Testimony of Dick Wilson before the Environmental Protection 

Agency regarding the Clean Power Plan 

Washington, DC 

July 29, 2014 

Good morning. My name is Dick Wilson. I am an International Representative with the 

International Brotherhood of Electrical Workers (IBEW) and a member of Local Union 753 in 

Springfield, Missouri. On behalf of the approximately 750,000 active members and retirees of 

the IBEW, I thank you for the opportunity to testify. For the following reasons, the IBEW 

opposes the Clean Power plan as proposed. 

EPA reports within six years, the Clean Power Plan will lead to the closure of 41 to 49 

gigawatts of coal-fired generating capacity by 2020. According to the government's own figures 

this will result in the loss of 52,000 permanent, direct jobs in the utility, rail, and coal mining 

sectors. In addition, closing this much coal generation will cost an additional 100,000 indirect 

jobs. That equals 152,000 good paying, middle class jobs, and jobs that are crucial to our 

nation's economic recovery. 

However coming from the "Show Me" state, I believe the EPA's numbers must be 

viewed with some suspicion. During the Mercury and Air Toxics Standards rule making process 

EPA claimed MATS would close only 4.7 gigawatts of coal generation. The IBEW and others 

told EPA their numbers were off base and out of touch, and that MATS would close 56 gigawatts 

of coal. As it turned-out we were correct. Experts now confirm that 56 gigawatts of coal 

generation will be lost by 2016. 

Taken together, MATS and the Clean Power Plan will close approximately 40 percent of 

today's coal fleet. Gone with those plants will be approximately 400,000 American jobs at a 

time when our nation continues to recover from the worst recession since the Great Depression. 

Unfortunately, given the IBEW's experience with MATS, these numbers could become far 

worse. 

As a former Business Manager, I have seen firsthand the jobs that are created by coal 

fired power plants and the importance they play in our small towns and communities across the 

country. In my hometown of Springfield, Missouri having our own base load power supply, 

which is owned by the municipal utility has been crucial in helping southwest Missouri weather 

the Great Recession and fare far better than most communities of its size. 

According to one of the proposed plans put forth by the EPA under the Clean Power 

Plan, the City of Springfield, Missouri and its municipal utility, City Utilities of Springfield, 

would lose close to one-third of its base load generation. This would force the utility and its rate 

payers to buy power from another source, outside of the community and a source that is in the 
business of making a profit, not providing reliable and economical electricity to the rate payers 

and citizens of the community. 

We ask that the EPA take a common sense approach to the rule making process. We ask 

that EPA not sacrifice our nation's economy and electric reliability by developing a rule that 

does not take into account current commercially proven and economically viable technology to 

reduce CO2, such as the AEP Turk plant. Along with the steps to reduce CO2 emissions that 

have already been taken in states due to market driven conditions such as increased natural gas 

use, retirements of older coal plants, and/or the construction of new nuclear generation. The 

IBEW recommends a delay in the implementation of the Clean Power Plan until a common sense 

approach can be developed to reduce CO2, an approach that will give states and utilities 

adequate time to develop and implement compliance strategies. In closing, we understand that it 

is the EPA's responsibility to determine environmental policy and our nation's role in addressing 

climate change; however we do not believe that it is the EPA's role to set energy or economic 

policy as this rule clearly does. We believe that the only way to have a meaningful impact on 

climate change will be to require the full cooperation of nations like China and India, without . 

their participation and commitment this rule will accomplish no measureable results in the global 

perspective and will only serve to harm our nation's economy and electric reliability.