimate relative to other studies. The 

EPA projected 64 GW wet FGD-equivalent retrofits on existing coal units nationally to comply 

with MATS.25 The EPA’s mix of retrofit projects includes 85 GW of baghouses, 44 GW of DSI, 

99 GW of ACI, 20 GW of dry FGD with baghouse, 63 GW of FGD upgrades and 34 GW of ESP 

upgrades. We also note that the EPA includes no wet FGD upgrades in its projection.

According to a January 2011 study by the EEI, a substantially larger number of coal units will 

need to install FGDs and baghouses.26 The EEI study projected FGD retrofits on approximately 

100 GW (42-43 GW of wet FGDs and 57 GW of dry FGDs) of coal capacity, 194-201 GW of 

ACI with baghouses, 18 GW of SCRs, and 46-48 GW of ACI retrofits under two of the relevant 

regulation scenarios.

27

 This amounts to a projected 207-212 GW of wet FGD equivalent 

retrofits, or more than three times the quantity projected by the EPA.

With respect to new generation, the EPA projects that 30 GW of new generation will be needed

by 2015 under MATS.28 This includes 21 GW of wind capacity additions, 1 GW of gas CCs, 2 

GW of gas CTs, 2 GW of coal plants, and 3 GW of other renewables. The EPA’s forecast of 

new generation capacity by 2015 is equivalent to a total of 93 GW of wet FGD retrofits.

In contrast, the EEI study projects a much larger 73-84 GW of new generation capacity by 2015 

under the two regulation scenarios we consider here.

29

 The composition of this new capacity 

projection is 13 GW coal, 16-25 GW gas CCs, 31-32 GW wind, and 13-14 GW other. This is 

equivalent to a total of 228-248 GW of Wet FGD retrofits, or approximately 2.5 times the 

quantity projected by the EPA. Some of the difference between the EEI and EPA new build 

estimates is driven by the EEI’s higher coal retirement estimate that would require a greater 

number of replacement projects, while some of the difference is simply related to a higher 

projection of renewables penetration. Recent announcements of coal plant retirements (about 30 

GW) and our assessments suggest that the need for new generation will be closer to the EEI 

estimates.

Table 7 compares the EPA and EEI projected retrofits and new generation capacity on an FGDequivalent basis. According to the EPA, 64 GW of retrofits and 93 GW of new generation 

capacity will be needed under the MATS rule by 2015, for a combined total of 157 GW on a Wet 

FGD-equivalent basis. The EEI projects a substantially greater impact of 207-212 GW of 

retrofits and 228-248 GW of new generation capacity on an FGD-equivalent basis or almost 

three times the EPA’s estimates.

 

25 EPA (2011b), p. 6.

26 EEI (2011), p. 52.

27 Referred to as “Scenario 1” and “1-Alt Air” in the original study. EEI study defined Scenario 1 as all coal 

units to be controlled with a scrubber (dry or wet), ACI and Baghouse. Under “Scenario 1 - Alt Air”, the 

scrubber requirement in Scenario 1 is relaxed for units smaller than 200 MW with a requirement (if 

economic) for a DSI retrofit, in addition to ACI and Baghouse. The study also projected other retrofits in 

small amounts, but we did not include those in our calculations.

28 EPA (2011c).

29 EEI (2011), p. 55.
34

Table 7

EPA and EEI Projected Retrofit and New Generation in the U.S. by 2015

(in Wet FGD Equivalent GW)

Sources and Notes:

Retrofit estimates from EPA (2011b), p. 6, and EEI (2011), p. 52.

New generation estimates from EPA (2011c) and EEI (2011), p. 55.

Conversions to Wet FGD equivalent from Section 0 above.

2. Projected Midwest MATS Requirements on a Wet FGD Equivalent Basis

To determine the total projected MATS-required retrofits and new builds in the Midwest, we 

converted MISO’s estimates of the total requirements from Section I.B above. Depending on the 

scenario, MISO projects a total of 74-91 GW of wet FGD equivalent upgrades and new 

generation will be required by 2015. Fewer upgrades are required in the higher retirement 

scenarios, but these scenarios still have greater overall impact because they require more 

replacement capacity to be built.

Table 8

MISO Projected Retrofit and New Generation in the Midwest by 2015

(in Wet FGD Equivalent GW)

Sources and Notes:

Estimated by MISO as reported in Section I.B and Appendix B.

Conversions to Wet FGD equivalent from Section 0 above.

Scenario Retrofits New 

Generation Total

(GW) (GW) (GW)

EPA 93 84 177

EEI Low 228 207 435

EEI High 248 212 459

MISO Scenario Retrofits New 

Generation Total

(GW) (GW) (GW)

1: 0 GW Retire 58 16 74

2: 3 GW Retire 56 16 73

3: 12 GW Retire 51 25 76

4: 19 GW Retire 53 38 91
35

3. Comparison of Projected MATS Requirements to “Soft Cap”

The following figures compare the projected new builds and retrofits against the historical “soft 

cap” nationally and in the Midwest.

30

 Nationwide, maximum annual projected retrofits and new 

generation according to EPA projections (about 60 GW per year of wet FGD equivalent 

capacity) is substantially below the historical annual maximum of 89 GW annual wet FGD 

equivalent capacity, while maximum annual projected retrofits and new builds based on EEI 

estimates (160-170 GW per year of wet FGD equivalent capacity) are roughly double the 

historical soft cap. If the EPA’s relatively optimistic estimate of MATS impacts is more 

accurate, it appears that the industry will be well-equipped to meet demand; conversely, if EEI’s 

projections are more accurate then it appears that MATS represents an unprecedented challenge 

that will require industry to more than double its historical maximum deployment. In the EEI 

case, even with a 1-year extension for MATS compliance the simultaneous demand would be 

more than 20% above the historical maximum. We believe that the actual MATS impact is 

likely in between the two extremes represented by the EPA and EEI studies, although our 

internal estimates are somewhat closer to those presented by EEI. 

 

30 Note that the timing of retrofits and some new generation builds have not been reported in the source 

studies. So we estimated this timing based on: (i.) plant owner announcements of retrofit online dates 

where available; (ii.) plant owners’ announcements of construction completion dates for all plants 

currently under construction; (iii.) study-projected online dates for new generation (available only for 

MISO’s study); and (iv.) assuming all other retrofit and new build projects come online split equally 

between 2014 and 2015. The reason for the dip in 2013 in the two figures is that most projects that are 

currently under construction or announced have online dates of 2012 with relatively fewer coming online 

in 2013.
36

Figure 18

Projected New Build and Retrofits in the U.S. Relative to Historical “Soft Cap”

Sources and Notes:

Retrofit estimates from EPA (2011b), p. 6, and EEI (2011), p. 52.

New generation estimates from EPA (2011c) and EEI (2011), p. 55.

Conversions to Wet FGD equivalent from Section 0 above; historical maximum estimate from 0.
37

In the Midwest, maximum annual projected retrofits and new generation in all four scenarios (in 

the range of 25-43 GW wet FGD equivalent) substantially exceed the historical soft cap of 16.3 

GW. However, in this case, the flexibility of the 1-year extension to MATS would be likely to 

substantially solve the problem and bring Midwestern demands just within the bounds of 

historical maximums in three of the four scenarios as long as retrofits are deployed evenly over 

the three years 2014-16. Because retrofits and new builds are likely to be lumpy and possibly 

back-loaded, it still appears likely that historical maximums may need to be exceeded in at least 

one year even with the 1-year extension. The potential for a high-retrofit case such as MISO’s 

Scenario 4 indicates an even greater concern in that even the 1-year extension would result in 

demand approximately 30% greater than historical maximums.

Figure 19

Projected New Build and Retrofits in MISO Relative to Historical “Soft Cap”

Sources and Notes:

Estimated by MISO as reported in Section I.B and Appendix B.

Conversions to Wet FGD equivalent from Section 0 above; historical maximum estimate from 0.

C. DEMAND FROM MATS RELATIVE TO LABOR SUPPLY 

To evaluate the total labor supply chain demand associated with MATS, we projected monthly 

schedules of labor demands associated with retrofits and new gas CCs and CT generation 

through 2015. We derived these schedules by combining project timelines and labor 

requirements from Section III above with the total amount of capacity to be retrofitted and built 

in the MISO region and in the U.S from Section V.B. We then compared these projected 

monthly labor requirements against the total available labor based on Bureau of Labor Statistics
38

data for 2011, the most recent year available.

31

 By comparing total labor needs against total 

supply, we concluded that among those labor categories we examined, boilermakers are most 

likely to create a bottleneck in deploying needed retrofits and new builds. Therefore, we present 

in this section our projection of demand for boilermakers against measures of total supply.

To project demand for boilermakers in the U.S., we used the EPA estimates and EEI high case 

estimates for coal retrofits and new generation. As described in Section V.B, the EPA study 

projected 64 GW of wet FGD-equivalent retrofits, 1 GW of gas CCs, and 2 GW of gas CTs 

would be needed. In contrast, the EEI study projected that 212 GW of wet FGD-equivalent 

retrofits and 25 GW of gas CCs would be needed by 2015 in its high case. As shown in Figure 

20, we estimate the maximum monthly demand at 2,617 boilermakers using EPA projections and 

7,590 boilermakers using the EEI projections. Compared to a total of 18,850 boilermakers 

employed in the U.S. in 2011, these projected needs represent 14% of total supply using EPA’s 

projections or 40% of total supply using EEI projections. 

Figure 20

Projected Need for Boilermakers in the U.S.

Sources and Notes:

Boilermaker demand consistent with MATS scenarios from V.B and labor requirements from Section III.A and Appendix C.

Current boilermaker employment data from BLS (2011).

 

31 BLS (2011).
39

Figure 20 also shows the total number of boilermakers currently employed in the in the Utility 

System Construction Industry, which includes utility construction activities in the water, sewer, 

petroleum, gas, power and communication utility industries.32 In 2011, BLS data indicated that 

there were 1,850 boilermakers employed in the Utility System Construction Industry, 

representing 9.8% of all U.S boilermakers. Therefore, the projected demand for boilermakers for 

retrofits and new generation projects exceeds the number of boilermakers currently employed in 

this industry. This comes at a time when demand for boilermakers in this sector have already 

increased substantially over the past several years as shown in Figure 21, possibly related to the 

large number of coal retrofits that have been implemented over the past few years. Despite this 

relatively high demand for boilermakers in utility construction, total employment of 

boilermakers actually dropped in 2010 (as did employment in many fields, related to the 

economic downturn). 

Overall, it appears that the small incremental demand for boilermakers that would be needed in 

the EPA scenarios would not appear to be a pressing concern. However, the more than threefold increase in boilermaker demand consistent with the EEI high case would likely be a 

substantial challenge and could result in substantial concerns from boilermaker availability or 

cost increases as boilermakers would have to be hired in against competition from other 

industries or developed as new skilled laborers. 

Figure 21

U.S. Boilermakers Employed in Utility System Construction and All Industries 

Sources and Notes:

Compiled from BLS data from 2002-2010, see BLS (2011).

Industry-specific boilermaker employment unavailable for 2005 and 2008.

 

32 Industry definition is based on North American Industry Classification System (NAICS). Definition for 

the Utility System Construction industry can be found in U.S. Census Bureau (2012). 
40

In the Midwest, we used the projected retrofits and new generation capacity in MISO’s Scenarios

2 and 3. As described in Appendix B, MISO projects in Scenario 2 that 61 GW of the coal fleet 

will need to install retrofits, but that no new gas CCs or CTs will be needed beyond those already 

under construction. In Scenario 3, due to higher coal retirements, MISO expects fewer retrofits 

(52 GW of the coal fleet) but expects more new generation (7 GW of new gas CCs and 2 GW of 

new gas CTs). As shown in Figure 22, we project the maximum monthly demand for 

boilermakers in the Midwest at 1,403 in Scenario 2 and 1,354 in Scenario 3, compared to a total 

of 5,170 boilermakers employed in Midwestern states as of 2011. Therefore, our projected 

maximum monthly demand for boilermakers in the MISO region represents about 30% of total 

supply in the region. 

Requiring 30% of all boilermakers in the utility system construction industry may be a challenge, 

if the Midwest is similar to the nation with only 9.8% of all boilermakers in this industry as of 

2011.

33

 Again, such a scale-up could be a major challenge and create a bottleneck in completing 

MATS deployments without substantial cost over-runs or project delays. As with the national 

estimates, we should note that the total supply of boilermakers in the MISO region is not a hard 

cap, since additional labor may be available from other regions, industries, or training. 

Figure 22

Projected Need for Boilermakers in the MISO Region

Sources and Notes:

Boilermaker demand consistent with MATS scenarios from V.B and labor requirements from Section III.A and Appendix C.

Current boilermaker employment data from BLS (2010).

 

33 Industry-specific data for employment are available nationally but are not available regionally, which is 

why those numbers are not reported here. 
41

D. MISO RETROFIT OUTAGE ANALYSIS

Figure 23 shows a projection of the total coal plant planned outages that are likely to be needed 

in MISO in each of the retrofit upgrade scenarios that we examine. The dark blue portion of the 

chart shows “typical” outages that would be needed for the coal fleet, assuming that all plants 

will need 23 days of planned outages per year.34 We also evaluate the incremental outage 

duration that would be needed for each type of retrofit as reported in Table 3 above. For 

simplicity, we assume that outages can be scheduled optimally such that all outages are 

uniformly realized over each 90-day spring and fall outage season. This is an optimistic 

assumption that will generally understate the potential system impacts and difficulty in absorbing 

these planned outages. On the other hand, MISO will have some ability to mitigate the impacts 

of these outages by scheduling a portion of planned outages in other months; MISO has already 

begun to analyze its ability to schedule outages during other months.35 

The figure shows that MISO will have to prepare for approximately 4 GW of additional average 

outages during the four MATS compliance seasons prior to the MATS deadline and 1-year 

extension deadline. This is approximately 40% more simultaneous coal outages than MISO 

would likely have to schedule if there were no coal retrofits. These 4 GW of incremental outages 

are a substantially greater concern in the high-retirement scenarios than in the low-retirement 

scenarios because the high-retirement scenarios will also have a lower reserve margin and less 

ability to schedule a large number of simultaneous outages. However, we note that some of 

these concerns could be mitigated by scheduling some of the outages outside the regular seasons 

for planned outages. 

MISO has already begun to analyze its total system capability to absorb incremental outages 

during the traditional outage season, finding that it has substantial capability to schedule outages 

during the winter months December through February, in addition to the traditional spring and 

fall outage seasons. MISO’s initial analysis indicates that its system has the capability of 

absorbing more than 27 GW of simultaneous outages at the 2012 installed reserve margin level, 

whether these outages are scheduled over 6 or 9 months.36 Even after accounting for modest 

retirements in Scenarios 1 and 2, it appears that MISO would have no difficulty absorbing the 4 

GW of incremental outages that may be needed for MATS.37 

However, in Scenario 3 with 12 GW of retirements, MISO’s ability to absorb large simultaneous 

outages is likely to be substantially diminished, possibly to less than 16 GW by 2015. In this 

case, there would be only approximately 4 GW of slack in the 6-month outage season with which 

to absorb non-coal planned outages and account for imperfect outage scheduling. Moving to a 9-

 

34 Based on the average number of planned outage days for all coal plants in the U.S. from NERC 2010 

GADS data, from Ventyx (2012). Note that this is less than the average individual outage duration as 

identified from analyzing CEMS data in Section III.B because, as explained previously, by using CEMS 

data we were not able to distinguish planned outages from maintenance, forced, and economic outages. 

35 See MISO (2012), p. 6.

36 Average of 6 or 9 month outage season from MISO (2012), p. 6.

37 Based on a rough calculation of outage capability using the average over 6 or 9 months from 2012 and 

adjusting downward for projected retirements. Outages needed for coal are as displayed in Figure 23 for 6 

months or the same quantity of outage days divided over 9 months.
42

month outage window is likely to create enough flexibility to absorb this concern.38 Scenario 4 

with 19 GW of retirements would be highly problematic, however, with only approximately 10 

GW available over the 9-month outage window and a total of 7.5 GW needed for coal units 

alone. This would leave little room for imperfect scheduling or non-coal outages. 

Figure 23

Projected Average Seasonal Coal Planned Outages Needed in MISO

Sources and Notes:

“Typical” outages are the average needed coal plant outages given the installed coal fleet for that season based on average 

NERC GADS planned outage rates.

“Incremental retrofit” outages are the additional average outages that will be needed in each season for longer outages 

associated with retrofit upgrades.

VI. SUMMARY OF FINDINGS

In evaluating the feasibility of the entire coal feet to meet MATS by the compliance deadline, we 

found that it is very likely that the industry will run into delays and bottlenecks, while MISO 

may face an operational challenge in managing outage scheduling. With respect to the timeline 

needed for retrofits, we find that some types of upgrades can be implemented before 2015 

without difficulty, including ACI and DSI, which can be implemented within approximately a 

year and a half. However, most projects have a longer lead time of approximately 3-4 years 

including wet and dry FGD, baghouse, ESP, and SCR retrofits, as well as new gas CTs and CCs. 

Some of these long-lead projects will be able to come online prior to the MATS deadline, 

particularly as many of them are already under development. Many plant owners have already 

 

38 A rough calculation shows that the outages needed for coal would be approximately 8 GW over 9 months, 

compared to approximately 16 GW available for all outages.
43

announced upgrade plans, although many others are likely still in the scoping phase. For the 

retrofit projects that need state commission approval of cost recovery to move forward, their 

ability to meet the MATS deadline will in part depend on the states’ speed of approval when 

evaluating a large number of projects at once. These long lead times introduce a substantial 

concern for any long-lead projects that are initiated late, both due to the timing constraint and 

due to the potential for difficulty in obtaining the necessary engineering and construction support 

during a period of very high demand.

To evaluate the scale of the supply chain demands from MATS, we compared projected retrofit 

and new build demands against the historical maximum for the industry in the U.S. and 

nationally. We separately looked at retrofits and new builds on a Wet FGD-equivalent basis, 

converting the MW of upgraded or built capacity into one equivalent unit based on capital costs. 

This approach reflects our assumption that capital costs are a reasonable indicator of the 

demands that a particular retrofit will impose on labor and equipment supply chains. We find 

that MATS will require retrofit and new build activities that exceed the historical industry 

maximum in the Midwest by 51%-162% based on MISO’s projected retrofit requirements and 

individual plant owner announcements. For the nationwide retrofits, the needs imposed by 

MATS could be substantially below historical maximums if the EPA’s projections are correct, or

up to 93% above historical maximums if industry estimates are more accurate. We believe that 

the EPA estimates may be optimistic while industry estimates may be pessimistic, especially in 

the highest retrofit cases. 

It appears that MATS will require a ramp up in labor, engineering, equipment, and construction 

that is likely to introduce substantial bottlenecks locally or nationally. These bottlenecks are 

likely to introduce delays or cost escalation, for example, if certain craft labor categories or 

qualified EPC firms are in short supply. The competitive marketplace will find opportunities to 

mitigate such concerns (e.g., by increasing labor supply with training, relocation, and overtime) 

but such measures are costly and time-consuming. 

We evaluated the potential for craft labor to become a bottleneck that could introduce project 

delays. Based on our estimates of typical craft labor requirements for retrofits and new 

construction, we projected a time profile of craft labor required for MATS compliance. 

Comparing projected labor needs against the current labor supply for each craft revealed that 

boilermakers are the most likely bottleneck. As many as 7,590 boilermakers (or 40% of 

boilermakers currently employed nationally) could be needed to complete the projected retrofits 

and new generation construction by 2015. This potential demand is more than four times the 

number of boilermakers (1,850) currently employed in the Utility System Construction 

Industry.39 Therefore, meeting the projected demand for boilermakers will likely require a 

combination of adjustments on the supply side, including training new labor, relocation, 

extending work hours, and attracting craft labor from other industries.

Finally, we examined the potential impacts of MATS on MISO’s outage scheduling process by 

examining the length of planned outages that coal units need in typical years compared with the 

duration of outages associated with plant retrofits. Based on our interviews with project 

 

39 According to the Bureau of Labor Statistics definitions, the Utility System Construction Industry includes 

utility construction activities in power, communication, oil, gas, water and sewer sectors, see U.S. Census 

Bureau (2012).
44

developers and electric utilities, we understand that most of the construction and installation 

associated with retrofits can be completed while the plant is operating, although final tie-in to 

major plant systems can only be done during a plant outage. These tie-ins will usually be 

scheduled concurrently with other standard maintenance during a planned outage but will require 

a longer than typical outage for completion. Based on an analysis of historical plant operations 

for coal plants, we estimate that some upgrades such as Dry FGD, DSI, SNCR, and ACI require 

that the outage duration need only be extended a few days or a week, although some types of 

upgrades impose much longer outages. Wet FGD, baghouse, and SCR retrofits are likely to 

require outages be extended by approximately three weeks. 

Considering the fleet-wide impacts of these outages, it appears that MISO may have to schedule 

approximately 45% more MW of coal outages per season for MATS compliance by Fall 2015 

(which assumes many plants will gain a 1-year compliance extension). The impact of these 

additional outages is further exacerbated by the fact that a substantial fraction of coal plants are 

likely to retire rather than comply with MATS, hence reducing the system’s ability to absorb 

additional outages. Based on MISO’s initial analysis of the fleet’s ability to absorb outages, it 

appears that the total quantity of outages for MATS could be easily absorbed and scheduled in its 

low retirement scenarios. However, in MISO’s 12 GW retirement scenario, it appears that MISO 

may only be able to absorb these outages by extending its typical 6-month (fall and spring) 

outage season to a 9-month (fall, winter, and spring) season. In MISO’s even higher 19 GW 

retirement scenario, it appears likely that the RTO would not be able to schedule all of the 

needed outages even in a 9-month window without facing reliability concerns or gaining an 

additional 1-year reliability extension to 2017. 

Overall, meeting MATS will be a major challenge for the industry, states, and MISO for a 

number of reasons. The industry will need to install retrofits at a pace and scale that exceeds the 

historical demonstrated capability, while the system operator is likely to experience a substantial 

operational challenge in the transition. 

 
45

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LIST OF ACRONYMS

ACI Activated Carbon Injection

BLS Bureau of Labor Statistics

CAIR Clean Air Interstate Rule

CC Combined Cycle

CT Combustion Turbine

CSAPR Cross-State Air Pollution Rule

DOE Department of Energy

DSI Dry Sorbent Injection

EEI Edison Electric Institute

EIA Energy Information Administration

EPA Environmental Protection Agency

EPRI Electric Power Research Institute

ESP Electrostatic Precipitator

FGD Flue Gas Desulfurization

GADS Generating Availability Data System

ICAC Institute of Clean Air Companies

ICAP Installed Capacity

ICF ICF International

IEc Industrial Economics, Incorporated

MATS Mercury and Air Toxics Standards

MISO Midwest Independent Transmission System Operator

NERC North American Electric Reliability Corporation

RPS Renewable Portfolio Standard

SCR Selective Catalytic Reduction

SNCR Selective Non-catalytic Reduction

UARG Utility Air Regulatory Group

URS URS Corporation
49

APPENDICES
50

APPENDIX A. TIMELINES FOR TYPICAL ENVIRONMENTAL RETROFIT PROJECTS 

This appendix contains Figure 24 and Figure 25 showing our estimated timelines for various 

environmental retrofit projects.

Figure 24

Typical Timelines for Dry FGD, Wet FGD, DSI and ACI Retrofit Projects

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First Energy, 

Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment manufacturing and

construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, and Foster Wheeler).

Dry FGD

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0

Wet FGD

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0

DSI

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

ACI

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
51

Figure 25

Typical Timelines for Baghouse, ESP, and SCR Retrofit Projects

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First Energy, 

Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment manufacturing and 

construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, and Foster Wheeler).

APPENDIX B. PROJECTED RETROFITS AND NEW GENERATION PLANTS IN MISO

To supplement our summary of MISO’s estimated new build, retirement, and coal retrofit 

projections from Section I.B, we provide a more detailed breakdown in the following table. 

Baghouse

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0

ESP

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0

SCR

Project Phase 0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60

Permitting 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Design Engineering 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

System Interface / Site Engineering 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Procurement 0 0 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Construction 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0

Testing 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0

Outage 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0
52

Table 9

Estimated New Builds and Coal Retrofits in the MISO Region by 2015

Sources and Notes:

Data from MISO (2011) and Ventyx (2012); new generation includes plants under and MISO-projections.

APPENDIX C. ESTIMATED LABOR REQUIREMENTS FOR RETROFIT PROJECTS

As explained in the earlier Section III.A, along with labor estimates for a dry FGD project, we 

developed estimates of the total person-months of labor that would be required to install various 

Scenario 1: EPA Scenario 2: 3k Retire Scenario 3: 12k Retire Scenario 4: 23k Retire

M W Count M W Count M W Count M W Count

New Builds

Gas - CC 300 1 300 1 2,400 1 4,800 1

Gas - CT 0 0 0 0 7,200 0 16,800 0

Coal 2,299 4 2,299 4 2,299 4 2,299 4

Wind 1,943 28 1,943 28 1,943 28 1,943 28

Other 68 4 68 4 68 4 68 4

Total 4,610 -- 4,610 -- 13,910 -- 25,910 --

Coal Retirements 520 1 0 3,214 5 1 12,305 151 18,625 196

Coal Retrofit Upgrade

No Need for Upgrade 7,650 5 9 7,492 4 9 6,967 2 7 3,329 9

One Control Only 25,676 6 9 25,448 6 7 24,237 5 9 17,200 3 4

SCR 0 0 0 0 0 0 3,532 6

Dry FGD 1,525 5 1,525 5 1,037 3 698 2

Wet FGD 670 2 670 2 670 2 670 2

DSI 167 2 167 2 79 1 0 0

Baghouse 23,315 60 23,087 58 22,452 53 12,300 24

Two Controls Only 23,911 7 1 23,559 6 7 20,520 4 7 14,518 3 3

SCR + Dry FGD 460 1 460 1 460 1 799 2

SCR + Baghouse 0 0 0 0 0 0 8,147 19

SNCR + ACI 374 1 374 1 374 1 0 0

Dry FGD + Baghouse 17,672 41 17,672 41 16,980 38 3,435 7

Wet FGD + Baghouse 2,489 4 2,489 4 2,489 4 1,694 3

DSI + Baghouse 1,490 11 1,314 9 101 1 0 0

DSI + ACI 1,426 13 1,250 11 116 2 69 1

Three Controls Only 13,266 103 11,310 7 8 6,994 2 8 16,789 3 9

SCR + Wet FGD + ESP 1,650 2 1,650 2 1,650 2 1,650 2

SCR + Dry FGD + B 783 2 783 2 783 2 11,316 23

SCR + Wet FGD + B 1,646 5 1,646 5 1,646 5 2,913 7

SNCR + Wet FGD + B 547 2 547 2 547 2 75 1

SCR + DSI + B 0 0 0 0 0 0 101 1

Dry FGD + B + ACI 563 1 563 1 563 1 0 0

DSI + B + ACI 7,677 90 5,721 65 1,405 15 218 2

SCR + Dry FGD + ACI 400 1 400 1 400 1 400 1

SCR + DSI + ACI 0 0 0 0 0 0 116 2

Four Controls 342 3 342 3 342 3 905 4

SCR + Dry FGD + B + ACI 0 0 0 0 0 0 563 1

SNCR + Dry FGD + B + ACI 99 1 99 1 99 1 99 1

SNCR + DSI + B + ACI 243 2 243 2 243 2 243 2

Any Control 63,196 246 60,659 215 52,094 137 49,412 110

Wet FGD Equivalent 58,725 -- 57,259 -- 52,017 -- 53,802 --
53

types of retrofit labor. We present here detailed tables of labor requirements for wet FGD, 

baghouse, ESP, SCR, DSI, and ACI retrofit projects. 

Table 10

Typical Labor Needs for Wet Scrubber Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 3 31 16 37 114 0 0 201

Construction / Site Engineers 0 8 136 25 715 13 5 902

Licensing Engineers 14 5 11 25 57 0 0 112

Procurement Engineers 0 14 0 61 143 0 0 218

Project Managers 5 5 0 25 57 1 1 95

Construction Managers 0 5 0 0 86 2 0 93

First Line Supervisors 0 0 0 0 229 0 0 229

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 1,001 0 0 1,001

Boilermakers 0 0 0 0 686 0 0 686

Electronic and Control Systems Specialists 0 0 0 0 372 0 0 372

Pipe Layers 0 0 0 0 629 0 0 629

Electrician - In-House Systems 0 0 0 0 229 0 0 229

Electrician - Power Line Installers 0 0 0 0 229 0 0 229

Iron/steel Workers 0 0 0 0 429 0 0 429

Brickmasons and Blockmasons 0 0 0 0 629 0 0 629

Concrete Finishers 0 0 0 0 200 0 0 200

Operator Pile Drivers 0 0 0 0 114 0 0 114

Carpenters 0 0 0 0 543 0 0 543

General Construction Labor 0 0 0 0 1,602 0 0 1,602

Insulation Workers 0 0 0 0 229 0 0 229

Reinforcing Iron and Rebar Workers 0 0 0 0 229 0 0 229

Welders, Solderer 0 0 0 0 372 0 0 372

Construction Equipment Operators 0 0 0 0 286 0 0 286

Power Plant Operators 0 0 0 0 0 7 0 7
54

Table 11

Typical Labor Needs for Baghouse Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 4 64 17 34 69 0 0 189

Construction / Site Engineers 0 13 143 23 18 54 5 255

Licensing Engineers 5 9 11 23 34 0 0 82

Procurement Engineers 0 21 0 57 0 0 0 79

Project Managers 2 9 0 23 34 4 1 73

Construction Managers 0 9 0 0 51 9 0 69

First Line Supervisors 0 0 0 0 206 0 0 206

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 600 0 0 600

Boilermakers 0 0 0 0 411 0 0 411

Electronic and Control Systems Specialists 0 0 0 0 137 0 0 137

Pipe Layers 0 0 0 0 257 0 0 257

Electrician - In-House Systems 0 0 0 0 206 0 0 206

Electrician - Power Line Installers 0 0 0 0 206 0 0 206

Iron/steel Workers 0 0 0 0 617 0 0 617

Brickmasons and Blockmasons 0 0 0 0 428 0 0 428

Concrete Finishers 0 0 0 0 206 0 0 206

Operator Pile Drivers 0 0 0 0 206 0 0 206

Carpenters 0 0 0 0 566 0 0 566

General Construction Labor 0 0 0 0 1,251 0 0 1,251

Insulation Workers 0 0 0 0 274 0 0 274

Reinforcing Iron and Rebar Workers 0 0 0 0 771 0 0 771

Welders, Solderer 0 0 0 0 617 0 0 617

Construction Equipment Operators 0 0 0 0 377 0 0 377

Power Plant Operators 0 0 0 0 0 17 0 17
55

Table 12

Typical Labor Needs for ESP Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 2 9 14 19 59 0 0 104

Construction / Site Engineers 0 2 118 13 369 44 4 551

Licensing Engineers 3 1 9 13 30 0 0 56

Procurement Engineers 0 3 0 32 0 0 0 35

Project Managers 1 1 0 13 30 4 1 49

Construction Managers 0 1 0 0 44 7 0 53

First Line Supervisors 0 0 0 0 177 0 0 177

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 517 0 0 517

Boilermakers 0 0 0 0 355 0 0 355

Electronic and Control Systems Specialists 0 0 0 0 207 0 0 207

Pipe Layers 0 0 0 0 207 0 0 207

Electrician - In-House Systems 0 0 0 0 355 0 0 355

Electrician - Power Line Installers 0 0 0 0 295 0 0 295

Iron/steel Workers 0 0 0 0 665 0 0 665

Brickmasons and Blockmasons 0 0 0 0 310 0 0 310

Concrete Finishers 0 0 0 0 207 0 0 207

Operator Pile Drivers 0 0 0 0 207 0 0 207

Carpenters 0 0 0 0 207 0 0 207

General Construction Labor 0 0 0 0 532 0 0 532

Insulation Workers 0 0 0 0 177 0 0 177

Reinforcing Iron and Rebar Workers 0 0 0 0 650 0 0 650

Welders, Solderer 0 0 0 0 650 0 0 650

Construction Equipment Operators 0 0 0 0 517 0 0 517

Power Plant Operators 0 0 0 0 0 14 0 14
56

Table 13

Typical Labor Needs for SCR Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 12 12 14 42 100 0 0 180

Construction / Site Engineers 0 2 117 28 622 58 6 833

Licensing Engineers 16 2 9 28 50 0 0 104

Procurement Engineers 0 4 0 70 0 0 0 74

Project Managers 6 2 0 28 50 5 1 91

Construction Managers 0 2 0 0 75 9 0 86

First Line Supervisors 0 0 0 0 299 0 0 299

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 1,120 0 0 1,120

Boilermakers 0 0 0 0 846 0 0 846

Electronic and Control Systems Specialists 0 0 0 0 373 0 0 373

Pipe Layers 0 0 0 0 473 0 0 473

Electrician - In-House Systems 0 0 0 0 448 0 0 448

Electrician - Power Line Installers 0 0 0 0 448 0 0 448

Iron/steel Workers 0 0 0 0 796 0 0 796

Brickmasons and Blockmasons 0 0 0 0 747 0 0 747

Concrete Finishers 0 0 0 0 373 0 0 373

Operator Pile Drivers 0 0 0 0 373 0 0 373

Carpenters 0 0 0 0 572 0 0 572

General Construction Labor 0 0 0 0 1,120 0 0 1,120

Insulation Workers 0 0 0 0 299 0 0 299

Reinforcing Iron and Rebar Workers 0 0 0 0 747 0 0 747

Welders, Solderer 0 0 0 0 846 0 0 846

Construction Equipment Operators 0 0 0 0 547 0 0 547

Power Plant Operators 0 0 0 0 0 19 0 19
57

Table 14

Typical Labor Needs for DSI Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 3 4 8 12 20 0 0 47

Construction / Site Engineers 0 2 10 12 50 75 7 156

Licensing Engineers 6 0 2 0 0 0 0 8

Procurement Engineers 0 0 0 72 0 0 0 72

Project Managers 0 0 0 12 10 6 1 29

Construction Managers 0 0 0 0 10 12 0 22

First Line Supervisors 0 0 0 0 20 0 0 20

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 0 0 0 0

Boilermakers 0 0 0 0 149 0 0 149

Electronic and Control Systems Specialists 0 0 0 0 119 0 0 119

Pipe Layers 0 0 0 0 119 0 0 119

Electrician - In-House Systems 0 0 0 0 159 0 0 159

Electrician - Power Line Installers 0 0 0 0 119 0 0 119

Iron/steel Workers 0 0 0 0 199 0 0 199

Brickmasons and Blockmasons 0 0 0 0 179 0 0 179

Concrete Finishers 0 0 0 0 139 0 0 139

Operator Pile Drivers 0 0 0 0 119 0 0 119

Carpenters 0 0 0 0 219 0 0 219

General Construction Labor 0 0 0 0 348 0 0 348

Insulation Workers 0 0 0 0 40 0 0 40

Reinforcing Iron and Rebar Workers 0 0 0 0 219 0 0 219

Welders, Solderer 0 0 0 0 219 0 0 219

Construction Equipment Operators 0 0 0 0 100 0 0 100

Power Plant Operators 0 0 0 0 0 12 6 18
58

Table 15

Typical Labor Needs for ACI Retrofit Projects (Person-Months)

Sources and Notes:

Based on interviews with electric utilities (AEP, Dairyland Power Cooperative, Detroit Edison, Dominion, Duke, First 

Energy, Indianapolis Power & Light, TVA, Tucson Electric Power, and Wisconsin Electric) and equipment 

manufacturing and construction companies (Babcock and Wilcox, Bechtel, Washington Group, Alstom, IHI Corporation, 

and Foster Wheeler).

Labor Type Permitting Design 

Engineering

System Interface / 

Site Engineering Procurement Construction Testing Outage TotalProject

Design Engineers 5 13 0 0 16 3 5 42

Construction / Site Engineers 5 3 13 0 64 3 0 88

Licensing Engineers 5 0 0 0 0 0 0 5

Procurement Engineers 0 0 0 56 16 0 0 72

Project Managers 0 0 0 0 16 0 0 16

Construction Managers 0 0 0 0 16 0 0 16

First Line Supervisors 0 0 0 0 48 0 0 48

Plumbers, Pipefitters and Steam Fitters 0 0 0 0 96 0 0 96

Boilermakers 0 0 0 0 192 0 0 192

Electronic and Control Systems Specialists 0 0 0 0 64 0 0 64

Pipe Layers 0 0 0 0 64 0 0 64

Electrician - In-House Systems 0 0 0 0 64 0 5 69

Electrician - Power Line Installers 0 0 0 0 64 0 0 64

Iron/steel Workers 0 0 0 0 96 0 0 96

Brickmasons and Blockmasons 0 0 0 0 0 0 0 0

Concrete Finishers 0 0 0 0 0 0 0 0

Operator Pile Drivers 0 0 0 0 32 0 0 32

Carpenters 0 0 0 0 0 0 0 0

General Construction Labor 0 0 0 0 223 0 0 223

Insulation Workers 0 0 0 0 64 0 0 64

Reinforcing Iron and Rebar Workers 0 0 0 0 96 0 0 96

Welders, Solderer 0 0 0 0 96 0 0 96

Construction Equipment Operators 0 0 0 0 64 0 0 64

Power Plant Operators 0 0 0 0 0 64 5 69