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Labor Availability for the Installation of Air Pollution 

Control Systems at Coal-Fired Power Plants

October 18, 2011

James E. Staudt, Ph.D.

Andover Technology Partners

In response to new and upcoming EPA air regulations for the electric power fleet, in particular the 

proposed Utility NESHAP (Toxics Rule) and the final Cross-State Air Pollution Rule (CSAPR), the nation’s 

fleet of coal-fired power plants is expected to install additional pollution control systems—such as 

scrubbers and fabric filters—over the next several years. These investments will create increased 

demand for construction materials, equipment and labor to design and install these vital controls. 

Contrary to claims that labor shortages will delay the installation of controls, our current analysis 

indicates that more than sufficient skilled labor is available to build the pollution control systems

required by these EPA air rules while creating jobs for American workers and boosting the national 

economy. Most notably:

 Based on conservative assumptions, more than 17,000 boilermaker job-years are available, 

providing a 3,000 job-years cushion over the 14,000 job-years EPA estimated are needed to comply 

with the Toxics Rule and CSAPR; and 

 The substantial drop in boilermaker man-hours from 2008 (40.5 million) to 2010 (28 million) 

demonstrates that the current market has substantial underutilized capacity to expand quickly to 

meet the increased demand.

Historically, with the introduction of any new regulations requiring significant investments in modern 

pollution controls, industry groups have raised concerns about labor availability to construct and install 

the equipment on a timely basis. In response to EPA’s CSAPR and Toxics Rule air regulations some 

groups again have asserted there are not enough laborers, in particular boilermakers, to construct and 

install the necessary pollution control equipment in the time required. Past experience, however, 

indicates these concerns are unfounded. For example, predictions of labor shortages in response to the 

NOx SIP Call and the Clean Air Interstate Rule (CAIR) that would have limited or delayed projects never

materialized. The market responded effectively to the increased demand during the implementation of 

these programs. In fact, the industry installed scrubbers in response to CAIR at a much faster rate than 

EPA had anticipated upon issuance of the rule.

In its analysis of the proposed Toxics Rule, EPA estimated that 13,400 boilermaker jobs (job years) will 

be necessary by 2015 to complete the pollution control installations required by the rule.1 In addition, 

EPA estimated that CSAPR will require 890 boilermaker jobs (job years) by 2014, although some of the 

predicted retrofits may overlap with the controls required for the Toxics Rule.2 The National Association 

of Construction Boilermaker Employers estimates that, as of 2010, there were 24,500 active 

boilermakers working in the construction trades. Using a conservative assumption that 35 percent of 
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boilermakers are available at any given time to work on pollution control retrofits3, and a worst-case 

scenario that boilermakers will be active for only a two-year period in constructing retrofits in response 

to these rules, a minimum of more than 17,000 boilermaker job-years should be available to construct 

the necessary pollution control systems.1 This worst case estimate significantly exceeds the 

approximately 14,000 boilermaker job years that EPA predicts will be required by 2015 under both air 

regulations; however, there is much more excess labor capacity to meet the demand because:

 The notion that there is a strict limit of available boilermakers is incorrect. In the past, industry 

groups justified their concerns 

by assuming a “hard cap” on 

boilermaker labor availability;

however, history has proven 

such a hard cap places 

unrealistic limits on retrofit 

activity as the labor market is, 

in fact, dynamic: the supply of 

labor is able to shift and grow 

rapidly in response to 

demand.4 While boilermakers 

indeed represent a highly 

specialized trade, experience 

has demonstrated that the 

available workforce for 

installing pollution control 

retrofits is highly flexible and 

can respond quickly to 

increased demand required 

under EPA’s new air rules. For 

example, during the CAIR 

compliance construction 

period, boilermaker activity in 

constructing pollution control equipment significantly surpassed the number of boilermakers 

predicted to be available by both EPA and industry groups, which, in part, explains why both EPA 

and industry consultants underestimated the rate of equipment installation.4

 Historically, the boilermaker’s trade has grown rapidly in response to increased demand. Over only 

two years, from 1999 to 2001, membership in the International Brotherhood of Boilermakers (IBB), 

the union that represents most boilermakers in the United States and Canada, grew by over 35%, or 

6,700 boilermakers.5 This increase was fueled by the increased demand for labor for installation of 

SCRs to comply with the NOx SIP Call. This rapid growth demonstrates that, despite the need for 

training, the boilermaker labor force is able to expand quickly to meet demand. Additionally, the 

Boilermakers National Funds, which manages boilermakers’ pensions, has special rules allowing 

retirees to return to work without suspension of benefits in case of a labor shortage.6

 

1

This effectively assumes that all of the retrofit work will occur within a two year window. In practice, the Clean 

Air Act allows three years to comply with the Toxics Rule with additional time allowed for the installation of 

controls on a case-by-case basis.

Boilermakers from Local 363 are installing a scrubber system at 

Dynegy’s Baldwin Energy Complex in Baldwin, Illinois 

http://www.boilermakers.org/resources/news/V49N3/kudos
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 While EPA has conservatively estimated that 35 percent of total boilermakers are available to work 

on pollution control retrofits, other types of boilermakers can be retrained to work in the pollution 

control sector if necessary. The number of all types of boilermakers in IBB is over 63,0007, which 

includes those that work in other industries such as manufacturing; these workers have similar skill 

sets to boilermakers working in the power sector, and can be trained to perform the same work. 

Workers in related trades, such as shipbuilders and ironworkers, some of whom share a union with 

boilermakers, can also be cross-trained to perform boilermaker duties. For example, the IBB 

estimates that a shipbuilder can be cross-trained to boilermaker status within a year.8

 Using modular construction, in which components of a pollution control system are fabricated in 

offsite shops rather than on-site fabrication, the labor requirement for a project can be reduced by 

up to 30%, which will free up labor for other projects.9

 Furthermore, experience has shown that the utility industry plans well ahead. For example, even 

prior to CAIR’s finalization, the industry had ordered about 40 GW of scrubbers, and ordered 

another 60 GW within only months of the rule’s finalization.4Such advance planning enables 

industry to spread out the retrofit projects and reduce peaks in labor demand. For this reason, the 

assumption of all work being performed over only a two year period is extremely conservative.

 In their analysis of the impact of the proposed Toxics Rule EPA made very conservative assumptions 

about mercury control and did not take into consideration the ability to upgrade existing ESPs to 

meet the proposed PM standards, and therefore EPA’s prediction of fabric filter retrofits in the

proposed Toxics Rule likely exceeds what will actually happen.

 Moreover, unemployment in the construction trades, at 13.3%, remains higher than in other sectors 

of the economy.

10

 While no unemployment numbers are specifically available for boilermakers, 

boilermakers apparently are working at less than full capacity as man-hours worked dropped 

significantly from a peak of 40.5 million in 2008 to 28 million in 2010, and 2011 hours are on track to 

remain at similar levels.11 (Figure 1, below.) This strongly suggests a substantial amount of 

underutilized capacity exists and workers would be able to increase their work hours in response to 

higher demand. The work resulting from this retrofit activity would be welcome to currently 

underemployed boilermakers.

Figure 1. Construction boilermaker hours worked, in millions, 1990-2010
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These factors, combined with the significant existing population of skilled and trained boilermakers, 

show that the existing boilermaker labor force will be able to construct and install the pollution controls 

required under the new EPA air rules in time to satisfy the requirements of these rules. This increased 

boilermaker labor—along with that of other skilled labor trades involved in building and manufacturing

pollution control equipment—will lead to cleaner air and a stronger economy.

References

 

1

EPA. 2011. “Regulatory Impact Analysis of the Proposed Toxics Rule.” 

http://www.epa.gov/ttn/atw/utility/ria_toxics_rule.pdf

2

EPA. 2011. “Regulatory Impact Analysis for the Final Transport Rule.”

http://epa.gov/airtransport/pdfs/FinalRIA.pdf

3

EPA. 2005. “Boilermaker Labor Analysis and Installation Timing.” Technical support document for final Clean Air 

Interstate Rule. http://www.epa.gov/cair/pdfs/finaltech05.pdf

4

Staudt, James E. 2010. “White Paper: Availability of Resources for Clean Air Projects.” 

http://andovertechnology.com/images/white%20paper%20-

%20availability%20of%20resources%20for%20clean%20air%20projects_public.pdf

5

EPA. 2005. “Boilermaker Labor Analysis and Installation Timing.” Technical support document for final Clean Air 

Interstate Rule. http://www.epa.gov/cair/pdfs/finaltech05.pdf

6

Boilermakers National Funds, “8th Special Retiree Work Rule in Effect.” http://www.bnfkc.com/news.aspx?id=6328

7

International Brotherhood of Boilermakers. Telephone call. October 17, 2011.

8

EPA. 2005. “Boilermaker Labor Analysis and Installation Timing.” Technical support document for final Clean Air 

Interstate Rule. http://www.epa.gov/cair/pdfs/finaltech05.pdf

9

Institute of Clean Air Companies, March 2004. “IAQR Projected 2015 Control Technologies Can Be Installed by 

2010.” http://www.icac.com/files/public/IAQRboilermaker.pdf

10 Bureau of Labor Statistics. “Industries at a Glance: Construction.” http://www.bls.gov/iag/tgs/iag23.htm. 

Accessed 10/14/2011.

11 National Association of Construction Boilermaker Employers. 2011. “Manhour Reports.” 

http://www.nacbe.com/manhour.html Accessed 10/14/2011.