### Testimony of Bruce Burton before the Environmental

Protection Agency regarding the Clean Power Plan

Washington, DC July 29, 2014 Good morning. My name is Bruce Burton. I am an International Representative with the International Brotherhood of Electrical Workers (IBEW). 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 the Clean Power Plan will lead to the closure of 41 to 49 gigawatts of coal-fired generating capacity by 2020; just six years from now. 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.
However, EPA's numbers must be viewed with some suspicion. During the Mercury and Air Toxics Standard rule making process EPA claimed MATS would close only 4.7 gigawatts of coal generation. The IBEW and others told EPA their number was far too rosy and that MATS would close 56 gigawatts of coal. Itturned-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 and the national unemployment rate stands at 6.1 percent. Unfortunately, given the IBEW's experience with MATS, these numbers could become far worse.

Closing so much coal so fast threatens the reliability of the nation's electric grid, creating the potential for widespread blackouts and brownouts during periods of peak usage. During the recent Polar Vortex, 90 percent of American Electric Power's coal plants scheduled to close under MATS were used to generate electricity. In addition, PJM, a Regional Transmission Authority (RTO) operating in the rnid-Atlantic and eastern-Midwest, reportedly came with 700 megawatts of being unable to meet electricity demand. This, during one of the coldest, snowiest, winters on record.
So, for all this pain the Clean Power Plan will certainly cause a large drop in CO2 emissions, correct? The answer is no. In fact, there will be almost no impacton CO2 emissions that contribute to global warming. As the graph included with

my testimony illustrates, the problem is not with the United States. U.S. CO2 emissions have been flat since 1990 and are forecast to remain so through the year 2030 — with or without the Clean Power Plan. The problem lies instead with our trading partners. While U.S. emissions have remained flat, CO2 output in the rest of the world has risen approximately 44 percent since 1990; from 16,000 million metric tons annually to approximately 36,000 million metric tons today. Our nation cannot afford to "go it alone" and expect our actions will have any meaningful climate impact in a world that is using more and more coal and other fossil fuels. Unless other nations act, our efforts in the United States will be for naught.
Given a recent Supreme Court decision regarding the greenhouse gas permitting rule, there is reason to believe the Court will take a skeptical view of an overly-expansive interpretation of EPA's authority to regulate greenhouse gases. With that in mind the IBEW recommends EPA reduce the significant economic impact of the Clean Power Plan by providing credit to states that have already reduced their CO2 emissions due to market-driven forces such as increased natural gas use, the retirement of older coal plants, and/or the construction of new nuclear generation. The IBEW also recommends a delay in the implementation of the Clean Power Plan in order to give states and utilities adequate time to implementcompliance strategies. Finally, though outside the scope of this rulemaking,

addressing global climate change in a meaningful way will require the full cooperation of nations like China and India. Absent their commitment, the Clean Power Plan will have no real benefit.