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

Existing Power Plants 

• My name is Kyle Brightbill. I am here speaking on behalf of SMART-TO. 

am the Vice Chairman of the Pennsylvania Legislative Board. 

• Why do Railroad Workers care? 

1. Almost 40% of all 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 

14,000 employees. 

2. 25% of the freight 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 

their jobs due to EPA's proposed Clean Power Plan. 

• EPA reports that the reduction of C0 2 emissions under the Clean Power 

Plan is equivalent to a 30% cut from 2005 emissions. However, EPA's 

proposal gives no credit to states that already have reduced their C0 2 

emissions due to market-driven forces such as increased natural gas use, 

the retirement of older 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 of further reducing their C0 2 emissions on the short timetable set 

by EPA's proposed rule. 
• We recognize that states will have flexibility in developing the measures 

to achieve the C0 2 emission reduction goals called for by the Clean Power 

Plan. However, the stringency of state reduction goals will nonetheless 

have the effect of dictating, for the first time, how states regulate the 

generation and use of energy. 

• EPA projects that the proposed C0 2 reductions would reduce U.S. coal 

production for electric generation by 3S% from 2009 levels by the year 

2020, with a comparable reduction of coal-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 that this rule will cause the loss of 41 to 49 Gigawatts of 

coal generating capacity by 2020. These retirements are in addition to the 

92 Gigawatts of coal capacity that EPA is already projecting will shut down 

between 2012 and 2020 due, in large part, to compliance with the 2012 

Mercury and Air Toxics Rule. We believe that losing around 130 Gigawatts 

of baseload coal capacity, nearly 40% of the nation's coal generation fleet 

in 2012, raises serious concerns about the future reliability of our electric 

power supplies. 

• Our reliability concerns will no doubt become even more urgent as existing 

base load nuclear units begin to retire upon the expiration of their already 

extended NRC operating licenses. 

• Our preliminary estimates of the job impacts of EPA's proposed Clean 

Power rule indicate the potential loss of S2,000 permanent direct jobs by 

2020 in the utility, rail and coal sectors due to power plant retirements, 

and the loss of 167,000 total direct and indirect jobs. These direct jobs are 

all highly-skilled, high-paying jobs, typically in rural communities without 

opportunities for comparable employment. These impacts do not consider 

any of the job losses associated with the closure of plants due to the MATS 
rule, and other factors. 

• EPA's proposal for increasing the dispatch of natural gas combined cycle 

units, in addition to the 40 Gigawatts of new natural gas combined cycle 

capacity that EPA projects to come on-line from 2020 to 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 project that utility gas 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 credit for prior C02 reductions, as an 

option towards meeting a reasonable national target for reducing C0 2 

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 implement compliance strategies in the most flexible, 

least-cost manner. 

3. EPA's proposals for major expansions of state energy efficiency and 

renewable energy programs interfere with traditional state authority in 

energy planning, and appear to be well beyond the agency's authority 

under the Clean Air Act. The Supreme Court's recent decision on the GHG 

permitting rule contains strong cautionary language that the Court will take 

a skeptical view of an overly-expansive interpretation of EPA's authority to