Technical Support Document 

for the Proposed 

Utility Air Toxics Rule 

Employment Estimates of Direct Labor in Response to the Proposed 

Toxics Rule in 2015 

EPA Docket Number: EPA-HQ-OAR-2009-0234 

March 2011 

U.S. Environmental Protection Agency 

Clean Air Markets Division 
DRAFT 

Employment Estimates of Direct Labor in Response to the Proposed Toxics Rule in 2015 

Table of Contents

Page

1. Introduction 2 

2. Overall Approach 3 

3. Employment Changes due to New Pollution Control Equipment 3 

4. Employment Changes due to Coal Retirements 7 

5. Employment Changes due to Changes in Fuel Use 8 

6. Conclusion 10 

Appendix 11 

References 16 

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Introduction 

This technical support document (TSD) presents the short-term employment estimates of the 

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

study is only on the first order employment impacts related to the compliance actions of the 

affected entities within the power sector. It does not include the ripple effects of these impacts 

on the broader economy (i.e., the “multiplier” effect), nor does it include the wider economy-wide 

effects of the changes to the energy markets (such as higher electricity prices).1

 Moreover, this 

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

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

arising from technological innovation and learning-by-doing. 

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

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

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

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

driven by the high demand for new pollution control equipment. The employment gains related 

to the new pollution controls are likely to be tempered by some losses due to certain coal 

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

plant retirements could find replacement employment operating the new pollution controls at 

nearby units. Finally, job losses due to reduced coal demand may be partially offset by job 

gains due to increased natural gas demand, resulting in small negative (less than a thousand) 

net change in employment due to fuel demand changes. Overall, the preliminary results indicate 

that the Toxics Rule could support a net of about 35,000 job-years in 2015. These results are 

summarized in Table 1 below. 

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

New Pollution Control Equipment 41,600

Retirements of Generating Units (5,630)

Changes in Fuel Use (810)

Net Effect 35,160

The job-years estimated here is a snapshot of the first order employment effect of the Toxics 

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

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

labor demand, for example, is expected to provide a short-term, temporary boost to employment 

that could last a few years, along with any multiplier effects that are not included in these jobyear estimates. Most of the operational labor needs are likely to be longer term. Thus, in terms 

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

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

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

 

1

 For more detail on the economic impacts of the proposed rule, see Chapter 8 of the Regulatory Impact 

Analysis accompanying the proposed Toxics Rule. 

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

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

other employment impacts of the Toxics Rule, such as those resulting from higher energy 

prices. 

Overall Approach 

The estimates for the near-term employment effects of the proposed rule utilize basic 

methodologies to estimate these job impacts relying on approaches used in prior EPA studies 

on similar issues. The basic approach involved using power sector projections and various 

energy market implications under the Toxics Rule from the Integrated Planning Model (IPM), 

along with data from secondary sources, to estimate the first order employment impacts for 

2015. Throughout this analysis, incremental employment is measured in job-years, since there 

is no temporal dimension to this analysis.2

 Also, this TSD does not include estimates of total 

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

related labor needs and more long-term operational labor needs for new pollution controls 

(though these operational labor requirements are also measured in 2015 job-years only). 

Employment Changes due to New Pollution Control Equipment 

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

pollution control demand. These are shown in Table 2 below:3

 

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

Pollution Control Type IPM Projected Additional 

Pollution Control 

Scrubbers (FGD) 21

Selective Catalytic 

Reduction (SCR) 2

Activated Carbon 

Injection (ACI) 93

Dry Sorbent Injection 

(DSI) 56

Fabric Filter (FF) 107

The employment impacts due to increased pollution control demand are divided into four 

categories, two of which are associated with the construction and installation related labor 

 

2

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

individual for one year (or FTE). 

3

 According to IPM, there is some overlap between the different types of pollution control equipment 

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

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

impacts. 

3 
DRAFT 

requirements, while the remaining two are associated with the resources required for the 

ongoing operation of these equipment. The two categories of labor needed for constructing and 

installing these controls are for construction-related sectors, such as boilermakers, engineers, 

and other installation labor; and for the labor needed to manufacture the steel used in the 

control equipment. The two categories of labor needs for resource requirements include 

employment in sectors that supply resources needed to run these pollution controls (such as 

reagents and catalysts); and utility sector jobs to operate these control equipment. The 

following sections discuss the approach for each: 

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

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

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

ACI).4

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

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

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

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

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

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

 Thus, all of the unit labor needed for 

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

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

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

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

pollution controls (FFs and DSIs). 

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

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

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

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

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

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

needed for installation. 

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

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

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

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

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

 These were 

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

(physical) quantity of resources needed.7

 Total tonnage (or volume for SCR catalyst) for 

 

4

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

Strategies”. EPA/ORD, 2002. 

5

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

Partners to ICF International. January 26, 2011. 

6

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

than the other controls. 

7

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

consistent with the 2002 EPA study approach. 

4 
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each resource was then converted to dollars of increased economic output for these 

resources using price estimates obtained from publicly available sources (see Table 3). 

Finally, the labor productivity for each particular sector was used to estimate the number 

of job-years these would likely create in 2015. Labor productivities for each sector were 

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

productivity and corresponding growth rates to account for future productivities came 

from the Economic Census and the Bureau of Labor Statistics (BLS) estimates.8

 

• The final employment vector estimated was for the utility sector labor needed to operate 

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

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

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

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

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

incremental labor demand to operate these pollution controls. The FOM costs were then 

translated into employment based on estimates of payroll per worker for the power 

sector taken from the 2007 Economic Census and BLS estimates.9

 

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

Amount of Resource Used   Price Used  ($/unit)

Steel (tons)             360,287 $                               550

Limestone, FGD (tons)                             6,780,477 $                                7510

Ammonia, SCR (tons)                                   55,868 $                               150

Catalyst, SCR (m3)                                     2,912 $                            8,475

Activated Carbon, ACI (tons)                                   51,126 $                            1,120

Sodium Bicarbonate, DSI (tons)                          12,498,334 $                               120

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

Limestone: FGD Tech Evaluation, March 2007. 

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

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

University, 2009. 

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

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

NETL, November 2003. 

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

 

8

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

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

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

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

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

2000 Survey of Manufacturers. See the Appendix for more details about the data used for these 

calculations. 

9

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

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

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

This price was used because IPM predicts only 1 GW of incremental wet FGD compared to 24 GW of dry 

FGD. 

5 
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Results 

Table 4 presents the estimated employment impacts in 2015 resulting from the additional 

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

to lead to a total capital investment of about $45 to $50 billion in order for the regulated entities 

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

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

42,000 job-years to design, construct, and operate the needed pollution control equipment in 

2015. Note, some of these jobs are expected to start before, and continue beyond 2015 (such 

as the resource related job-years), but this analysis only provides a snapshot for 2015. 

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

(Job-years in 2015) 

Jobs for Construction Incremental Employment

1. Boilermakers 13,400 

2. Engineers 3,270 

3. General Construction 13,770 

4. Steel Manufacturing 430 

Sub-Total: 30,870 

Jobs for Operation 

Jobs from Increased Operating 

Resource Use 

1. Limestone (FGD) 2,020 

2. Ammonia (SCR) 20 

3. Catalyst (SCR) 100 

4. Activated Carbon (ACI) 90 

5. Sodium Bicarbonate (DSI) 2,940 

6. Baghouse material (FF) 60 

Sub-Total: 5,230 

Jobs for Pollution Control Operation 5,500 

Total Labor: 41,600 

Note: Totals may not add due to rounding 

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

demand for new FFs used in IPM. As shown in Table 2, up to 107 GW of new stand-alone FF 

capacity is projected to come online in 2015 due to the Toxics Rule, which is over 10 GW more 

than ACI, the next highest. The demand for new FFs is estimated to contribute about 67 

percent of the new employment resulting from the installation of pollution controls. Moreover, of 

the labor needed due to increased resource use, the sodium bicarbonate required for DSI is 

estimated to support higher number of jobs than the other resources. This is because the DSI 

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

6 
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according to the ATP report. The second highest resource-related employment gains would 

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

Of the roughly 42,000 job-years estimated in Table 4, about 5,500 job-years, or less than 15 

percent, are estimated to occur within the utility sector for labor needed to operate the pollution 

controls (referred to as “Jobs for Pollution Control Operation” in Table 4). The rest of the labor 

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

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

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

The majority of these first order employment needs, however, are likely to benefit constructionrelated sectors, such as construction, boilermaker, heavy engineering, and other heavy 

construction sectors, due to the needs for constructing and installing the new pollution controls 

at affected sources throughout the country. 

Employment Changes due to Coal Retirements 

Employment changes due to plant retirements were estimated by first identifying the retiring 

coal units11 from IPM results (for the base and the Toxics Rule policy cases). EPA projects that 

there will be roughly 9.9 GW of additional coal retirements by 2015 with the Toxics Rule in 

place.12 

In order to convert the retired coal capacity into potential employment losses, it was assumed 

that changes in the operating costs for the retired coal units can be used as a proxy for the lost 

economic output due to fossil retirements. Thus, the changes in the O&M costs (both FOM and 

VOM) for these particular retiring units were derived using IPM outputs, and converted to lost 

jobs using data from the Economic Census and BLS output/worker estimates for the utility 

sector.13 

Note that the lost economic output due to fossil retirements is likely to affect not just the utility 

sector, but others as well. Employment losses due to plant retirements will not only affect those 

that are directly working at the plant (i.e., plant operators), but would also affect administrative 

and other “back-office” workers for those utilities and their support organizations. This TSD 

assumes that the FOM costs related to retiring plants are a good proxy for these types of job 

losses. Moreover, because the VOM costs represent the variable costs of operating the plant, 

including costs of materials needed to run any installed pollution control equipment (such as 

cost of reagents, etc.), this TSD assumes that the VOM costs can be used as an indicator of the 

employment effects on the resource suppliers to these plants and units. Thus, the retirement 

related employment losses shown below are assumed to include losses directly affecting the 

 

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

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

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

of potential job losses due to retirements provided here will understate the employment losses. 12 Retirement estimates are based on IPM System Summary Reports. Where applicable, data from IPM 

parsed outputs were adjusted to account for partial retirements reported in the parsed outputs. 13 The same specific sources as cited before, however, used workers and total payroll. 

7 
DRAFT 

utility sector as well as other “upstream” sectors that provide material inputs needed to operate 

these plants. Table 5 shows those results. 

Table 5: Job Losses due to Coal Capacity Retirements 

O&M Decrease from Retirements ($MM) 648 

Workers Per Million$ in payroll 8.7 

Workers lost due to retirements (job-year): 5,630 

Results indicate there could potentially be about 5,600 job losses (measured in job-years for 

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

retirements. However, two mitigating factors could reduce the negative employment impacts 

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

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

retiring units could well be absorbed at other units within the same firm.14 

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

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

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

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

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

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

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

Employment Changes due to Changes in Fuel Use 

Two types of employment impacts due to projected fuel use changes are estimated from IPM. 

First, employment losses due to reductions in coal demand were estimated using an approach 

similar to EPA’s coal employment analyses under Title IV of the Clean Air Act Amendments.15 

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

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

productivity (in short tons per employee hour), using 2008 labor productivity estimates.16 17 

 

14 According to the IPM results, approximately 70 percent of the coal retirements (in terms of capacity) 

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

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

March 2001. 

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

Data. Used 2008. 

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

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

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

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

introduced a high degree of uncertainty in forecasting productivity growth rates for future years. 

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

 

Table 6: Employment Due To Changes in Coal Use 

Coal by Region Change in Coal 

Demand (MM Tons)

Labor 

Productivity 

Job-year 

Change

 Appalachia (15.1) 2.91 (2,490)

 Interior 5.6 4.81 560

 West (8.7) 19.91 (210)

 Waste Coal (0.7) 5.96 (60)

Net Total (18.9) -- (2,200)

Notes: Used US national coal productivity for waste coal 

Totals may not add due to rounding 

For natural gas demand, labor productivity per unit of natural gas was unavailable, unlike coal 

labor productivities used above. Most secondary data sources (such as Census and EIA) 

provide estimates for the combined oil and gas extraction sector. This TSD thus uses an 

adjusted labor productivity estimate for the combined oil and gas sector that accounts for the 

relative contributions of oil and natural gas in the total sector output (in terms of the value of 

energy output in MMBtu). This estimate of labor productivity is then used with the incremental 

natural gas demand for the Toxics Rule to estimate the job-years for 2015. In addition, the 

projected capital cost estimates for new pipeline capacity needed to meet the 2015 demand 

levels from IPM were also used, and translated into employment using worker productivity 

estimates for the pipeline construction sector.18 These results are summarized in Table 7 

below. 

 

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

Fuel Type Employment

Coal Job Years Lost (2,200) 

Natural Gas 

 Incremental Natural Gas Use (MMBtu) 284,967,600

 Labor Productivity (MMBtu/job-year) 261,840

 Job-years gained                       1,090

Gas Pipeline 

 Capital Cost for New Pipeline Capacity 

 (US total: MM $/year) 59.2 

 

18 Same Economic Census 2007 source as used previously. Because BLS does not have growth rate 

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

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

9 
DRAFT 

 Workers/million $ in Pipeline Construction 5.1 

 Job-years gained 300 

Net Employment Effects of Fuel use changes 

 

(810) 

Note: Totals may not add due to rounding 

Thus, about 2,200 job losses in the coal mining sector are likely to be partially offset by about 

1,400 job gains in the production and transportation-related jobs in the natural gas related 

sectors, for a net effect of less than a thousand job losses due to changes in fuel use. 

Conclusion 

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

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

estimated to lead to a total pollution control-related capital investment of about $45 to $50 

billion, and results for 2015 indicate this could support or create around 35 thousand job-years, 

driven primarily by the need to design and construct the needed equipment. While there could 

be some employment losses due to coal retirements that will likely have a negative effect on 

some utilities and the coal mining sector, employment gains in pollution control operation 

activities and the natural gas sector are likely to partially offset some of those losses. As 

previously discussed, this assessment does not account for the long-run economy-wide effects 

of the proposed Toxics Rule. 

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

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

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

such as the 2005 Clean Air Interstate Rule (CAIR) TSD on boilermaker labor.19 Thus, results 

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

 

 

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

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Appendix 

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

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

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

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

discussions for coal retirements and fuel use change employment analysis. 

Pollution Control Equipment Labor 

• Installation Labor 

Table A-1: Installation Labor Requirement 

Pollution 

Control 

Type 

Incremental 

GW Installed 

Manhours/MWBoilermakers 

(%) 

Engineers 

(%) 

Others 

(%) 

FGD 21 760 40 20 40 

SCR 2 700 45 7 48 

ACI 93 10 50 17 33 

DSI 56 44 50 17 33 

FF 106.7 398 45 7 48 

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

Technology Partners. 

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

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

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

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

2,080 working hours per year. 

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

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

study and supplemented by ATP information for DSI and FF. 

 

• Installation Resource Labor 

Table A-2: Installation Resource Needs 

Pollution 

Control Type 

Steel 

(Tons/MW) 

FGD 2.25 

SCR 2.5 

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DRAFT 

ACI 0.35 

DSI 2.2 

FF 1.42 

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

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

Productivity: 2000 Annual Survey of Manufacturers:Iron and Steel Pipes and Tube Manufacturing, 

BLS for Productivity Growth Rate. 

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

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

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

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

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

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

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

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

using the productivity estimates calculated from the Economic Census data using workers per $ 

Million in total output for the iron and steel manufacturing industry (= 2.1 workers/$Million).20

• Operating Resource Labor 

Table A-3: Resources Needed for Operation

Pollution 

Control 

Type 

Incremental 

Total GW 

(Includes 

Existing 

Units) 

Resource 

(Units in 

parenthesis) 

Usage 

Estimates

Price 

($/unit) 

Industry 

Assumed for 

Productivity 

Calculations 

Productivity* 

FGD 25 Limestone 

(Tons/MWh) 0.036 75 Lime Manufacturing 4.0 

SCR 

4 

(NOx 

reduction: 

286,512,800 

lbs) 

Ammonia 

(lbs/lb NOx 

Reduced) 

0.39 150 

All Other Basic 

Inorganic 

Chemical 

Manufacturing 

2.1 

Initial Catalyst 

(m3/MW) 1.2 

8,475 

Combined: Other 

Nonferrous Metal 

Primary and 

Secondary 

Smelting and 

Refining 

Operational 3.2 

Catalyst 

(m3/MWh) 

0.00002 

ACI 93 

Activated 

Carbon 

(Tons/MWh) 

0.000074 1,120 

Other Chemical 

Product 

Manufacturing 

1.6 

 

20 In general, the productivity estimates for various sectors were derived using data from the 2000 Annual 

Survey of Manufacturers or 2007 Economic Census. These were then forecasted to 2015 using 

corresponding average growth rates estimated using data from the Bureau of Labor Statistic (BLS) 

information on productivity growth rates. 

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DSI 56 

Sodium 

Bicarbonate 

(Tons/MWh) 

0.03 120 

Potash Soda and 

Borate Mineral 

Mining 

2.0 

FF 106.7 Bag-house 

Resources 

*Resource Labor 

determined Using 

VOM cost for FFs 

Plastics Material 

and Resin 

Manufacturing 

0.6 

*Workers/$Million in Output, Forecasted to 2015 

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

Partners; 

Prices: Limestone: FGD Tech Evaluation, March 2007 

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

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

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

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

2003 

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

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

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

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

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

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

resources – ammonia and catalyst – were chosen. 21 This approach is consistent with the 2002 

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

generally in tons of material (cubic meters (m3) for catalyst), using the resource usage 

estimates as shown in Table A-3. 22 Using the total usage for each pollution control input (in 

tons or m3) and associated average prices, total expenditure by each resource type was then 

calculated. This total expenditure was then converted to labor using workers per $Million in total 

output for the industry associated with producing each respective input material.23

• Operating Labor 

Table A-4: Operating Labor Assumptions

Incremental FOM from IPM Parsed ($ Billion) 3.19 

FF Capital Cost Included in FOM ($ Billion) 1.83 

FGD Improvement included in FOM ($ Billion) 0.73 

Remaining FOM used to find O&M Labor ($ Million) 632.4 

Productivity* 8.7 

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

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

 

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

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

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

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

the total NOx reduced between the base and policy cases. 

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

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

industry sector. 

13 
DRAFT 

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

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

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

true FOM costs ($632.4 million). Resulting FOM cost estimate was then converted to labor 

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

 

Retirement Labor 

Table A-5: Inputs to Labor from Retirements 

Capacity of Incremental Retirements in SSR (MW) 9,868 

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

account for Partial Retirements) 647.9 

Workers Per $Million in payroll, forecast to 2015 8.692 

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

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

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

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

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

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

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

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

Fuel Use Labor 

Table A-6: Inputs to Labor for Fuel Use 

Coal by 

Region 2015 Incremental Fuel USE (Tons) 2008 Short Tons/Employee hour

Appalachia (15,060,000) 2.9

Interior 5,610,000 4.8

West (8,690,000) 19.9

Waste Coal (720,000) 6.0

Natural Gas 

EIA Total Natural Gas Production 2007 (TCF) 24.664

EIA Total Crude Oil Production 2007 (Barrels) 1,848,450,000

EIA Natural Gas Heat Content 2007 (Btu/cf) 1,027

EIA Petroleum Heat Content (MMBtu/Barrel) 6.151

14 
DRAFT 

Total Crude Oil and Natural Gas Production (MMBtu) 36,699,744,000

Economic Census 2007 Oil and Gas Extraction Employees 140,160

MMBtu per Man-year for Oil and Gas Extraction 261,842

Incremental Natural Gas from IPM (TCF) 0.277

Incremental Natural Gas from IPM (Converted to MMBtu) 284,967,573

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

 59.2 5.1

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

Note: Heat Contents from EIA are assumed to be for fuels used in Electric Power Sector 

Sources: Short Tons per hour from US EIA, Coal Industry Annual. Total Production from 2009 

EIA Annual Energy Review. Heat Contents from EIA, Heat Content of Natural Gas Consumed 

and 2009 Annual Energy Review. Employment Data from 2007 Economic Census. 

Fuel use related employment impacts were estimated by using IPM results for incremental 

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

coal use in tons by region from IPM were used in conjunction with labor productivity estimates 

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

needed. These were then converted to job-years, assuming 2,080 working hours per year. As 

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

productivity in recent years, no attempt was made to forecast coal (and natural gas, for 

consistency) productivities, instead the most recent historical estimates were used in this TSD 

(which was the 2008 labor productivity for coal). 

For natural gas, the first step was estimating labor productivity since such information was not 

available directly from any reliable source. EIA production data from the Annual Energy Review 

for natural gas and crude oil (in TCF and barrels, respectively), along with EIA heat content 

estimates were used to find total crude oil and natural gas production in MMBtu for 2007. Labor 

productivity in MMBtu per job-year for the Oil and Gas Extraction sector was then estimated 

using data from the Census on oil and gas extraction employment. Then, incremental natural 

gas demand from IPM (in TCF) was converted to MMBtu of natural gas demand using EIA data 

on natural gas heat content. This was then used with the labor productivity estimated above to 

calculate the total job-years needed for increased natural gas demand for the Toxics Rule. 

For pipeline capacity, a similar approach was applied, using the capital cost of new pipeline 

(from IPM) and labor productivity for the pipeline construction sector to estimate the labor 

needs. For both cases, to be consistent with coal and again because of the variability, most 

recent confirmed productivity estimates from 2007 were used in the job-year calculations. 

 

15 
DRAFT 

16 

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