wv WEST VIRGINIA 

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MANUFACTURERS ASSOCIATION 

.	 2001 Quarrier Street, Charleston, WV 25311


Telephone: (304) 342-2123 

FAX: (304) 342-4552 

wvma@wvma.com

April 11, 2014 

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The Honorable Gina McCarth Y ^°

Administrator

U.S. En.-riron:nental Protection Agency ^ 

1200 Pennsylvania Avenue, N.W. ;; T :X 

Washington, D.C. 20460 ^'^' rv 

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Dear Administrator McCarthy:

On behalf of the West Virginia Manufacturers Association, I write to express our members' 

concerns about the impact that the U.S. Environmental Protection Agency's greenhouse gas 

regulatory agenda will have on the manufacturing sector in West Virginia. 

WVMA's membership consists of manufacturers from across the State. This sector provides 

opportunities for both employment and investment, thereby contributing significantly to West 

Virginia's economy. Indeed, by most recent accounts, manufacturing represents nearly 50,000 

jobs in West Virginia, eniploying 6.6% of the workforce. Thanks in part to the abundance of 

natural gas and downstream manufacturing growth, these numbers are expected to grow. 

The key to sustaining this continued growth -- and a paramount concern of our members -- is 

access to dependable and low-cost energy. Fortuitously, our State possesses a natural abundance 

of coal. It is no wonder that coal-fired power plants represented 95% of West Virginia's net 

energy generation in the past year. Thus, the electricity produced at these plants is truly the 

lifeblood of manufacturers across West Virginia. 

The EPA's plan to limit carbon emissions from new and existing power plants severely 

jeopardizes manufacturers' ability to reap the advantages of this natural resource. The proposed 

and anticipated standards are not only unnecessary, but also not technologically attainable. As a 

result, our members' operating costs will rise, putting manufacturing jobs, investment, and 

associated economic growth in West Virginia on the line. 

Board of Directors 

A, C& S, Inc.	 Bayer CropScience	Dominion Transmission 

Allied Processing Services	Bayer MaterialScience, LLC	Dow Chemical Company 

ArcelorMittal	 Charles Ryan Associates, Inc.	DuPont 

Armstrong	 Chemtura Corporation	Eagle Manufacturing Company 

Ashland Inc.	 Chesapeake Energy	ERGON, WV, Inc. 

Axiall Corporation	Continental Brick Company	Essroc Ready Mix

FirstEnergy 

ICL-IP Clearon 

Kanawha Manufacturing Company 

Kingsford Manufacturing Company 

Kureha PGA LLC 

Marble King, Inc.

Medical Action Industries 

NGK Spark Plugs (U.S.A.), Inc. 

Phillips Machine Service, Inc. 

Toyota Motor Manufacturing, WV, Inc. 

U. S. Silica Company 

Wheeling-Nisshin, Inc. 

Zoetis 
April 11, 2014 

Page 2 

We ask that the EPA seriously consider these concerns in developing reasonable greenhouse gas 

regulations that will safeguard the affordability and reliability of energy from coal-fired power 

plants. It is essential that these rules be both technically and economically feasible, and that they 

afford the greatest possible latitude to the states. We are confident that these objectives can be 

achieved by actively engaging with WVMA, other stakeholders, and the public in developing 

such standards. Thank you for your consideration, and we look forward to participating in this 

process. 

Sincerely, 

Rebecca Randolph 

President
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