Good morning, my name is Jeff Kelley and I am President and General Manager of 

Vindex Energy, a Subsidiary of Arch Coal, Inc. Vindex and Arch appreciates having the 

opportunity to share publicly the following comments in response to the EPA's proposed 

emission guidelines for states to follow. Vindex Energy operates surface and deep coal mines in 

Allegheny and Garrett County, MD and Grant County, WV. We produce in excess of 600,000 

tons of coal each year to supply local power generators which intern supplies electricity for the 

eastern US. Vindex Energy employees approximately 95 full time employees with an annual 

payroll, including benefits of $9.2 million dollars. 

The power generators' transformation of our coal and that of other suppliers into a lowcost, stable flow of electricity is a vital national service that is now in jeopardy due to EPA's 

proposed regulations. The United States' success since the industrial revolution has been due to 

the abundance of cheap affordable power to supply our factories, businesses and homes. In large 

part this has come from COAL. EPA's proposal threatens continued domestic coal utilization in 

the hope of preventing global climate change, but will not meaningfully or economically deliver 

on this objective. U.S. power plants are responsible for a relatively small percentage of global 

GHG emissions—about 4%. EPA's proposal will reduce global GHG emissions by a tiny 

amount (less than 1%) at a cost projected by the agency itself of $4.2 to $8.8 billion per year. In 

exchange for reducing coal utilization for power generation, American consumers, my family 

and I, will receive rising electricity prices and reduced electric power reliability. 

EPA estimates that its rule will increase electricity prices between 6 and 7% nationally by 

2020. That increase masks substantially higher double digit increases in some states, including 

my own (West Virginia) that generates most of its electrical power (95%) from coal. Rate 

increases will fall disproportionately on the lower income and middle income families. Since 

1 
2001, energy costs have increased by 27% for middle and lower income families, while their 

incomes have declined by 22%. The increases will also place a significant burden on U.S. 

businesses for which affordable energy provides a critical operating advantage in competitive 

global markets. Also, Power Plants are only the first step of the EPA's broader greenhouse gas 

agenda. New rules restricting emissions from landfills, refineries, pulp and paper mills, iron and 

steel production, livestock operations and cement manufacturing will follow. Lastly, the price 

of all goods and services will increase, further harming all Americans. 

Power supply in the U.S. is reliable because of adequate, non-intermittent baseload 

generating capacity. The primary fuel powering this generation is coal. It is sourced by U.S. 

power generators predominately from domestic supply sources, which have limited alternative 

domestic and foreign markets. If the utilities are forced to comply with the EPA's proposals as 

they stand, compliance costs as high as $28 billion per year could be realized, job losses of up to 

4 million Americans would occur and the forced shutdown of over half of all U.S. coal-fired 

could occur. Since 2005, American power plants have already reduced CO2 emissions by 21% 

and are projected to remain 19% below 2005 levels through 2020. It must be noted that CO2 

emissions from US power plants represent only 4% of global greenhouse gas emissions. No 

matter how stringent the EPA approach, the climate effects will be meaningless... but the costs 

will be very high. An example of the true reduction.... If all US coal fired power plants were 

eliminated, the global temperature through 2050 would be reduced by less than 1/20thof a degree 

and reduced sea level rise would be less 1/25thof an inch (less than the thickness of a dime). 

Many other countries continue to increase their use of coal, while the EPA is taking 

unilateral action that penalizes the US economy. The U.S. has led the world in reducing CO2 

emissions since 2005. During that time, U.S. emissions have fallen while China's have grown 

2 
by 69% and India's by 53%. Emissions growth in China and India accounted for 90% of global 

growth in emissions from 2005 to 2012. 

In summary, EPA's proposal negligibly reduces GHG emissions, imposes higher cost 

electricity on U.S. households and industry, reduces the reliability of the power grid, and is 

neither permissible under existing law nor technically feasible. For these reasons, Arch 

respectfully requests that the agency withdraw its proposed rule—thank you for your time and 

attention. 

3