Talking points for US EPA's field hearings on reducing C02 emissions from Existing Power Plants

• My name is Kyle Brightbill. Iam here speaking on behalfofSMART-TO. am the Vice Chairman ofthe Pennsylvania Legislative Board.

• Why do Railroad Workers care? 

### 1. Almost 40% ofall freight railroad cars in America are coal cars. Coal has provided the revenues needed to build and rebuild America's freight railroads. Coal revenues continue to provide the money necessary to expand and maintain our rail infrastructure. America's railroads will spend about $25b in 2014 to maintain and expand our rail infrastructure and hire about 14,000employees. 2. 25% ofthefreight rail industry's revenues come from the shipping of coal. 3. 20% of all freight rail jobs involve hauling coal.

• I am here today because our members are concerned about the loss of theirjobs due to EPA's proposed Clean Power Plan.

• EPA reports that the reduction ofC0 2 emissions underthe Clean Power Plan is equivalentto a 30% cut from 2005 emissions. However, EPA's proposal gives no creditto states that already have reduced their C0 2 emissions due to market-driven forces such as increased natural gas use, the retirement ofolder coal generating plants, and construction of new nuclear generation.

• Since 2005, C0 2 emissions from all fossil-fueled plants have decreased by 13%. Many states highly dependent on coal-based generation have already achieved significant emission reductions, but still face the additional burden offurther reducing theirC0 2 emissions on the shorttimetable set by EPA's proposed rule.• We recognize that states will have flexibility in developingthe measures to achieve the C02 emission reduction goals called for bythe Clean Power Plan. However, the stringency ofstate reduction goals will nonetheless have the effect ofdictating, forthe first time, how states regulate the generation and use of energy.

• EPA projects that the proposed C02 reductions would reduce U.S. coal production for electricgeneration by 3S% from 2009 levels by the year 2020, with a comparable reduction ofcoal-based electric generation. Even larger regional coal production reductions are projected by 2020 for Appalachia (a 63% reduction) and the West (a 47% reduction).

• EPA also projects thatthis rule will cause the loss of41to 49 Gigawatts of coal generating capacity by 2020. These retirements are in addition tothe 92 Gigawatts of coal capacitythat EPA is already projectingwill shut down between 2012 and 2020 due, in large part, to compliance with the 2012 Mercuryand AirToxics Rule. We believe that losing around 130 Gigawatts of baseload coal capacity, nearly 40% ofthe nation's coal generation fleet in 2012, raises serious concerns aboutthe future reliability ofour electric power supplies.

• Our reliability concerns will no doubt become even more urgent as existing baseload nuclear units begin to retire upon the expiration oftheir already extended NRC operating licenses.

• Our preliminary estimates ofthejob impacts of EPA's proposed Clean Power rule indicatethe potential loss of S2,000 permanent directjobs by 2020 in the utility, rail and coal sectors dueto power plant retirements, and the loss of 167,000total direct and indirectjobs. These directjobs are all highly-skilled, high-payingjobs, typically in rural communities without opportunitiesfor comparable employment.These impacts do not consider any ofthejob losses associated with the closure of plants dueto the MATSrule, and otherfactors.

• EPA's proposal for increasingthe dispatch ofnatural gas combined cycle units, in addition tothe

### 40 Gigawatts of new natural gas combined cycle capacitythat EPA projectsto come on-line from 

### 2020to 

### 2030, will lead to significant increases in natural gas prices well above EPA's projections. These price increases will be further amplified by 

### LNG exports. Independent analysts projectthat utilitygas demand may rise three-fold above EPA's forecast. Consumers and energy-intensive industries will bear the brunt of these gas price increases.
We have several recommendations about revisions to the Clean Power Plan:
1. The plan should provide states with creditfor prior C02 reductions, as an option towards meeting a reasonable national target for reducing C02 emissions from the electric power sector.

2. EPA's compliance timetable is unrealistic and unachievable, even with multi-year compliance averaging toward the interim and final targets. The initial reduction program should be delayed by several years to allow states and affected sources adequate time to prepare and submit state plans, and to structure and implementcompliance strategies in the mostflexible, least-cost manner.
3. EPA's proposals for major expansions ofstate energy efficiency and renewable energy programs interfere with traditional state authority in energy planning, and appearto be well beyond the agency's authority underthe Clean Air Act. The Supreme Court's recent decision on the GHG permitting rule contains strong cautionary languagethat the Court will take
askeptical view ofan overly-expansive interpretation of EPA's authorityto