# wv WEST VIRGINIA

MANUFACTURERS ASSOCIATION All

. 2001 Quarrier Street, Charleston, WV 25311 Telephone: (304) 342-2123 FAX: (304) 342-4552 wvma@wvma.com April 11, 2014



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# ^ ^ ° 

# r 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 

# ^ — 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

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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 President4J
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