***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 1 EO12866MACT_NSPSUtilitiesMATS2060_AP52RIA20111104Ch6.docx **CHAPTER 6 EMPLOYMENT**  **IMPACT ANALYSIS**  In this chapter, estimates are provided for select employment effects of the rule , for both the regulated industry (electric power industry) and the environmental control industry. **6 .**  **1 Empl**  **oyment Impacts for the MA T**  **S** In addition to addressing the cos ts and benefits of the MATS , EPA has estimated certain impacts of this rule on employment , which are presented in this section. 1 While a standalone analysis of employmen t impacts is not included in a standard cost - benefit analysis, such an analysis is of particular concern in the current economic climate of sustained unemployment. Executive Order 13563, states, “ Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation ” (emphasis added). Therefore, the Agency ha s provided this analysis to inform the discussion of labor demand and employment impacts. The estimate s in clude the employment impacts on the regulated industry over time. Also provided are certain short - term and on - going employment impacts (increase in labor demand) associated with the construction of needed pollution control equipment , and other activities, to comply with the regulation. The Agency ha s not quantified the rule ’ s effects on all labor in other sector s not regulated by the MATS , or the effects induced by changes in workers ’ incomes. What follows is an overview of the various ways that environme ntal regulation can affect employment, followed by a discussion of the estimated impacts of this rule. EPA continues to explore the relevant theoretical and empirical literature and to seek public comments in order to ensure that such estimates are as acc urate, useful and informative as possible. From an economic perspective , labor is an input into producing goods and services . I f regulation requires that more labor be used to produce a given amount of output, th e additional labor is reflected by an incre ase in the cost of production. Moreover, when the economy is at full employment, we would not expect an environmental regulation to have an impact on overall employment because labor is being shifted from one sector to another. On the other hand, in peri ods of high unemployment, an increase in labor demand due to regulation may result in a short - term net increase in overall employment due to the potential

1 See the employment impacts appendix included in this RIA.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 2 hiring of previously unemployed workers by the regulated sector to help meet new requirements (e.g., to install new equipment) or by the environmental protection sector to produce new abatement capital . With significant numbers of workers unemployed, the opportunity costs associated with displacing jobs in other sectors are likely to be much smaller. To provide a partial picture of the employment consequences of this rule, EPA takes two approaches. First, the analysis uses the results of Morgenstern, Pizer, and Shih (2002) to estimate the effects of the regulation on the regulated industry, the electric power industry in this case. This approach has been used by EPA previously in recent Regulatory Impact Analyses. Second, EPA uses information derived from engineering studies and projections of pollution controls from the power sector modeling to generat e estimates of employment impacts to the pollution control sector. EPA is interested in public comments on the merits of including information derived in this fashion for assessing the employment consequences of regulations. Section 6.2 discusses the esti mates of the employment consequences in the electricity sectors, using the Morgenst ern, et al. approach. Section 6. 3 estimates the employment consequences in the environmental protection sector. **6.2 Employment Impacts Primarily on the Regulated Industry:**  **Morgenstern, Pizer, and Shih (2002)**  EPA examined possible employment effects within the electric utility sector using a peer - reviewed, published study that explores historical relationships between industrial employment and environmental regulations (Morg enstern, Pizer, and Shih, 2002). For context, in 2007, the electric power generation, transmission and distribution sector (NAICS 2211) had approximately 510,000 paid employees (a ccord ing to the 2007 Economic Census) . Estimates from Morgenstern et. al. stu dy have been applied in recent RIAs to derive the employment effects of new regulations within the regulated industry. (See, for example, the Regulatory Impact Analyses for the proposed MATS and final CSAPR regulations). We believe this study is applicable to this employment analysis, as it was for the MATS proposal , since the pollution control strategies or measures that form the basis of the cost inputs in the Morgenstern et al. analysis are primarily add - on or end - of- line pollution controls, in general covering more than 70% of the abatement expenditures in most years and industrie s analyzed as shown in Table 6 - 1 . The analysis of control strategies presented in Chapter 3 of this RIA are composed entirely of add - on or end - of- line pollution controls. Thus , the cost inputs in the Morgenstern et al. analysis are consistent with the cost inputs that enter into this analysis of employment impacts within the regulated industry for MATS.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 3 **Table 6**  **- 1**  **. Percent of Abatement Expenditures**  **in Different PACE Studies from Add**  **- On or** 

**End -**  **of -**  **Line Control Measures 2**  **Industry Percent**  **1979 1983**  **1988 1991**  Pulp and Paper 84 80 61 47 Plastics 85 88 75 67 Petroleum Refining 72 57 63 61 Iron and Steel 96 93 94 92 Determining the direction of employment effects in the regulated industry is challenging due to competing effects. The fundamental insight of Morgenstern, et al. is that environmental regulations can be understood as requiring regulated firms to add a new output (environmental quality) to their product mi xes. Although legally compelled to satisfy this new demand, regulated firms have to finance this additional production with the proceeds of sales of their other (market) products. Satisfying this new demand requires additional inputs, including labor, and may alter the relative proportions of labor and capital used by regulated firms in their production processes. Thus, Morgenstern et al. decompose the overall effect of a regulation on employment into the following three subcomponents:

 The “Demand Effect”: higher production costs raise market prices, reducing consumption (and production), thereby reducing demand for labor within the regulated industry (an unambiguously negative effect);

 The “Cost Effect”: Assuming that the capital/labor ratio in the produc tion process is held fixed, as production costs increase, plants use more of all inputs, including labor, to maintain a given level of output. For example, in order to reduce pollutant emissions while holding output levels constant, regulated firms may req uire additional labor (an unambiguously positive effect) ;

 The “Factor - Shift Effect”: Regulated firms’ production technologies may be more or less labor intensive after complying with a regulation (i.e., more/less labor is required per dollar of output). “ E nvironmental activities may be more labor intensive than conventional production,” meaning that “the amount of labor per dollar of output will rise.” However, activities may, instead, be less labor

2 U.S. Bureau of the Census. Pollution Abatement Costs and Expenditures . Washington, DC: U.S. Government Printing Office, various years. The pulp and paper industry is defined by SIC 2611 & 2621, plastics by SICE 282, petroleum refining by SIC 2911, and iron and steel by SIC 332. For pulp and paper and iron and steel industries in 1983 the data is partially estimated based on non reported data due to disclosure reasons. The 1984 (1989) data for plastics (pulp and paper) is used instead of 1983 (1988) due to a lack of reported data in the original year.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 4 intensive because “cleaner operations could involve aut omation and less employment, for example.” (p. 416) (ambiguous effect) Decomposing the overall employment impact of environmental regulation into three subcomponents clarifies the conceptual relationship between environmental regulation and employment in r egulated sectors, and permitted Morgenstern, et al. to provide an empirical estimate of the net impact. For present purposes, the net effect is of particular interest, and is the focus of our analysis. The demand effect is expected to have a n unambiguousl y negative effect on employment, the cost effect to have a n unambiguously positive effect on employment, and the factor - shift effect to have an ambiguous effect on employment. Without more information with respect to the magnitudes of these three competing effects, it is not possible to predict the net employment effect in the regulated sector . Using plant - level Census information between the years 1979 and 1991, Morgenstern et al. estimate the size of each effect for four highly polluting and regulated ind ustries (petroleum, plastic material, pulp and paper, and steel). On average across the four industries, each additional $1 million ($1987) spending on pollution abatement results in a (statistically insignificant) net increase of 1.55 (+/ - 2.24) jobs. As a result, the authors conclude that increases in pollution abatement expenditures do not necessarily cause economically significant employment changes. The conclusion is similar to Berman and Bui (2001) who found that increased air quality regulation in Lo s Angeles did not cause in large employment changes. Since the Morgenstern, et al. parameter estimates are expressed in jobs per million ($1987) 3 of environmental compliance expenditures, their study offers a transparent and simple way to transfer estimat es for other employment analysis. For each of the three job effects outlined above, EPA used the Morgenstern et. al. four industry average parameters and standard errors along with the estimated private compliance costs to provide a range (based on the 95t h percentile of results) of employment effects in the electricity sector associated with the rule. By applying these estimates to annualized cost for the final rule for the electric power sector as shown in Chapter 3 of this RIA ($9.2 billion in 2007$) , the Agency estimated each effect. The results are:

3 The Morgenstern et al. analysis uses “production worker” as defin ed in the US Census Bureau’s Annual Survey of Manufactures (ASM) in order to define a job. This definition can be found on the Internet at http://www.census.gov/manufacturing/asm/ definitions/index.html***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 5  Demand effect: −38,000 to +2,000 jobs in the directly affected sector with a central estimate of −18,000;

 Cost effect: +4,000 to +20,000 jobs in the directly affected sector with a central estimate of +1 2,000; and

 Factor - shift effect: +200 to +27,000 jobs in the directly affected sector with a central estimate of +13,000. EPA estimates the net employment effect to range from −1 4 ,000 to +30,000 jobs in the directly affected sector with a central estimate of +8,000. 4 5 EPA recognizes there will be other employment effects which are not considered in the Morgenstern et al. study. For example, employment in environmental protection industries may increase as firms purchase more pollution control equipment an d services to meet the rule’s requirements. EPA does provide such an estimate of employment change later in this section in a separate analysis. On the other hand, industries that use electricity will face higher electricity prices as the result of this ru le, potentially reduc ing output, and demand ing less labor. A defensible methodology for evaluating the employment impacts beyond the environmental protection and regulated sectors is not yet available, though as noted before , net effects on employment are expected to be at or very close to zero for the economy overall under full employment. Attempts to estimate such effects usually rely on input - output methodologies that hold technologies and the proportion of various inputs constant over time, making them inappropriate for estimating long run impacts of regulation. **6.2 .1**  **Limitations** The Morgenstern et al. approach to employment analysis has the advantage of carefully controlling for many possibly confounding effects in orde r to separate the effect of changes in regulatory costs on employment. Although the Morgenstern et al. paper provides information about the potential job effects of environmental protection programs, however, there are several caveats associated with using those estimates to analyze the final rule. First, the Morgenstern et al. estimates presented in Table 6 - 2 and used in EPA’s analysis represent the weighted average parameter estimates for a set of manufacturing industries (pulp and paper,

4 Since Morgenstern’s analysis reports environmental expenditures in $1987, we make an inflation adjustment the IPM costs using the ratio of the annual consumer price index, U.S. city, all items reported by the U.S. Bureau of Labor S tatistics: CPI 1987/ CPI 2007 = (113.6/207.3) = 0.55. 5 Net employment effect = 1 .5 5 × $9,200 million × 0. 55. Given the 95% confidence interval for this effect, this estimated net result is not statistically different from zero.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 6 plastics, petrol eum, and steel). Unfortunately this set of industries does not overlap directly with the electric utility sector. Second, relying on Morgenstern et al. implicitly assumes that the employment estimates derived from 1979 – 1991 data are still applicable. Third , the methodology used in Morgenstern et al. assumes that regulations affect plants in proportion to their total costs. In other words, each additional dollar of regulatory burden affects a plant by an amount equal to that plant’s total costs relative to t he aggregate industry costs. By transferring the estimates, EPA assumes a similar distribution of regulatory costs by plant size and that the regulatory burden does not disproportionately fall on smaller or larger plants. Fourth, the Morgenstern et al. an alysis makes particular assumptions about the role of imports and the effect of previous regulation on plant closures. While imports are not an issue for MATS , the stringency of the current regulation is expected to result in a number of power plant closu res due to early retirement of coal - fired EGU capacity in 2015, as indic ated in Chapter 3 of this RIA. Finally, the Morgenstern et.al. methodology does not examine the effects of regulation on employment in sectors related to , but outside of the regulated sector, but it does suggest that it is not appropriate to assume that the employment impact in any sector is directly proportional to increased costs . **Table 6 -**  **2 .**  **Employment Impacts Within the Regulated Industry**  **Using Peer -**  **Reviewed Study**

**Estimates using Mor genstern et al. (2002)**  **Estimates Using Morgenstern, et. al (2002) Demand Effect**  **Cost Effect Factor Shift Effect**  **Net Effect** Change in Full -Time Jobs per Million Dollars of Environmental Expenditure −3.56 2.42 2.68 1.55 Standard Error 2.03 0.83 1.35 2.24 EPA Estimate for Rule b −38,000 to +2,000 +4,000 to +20,000 +200 to +27,000 −14,000 to +30,000 a Expressed in 1987 dollars . Adjustment of dollars from 2007 to 1987 is accomplished through use of the annual Consumer Price Index – All Urban Consumers, found on the Internet at ftp://ftp.bls.gov/pub/special.request s/cpi/cpiai.txt . U.S. Department of Labor, Bureau of Labor Statistics . Washington, D.C. b According to the 2007 Economic Census, the electric power generation, transmission and distribution sector (NAICS 2211) had approximately 510,000 paid employees. Both the midpoint and range for each effect are reported in the last row of the table.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 7 **6.3 Employment Impacts of the MATS**  **- Environmental Protection Sector Approach by**  **2015 6**  Regulations set in motion new orders for pollution control equipment and services. New categories of employment have been created in the process of implementing regulations to make our air safer to breathe. When a regulation is promulgated, the first response of industry is to order pollution control equipment and services in order to compl y with the regulation when it becomes effective. This section presents estimates for short term employment needed to design, construct, and install the control equipment in the three or four year period leading up to the compliance date. Revenue and empl oyment in the environmental technology industry have grown steadily between 2000 and 2008, reaching an industry total of approximately $300 billion in revenues and 1.7 million employees in 2008. 7 While these revenues and employment figures represent gains for the environmental technologies industry, they are costs to the regulated industries required to install the equipment. As with any pool of labor, the gross size of the labor pool does not reflect the net impact on overall employment after adjusting for shifts in other sectors. Regulated firms hire workers to design and build pollution controls. Once the equipment is installed, regulated firms hire workers to operate and maintain the pollution control equipment – much like they hire workers to produc e more output. Of course, these firms may also reassign existing employees to do these activities. Environmental regulations also support employment in many basic industries. In addition to the increase in employment in the environmental protection indus try ( to fill increased orders for pollution control equipment placed by the regulated sector ), environmental regulations also support employment in industries that provide intermediate goods to the environmental protection industry. For example, an invest ment in capital expenditures to reduce air pollution involves the purchase of abatement equipment. The equipment manufacturers, in turn, order steel, tanks, vessels, blowers, pumps, and chemicals to manufacture and install the equipment. A

6 EPA expects that the inst allation of retrofit control equipment in response to the requirements of this proposal will primarily take place within 3 years of the effective date of the final rule, but there may be a possibility that some installations may occur within 4 years of the effective date. 7 In 2008, the industry totaled approximately $315 billion in revenues and 1. 7 million employees including indirect employment effects, pollution abatement equipment production employed approximately 4.2 million workers in 2008. These ind irect employment effects are based on a multiplier for indirect employment = 2.24 (1982 value from Nestor and Pasurka - approximate middle of range of multipliers 1977 - 1991). Environmental Business International (EBI), Inc., San Diego, CA. Environmental Bu siness Journal, monthly (copyright). http://www.ebiusa.com/ EBI data taken from the Department of Commerce International Trade Administration Environmental Industries Fact Sheet from April 2010: http://web.ita.doc.gov/ete/eteinfo.nsf/068f3801d047f26e85256883006ffa54/4878b7e2fc08ac6d85256883006c4 52c?OpenDocument***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 8 study by Bezdek, Wendling, and DiPernab (2008) found that “ investments in environmental protection create jobs and displace jobs, but the net effect on employment is positive. ” 8 The focus of this part of the employment analysis is on short - term employment related to the compliance actions of the affected entities. This analysis estimates the employment impacts due to the increased demand for pollution control equipment in response to MATS. 9 Results indicate that the MATS has the potential to result in a net increase of labor in these industries, driven by the high demand for new pollution controls. Overall, the results of the environmental protection sector approach indicate that the MATS could support an increase of about 4 7 ,000 job - years 10 by 2015. **6. 3**  **.1 Overall Approa**  **ch and Methodology for Environmental Protection Sector Approach** EPA developed estimates of the potential employment changes for the Environmental Protection Sector using a bottom - up engineering based methodology combined with macroeconomic data on industri al output and productivity, to estimate employment impacts. The approach relies heavily on the projections and cost ing analysis from the IPM model, which uses industry specific data and assumptions to derive compliance costs and energy impacts (See Chapte r 3 ) . Central to t he approach are prior EPA studies on similar issues, and in particular , data and information from extensive engineering studies that the Agency has commissioned . 11 The analysis develops employment estimates by relying on IPM projections from the MATS analysis for the specific types of pollution control technologies expected to be installed to comply with the rule. 12 More specifically, the analysis includes estimates for the labor needed to design, manufacture and install the needed pollution control equipment over the 3 to 4 years leading up to compliance in 2015. For construction labor, the labor needs are derived from an update to a 2002 EPA resource analysis for bu ilding various pollution controls (FGD – Flue Gas Desulfurization

8 Environmental protection, th e economy, and jobs: National and regional analyses , Roger H. Bezdek, Robert M. Wendling and Paula DiPerna, Journal of Environmental Management Vol ume 86, Issue 1 **,** January 2008, Pages 63 - 79. 9 For more detail on methodology, approach, and assumptions, see TSD as part of the Toxics Rule Docket: “ Employment Estimates of Direct Labor in Response to the Proposed Toxics Rule in 2015. ” 10 Numbers of job yea rs are not the same as numbers of individual jobs, but represents the amount of work that can be performed by the equivalent of one full - time individual for a year (or FTE). For example, 25 job years may be equivalent to five full - time workers for five yea rs, twenty - five full - time workers for one year, or one full - time worker for twenty - five years. 11 Engineering and Economic Factors Affecting the Installation of Control Technologies for Multipollutant Strategies EPA - 600/R - 02/073 (2002) and Engineering and E conomic Factors Affecting the Installation of Control Technologies – An Update (2011) . 12 Detailed results from IPM for the MATS can be found in Chapter 3 of the RIA.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 9 scrubbers, SCR - selective catalytic reduction, ACI – activated carbon injection, DSI - dry sorbent injection, and FF - Fabric Filters) and are further classified into different labor categor ies. These categories include boilermakers, engineers and a catch - all “ other” installation labor. For the inputs needed (e.g., steel), the updated 2002 resource study was used to determine the steel demand for each MW of additional pollution control, combi ned with labor productivity data from the Economic Census and BLS for relevant industries. More detail on methodology, assumptions, and data sources can be found in Appendix 6A for this RIA. Projections from IPM were used to estimate the incremental retrof it capacities projected in response to the final rule. These additional pollution controls are shown in Table 6 - 3 , and reflect the added pollution controls needed to meet the requirements of the rule. Additional information on the power sector impacts can be found in Chapter 3 of the RIA. **Table 6 -**  **3 .**  **Increased Pollution Control Installations due to MATS, by 2015 (GW)**

**Retrofit Type IPM Projected Additional Pollution Control**  FGD 15 ACI 92 DSI 45 FF 88 **6.3 .2**  **Summary of Employment Estimates from Environmental Protection Sector Approach**  Table 6 - 4 shows the results of employment impacts resulting from the additional demand for the aforementioned pollution controls. The results indicate that MATS could support or create roughly 4 7 ,000 one - time job - years of increased cost of direct labor, driven by the need to design and build the pollution control retrofits. **Table 6 -**  **4 .**  **Employment Effects Using the Environmental Protection Sector Approach for the**

**MATS (in Job -** **Years)**

**Employment Incremental Employment**  One - Time Employment Changes for Construction 1. Boilermakers 20,600 2. Engineers 5,100 3. General Construction 21,300 **Total 47,000** ***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 10 **6.3 .3**  **Other Employment Impacts of the Proposed Toxics Rule** There are also likely to be other employment impacts associated with MATS . These include changes resulting from additional labor needed to operate the needed pollution controls, increased demand for materials used in pollution control operation, shifts in demand for fuel in response to t he rule, changes in employment resulting from additional coal retirements, and changes in other industries due to changes in the price of electricity and natural gas. The EPA has provide d estimates of some of these effects below, which can be found in App endix 6A. The most notable of the ones that the Agency is unable to estimate is the impacts on employment as a result of the increase in electricity and other energy prices in the economy. Nor is the Agency able to quantify all the employment changes in industries that support and supply the pollution control industry. Because of this inability to estimate all the important employment impacts, EPA neither sums the impacts that the Agency is able to estimate for the se other employment impacts or make any inferences of whether there is a net gain or loss of employment across the se categories . A summary of the other employment impacts can be found in Table 6 - 5 , with additional detail provided in Appendix 6A. **Table 6 -**  **5 . Other Employment Impacts of MATS (i**  **n Job -** **Years)** Employment Impacts from Increased Demand for Pollution Control Operating Inputs Lime (FGD) 230 Activated Carbon (ACI) 610 Trona (DSI) 3,190 Baghouse material (FF) 20 Employment Impacts from Pollution Control Operation 2,780 Employment Impacts from Retirements of Existing Coal Capacity (3,060) Employment Impacts from Changes in Coal Demand (380) Employment Impacts from Changes in Natural Gas Demand 680 Note: See Appendix 6A for more detail. **6.4 Summary**  **of Employment Impacts** The employment approaches used by EPA rely on different analytical techniques and are applied to different industries during different time periods, and they use different units of analysis. These estimates should not be summed because of the different metrics, length and methods of analysis. The Morgenstern estimates are used for the ongoing employment impacts for the regulated entities (the electric power sector). The short term estimates for employment needed to design, cons truct, and install the control equipment in the three or four***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 11 year period leading up to the compliance date are also provided. Finally some of the other types of employment impacts that will be ongoing are estimated. In Table 6 - 6 , we show the employment im pacts of the MATS as estimated by the environmental protection sector approach and by the Morgenstern approach. **Table 6 -**  **6 .**  **Estimated Employment Impact Table for the MATS Annual (Reoccurring)**  **One Time (Construction During Compliance Period)**  Environmental Protection Sector approach a Not Applicable 47,000 Net Effect on Electric Utility Sector Employment from Morgenstern et al. approach c 8,000 b

- 14, 000 to +30,000 d Not Applicable

a These one - time impacts on employment are estimated in terms of job - years. bThis estimate is not statistically different from zero. cThese annual or recurring employment impacts are estimated in terms of production workers as defined by the US Census Bureau ’ s Annual Survey of Manufacturers (ASM). d 95% confidence interval***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6 - 12 **6.5 References**  Berman, E., and L. T. M. Bui. 2001. Environmental Regulation and Labor Demand: Evidence from the South Coast Air Basin. Journal of Public Economics 79(2):265 - 295. Bezdek, Roger H. , Robert M. Wendling and Paula DiPerna, Environmental protection , the economy, and jobs: National and regional analyses. Journal of Environmental Management Volume 86, Issue 1 **,** January 2008, Pages 63 - 79. Environmental Business International (EBI), Inc., San Diego, CA. Environmental Business Journal, monthly (copyright). http://www.ebiusa.com/ Morgenstern, R. D., W. A. Pizer, and J. S. Shih. 2002. Jobs versus the Environ ment: An Industry Level Perspective. Journal of Environmental Economics and Management 43(3):412 - 436. U.S. Bureau of the Census. 2007 Economic Census, Washington, DC: U.S. Government Printing Office, http://www.census.gov/econ/census07/ . U.S. Bureau of the Census. Pollution Abatement Costs and Expenditures Washington, DC: U.S. Government Printing Office, various years. US Bureau of Labor Statistics, United States Department of Labor. ―Industry Labor Productivity and Cost Data Tables, Annual Percent Changes. (2010). US Energy Information Administration (EIA), Annual Energy Review 2010. ―Coal Mining Productivity By State and Mine Type. US Environmental Protection Agency. Engineering and Economic Factors Affecting the Installation of Control Technologies for M ultipollutant Strategies, EPA - 600/R - 02/073 (2002).***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 1 **APPENDIX 6A EMPLOYMENT ESTIMATES**  **O F DIRECT LABOR IN RE**  **SPONSE TO THE MERCUR Y AND AIR**  **TOXICS STANDARDS IN 2015**  **6A.1 Introduction**  This appendix presents the short - term employment estimates of the Mercury and Air Toxics Standards (MATS), henceforth referred to as the final MATS. The focus of the employment analysis in this study is only on the first order employment impacts related to the compliance actions of the affected coal - fired entities within the power sector. 13 It does not include the ripple effects of those impacts on the broader economy (i.e., the “multiplier” effect), nor does it include the wider economy - wide effects of the changes to energy markets (such as higher electricity prices). 14 Moreover, this stud y provides only a static snapshot of the impacts for 2015 and does not account for the dynamic adjustments of the affected entities as they adapt to the final MATS, such as those arising from technological innovation and learning by - doing. This analysis i s also independent of other techniques used by the U.S. EPA to estimate certain employment effects of particular regulations. The estimates of the employment impacts are divided into several categories: job gains due to the increased demand for pollution c ontrol equipment; job losses due to retirements of coal capacity; and job shifts due to changes in demand for fuels. These elements can be distinguished by one time employment changes (e.g., pollution control construction or coal retirements), and ongoing employment changes (e.g., fuel use changes and pollution control operation). Results indicate that the final MATS has the potential to provide significant short term employment opportunities, primarily driven by the high demand for new pollution control equipment. The employment gains related to the new pollution controls are likely to be tempered by some losses due to certain coal retirements, although, as discussed below, some of these workers who lose their jobs due to plant retirements could find rep lacement employment operating the new pollution controls at nearby units. Finally, job losses due to reduced coal demand are expected to be offset by job gains due to increased natural gas demand, resulting in a small positive (less than a thousand) net c hange in employment due to fuel demand changes. Overall, the preliminary results indicate that the final MATS could

13 This analysis does not include potential employment effects resulting from projected imp acts on oil/gas - fired units. 14 For more detail on the economic impacts of the proposed rule, see Chapter 3 of the Regulatory Impact Analysis accompanying final MATS.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 2 support a net of slightly under 47,000 one - time job - years and a net of about 4,100 ongoing job years in 2015. These results are summarized in Table 6A - 1 below. **Table 6A**  **- 1: Net Employment Changes for 2015 (job**  **- years)**  **One Time Ongoing**  New Pollution Control Equipment 46,980 6,830 Retirements of Generating Units - (3,060) Changes in Fuel Use - 300 **Net Effect 46,980**  **4,070** Total job years of labor for controls projected to be installed by 2015 The job - years estimated here is a snapshot of the first order employment effect of the final MATS in 2015. While there is no temporal dimension to this study, some of these jobs are likely to be spre ad over several years, and some will last longer. Most of the construction related labor demand, for example, is expected to provide a short - term, temporary boost to employment that could last two or three years, along with any multiplier effects that are not included in these job - year estimates. Most of the operational labor needs and labor shifts resulting from fuel changes are likely to be longer term. Thus, in terms of the impacts of the final MATS on economy - wide employment over time, this analysis shows there could be a significant temporary increase to employment levels starting well before 2015, which would likely recede thereafter as the construction phases for the needed pollution controls wind down. Over time, the operational jobs will continu e to provide a small boost to employment over “business as usual” baseline employment levels. Note that this synopsis does not account for other employment impacts of the final MATS, such as those resulting from higher energy prices. **6A.2 Overall Appr**  **oach** The estimates for the near - term employment effects of the final MATS utilize studies conducted by EPA on engineering and resource requirements for various compliance activities, such as installing pollution control equipment, switching fuels, or cea sing plant operations as they become uneconomic. Some of the information used here was obtained from a 2002 EPA engineering study for multi - pollutant control strategies. 15 This study was also the basis for the employment analysis for the proposed MATS. For the final MATS, EPA has undertaken an

15 Engineering and Economic Factors Affecting the Installation of Control Technologies for Multi-pollutant Strategies . EPA - 600/R - 02/073 (October, 2002) .***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 3 update of the 2002 study in order to refine and update the Agency’s understanding of the resource requirements (labor and material s) of various compliance activities, including estimates for newer pollution control equipment that were not included in the 2002 analysis. 16 For example, the 2002 study focused on pollution control technologies that directly address SO 2 and NO x emissions, while the updated study also includes pollution control technologies that reduce mercury emissions and hazardous air pollutants as well. Collectively, these studies are referred to as EPA pollution control studies in this appendix. This employment analy sis is based on information from the updated study where available, as well as data from the original 2002 study. The basic approach involved using power sector projections and various energy market implications under the final MATS from modeling using E PA’s data and assumptions with the Integrated Planning Model (IPM), along with data from secondary sources, to estimate the first order employment impacts for 2015. Throughout this analysis, incremental employment is measured in job - years, since there is no temporal dimension to this analysis. 17 Also, this appendix does not include estimates of total employment impacts over time , though there is a distinction between short - term construction related labor needs and more long - term operational labor needs for new pollution controls (though these operational labor requirements are also measured in 2015 job - years only). **6A.2.1 Employment Changes due to New Pollution Control Equipment**  IPM projections for the final MATS policy case were used to estimate the incr emental pollution control demand. These are shown in Table 6A - 2 below: 18 , 19

16 Engineering and Economic Factors Affecting the Installation of Control Technologies – An Update . Andover Technology Partners and ICF International. October 20, 2011. 17 A job - year is define d as the amount of work that can be performed by the equivalent of one full - time individual for one year (or FTE). 18 According to IPM, there is some overlap between the different types of pollution control equipment demand at individual facilities. To the extent that there could be some efficiency gains at plants installing multiple controls due to economies of scale, the job estimates presented here could overstate the impacts. 19 This analysis does not include employment estimates related to ESP upgrades as the engineering studies used do not include resource estimates for this technology. EPA’s modeling projects a significant amount of ESP upgrades and not including jobs related to those implies these estimates likely understate the total impacts.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 4 **Table 6A.**  **2: Increased Pollution Control Demand due to the final MATS, 2015 (GW) Pollution Control Type**  **IPM Projected Additional Pollution Control** Scrubbers (FGD) 15 Activated Carbon Injection (ACI) 92 Dry Sorbent Injection (DSI) 45 Fabric Filter (FF) 20 88 The employment impacts due to increased pollution control demand are divided into three categories, one of which is associated with the construction and installation labor requirements, while the remaining two are associated with the resources required for the ongoing operation of the pollution control equipment. The labor needed for constructing and installing these controls are for construction - related sectors, such as boilermakers, engineers, and other installation labor. The two categories of labor ne eds for ongoing resource requirements include employment in sectors that supply resources needed to run these pollution controls (such as reagents); and utility sector jobs to operate the control equipment. The following sections discuss the approach for each:

 For the construction labor estimates, per - unit labor needs were taken from the pollution control studies, which included man - hours required per MW for each of the control technologies listed above. The total installation labor was then sub - divided i nto different labor categories, such as boilermakers, engineers and a catch - all “other installation labor”, using estimated shares of the different labor types in studies.

 For the longer term labor associated with operating the pollution controls , per- unit estimates of the main resources needed for the particular types of equipment (see Table 6A - 3 below for a list of the resources) are also taken from EPA’s pollution control studies. Resources needed for FF (such as the filter bags) were estimate d from the incremental Variable Operation and Maintenance (VOM) costs from IPM. 21 These were

20 This number includes the incremental fabric filters that are standalone, or installed with DSI or ACI+Toxecon. In ad dition, EPA’s modeling also included fabric filters installed on units with dry scrubbers, which are excluded from the employment analysis under the assumption that the labor estimates for dry scrubbers include the labor associated with a fabric filter tha t will be installed in conjunction with a dry scrubber. 21 Because FF requirements are not endogenously determined in IPM, it required a different approach than the other controls.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 5 then multiplied by the incremental GW for each pollution control to obtain the total (physical) quantity of resources needed. Total tonnage for each resource was then converted to dollars of increased economic output for these resources using price estimates developed by Sargent & Lundy for EPA’s IPM Base Case v4.10 modeling assumptions (see notes at the end of Table 6A- 3 below).. Finally, the labor productivity for each particular sector was used to estimate the number of job - years these could create in 2015. Labor productivities for each sector were adjusted to account for increased worker productivity in 2015. Data for baseline worker productivity and corresp onding growth rates to account for future productivities came from the Economic Census and the Bureau of Labor Statistics (BLS) estimates. 22

 The final employment vector estimated was for the utility sector labor needed to operate these pollution control eq uipment. This estimate was based on the incremental Fixed Operation and Maintenance (FOM) costs from IPM outputs, excluding costs due to retirements. The assumption is intended to be a proxy for payroll costs, which IPM includes as a part of FOM (which is defined as the operating and maintenance costs incurred by the utility, such as those for payroll, irrespective of whether the equipment is operated). The FOM costs were then translated into employment based on estimates of payroll per worker for the pow er sector taken from the 2007 Economic Census and BLS estimates. 23 **Table 6A.**  **3: Estimated Pollution Control Resource Needs (Quantity and Prices Used) Amount of Resource Used**  **Price Used ($/unit)** Lime, FGD (tons) 1,223,030 $95 24 Activated Carbon, ACI (tons) 247,840 $1,500 Trona, DSI (tons) 10,864,594 $150 Price Sources:  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Mercury Control

22 Total value of shipments in 2007 and total employees were taken from 2 007 Economic Census, Statistics by Industry for Mining and Manufacturing sectors. The average annual growth rate of labor productivity was taken from the Bureau of Labor Statistics. Average growth rate calculated for years 1992 - 2007, applied to 2007 produ ctivity to determine 2015 estimates of productivity. See the Detailed Methodology section at the end for more details about the data used for these calculations. 23 Same sources as other productivity estimates (2007 Economic Census and BLS), however, use s employees and total payroll rather than revenue or value of shipments. 24 For FGD this study uses the price for Lime (Dry FGD) which is significantly greater than the Limestone (Wet FGD) price. This price was used because EPA’s modeling indicates most o f the incremental FGD units are likely to be dry scrubbers.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 6 Cost Development Methodology FINAL”, March 2011, Project 12301 - 009, Perrin Quarles Associates, Inc.  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Dry Sorbent Injection Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc.  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies SDA FGD Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc. **6A2.2 Results**  Table 6A - 4 presents the estimated employment impacts in 2015 resulting from th e additional pollution controls needed to meet the final MATS requirements. According to this analysis, these investments could provide the opportunity to support about 54,000 job - years to design, construct, and operate the needed pollution control equipm ent in 2015. Note, some of these jobs are expected to start before, and continue beyond 2015 (such as the resource related job - years), but this analysis only provides a snapshot for 2015. **Table 6A.**  **4: Jobs Due to Pollution Control Equipment under the final MATS**  **(Job -**  **years in 2015) Jobs for Construction**  **Incremental Employment** 1. Boilermakers 20,610 2. Engineers 5,050 3. General Construction 21,320 **Sub -** **Total: 46,980**  **Jobs for Operation Jobs from Increased Operating Resource Use**  1. Lime (FGD) 230 2. Activated Carbon (ACI) 610 3. Trona (DSI) 3,190 4. Baghouse material (FF) 20 **Sub -** **Total: 4,050**  **Jobs for Pollution Control Operation 2,780**  **Total Labor: 53,810**  Note: Totals may not add due to rounding The number of job - years estimated for pollution control installation is driven in large part by the demand for new FFs used in EPA’s modeling. As shown in Table 6A - 2, up to 88 GW of new FF capacity is projected to come online in 2015 due to the final MATS that are relevant for this employment analysis. The demand for new FFs is estimated to contribute nearly three -***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 7 quarters of the new employment resulting from the installation of pollution controls. Moreover, of the labor needed due to increased resource use, the Trona required for DSI is estimated to support higher number of jobs than the other resources. This is because the DSI technology requires significantly higher quantities of reagents than the other pollution controls, based on EPA’s engineering e stimates and pollution control studies. The second highest resource - related employment gains would likely come from the activated carbon needed in response to the final MATS. Of the roughly 54,000 job - years estimated in Table 6A- 4, about 2,800 job - years , or about 5 percent, are estimated to occur within the utility sector for labor needed to operate the pollution controls (referred to as “Jobs for Pollution Control Operation” in Table 6A- 4). The rest of the labor demand will benefit the pollution contro l industry and other economic sectors. The increased demand for resources and chemicals needed to operate the pollution controls will result in increased employment in sectors such as mining, chemicals, and other manufacturing sectors. The majority of th ese first order employment effects, however, are likely to benefit construction - related sectors, such as construction, boilermaker, heavy engineering, and other heavy construction sectors, resulting from the construction and installation of the new polluti on controls at affected sources throughout the country. 6A2.2.1 Employment Changes due to Coal Retirements Employment changes due to incremental coal plant retirements were estimated by first identifying the retiring coal units 25 from EPA’s modeling results (for the base and the final MATS policy cases). EPA projects that there will be roughly 5.5 GW of additional coal retirements by 2015 with the final MATS in place. 26 In order to convert the retired coal capacity into potential employment losses, it was assumed that changes in the operating costs for the retired coal units can be used as a proxy for payroll expenditures and the lost economic output due to coal retirements. Thus, the changes in the FOM costs for these particular r etiring units were derived using EPA’s IPM modeling results, and converted to lost jobs using data from the Economic Census and BLS output/worker estimates for the utility sector. 27 Employment losses due to plant retirements will not only

25 Oil and gas steam unit emissions requirements, and potential retirements, were not directly included in IPM modeling under the MATS policy scenario. An analysis of these units was conducted separately, and to the extent that there may be some retirements of oil and gas units, then the estimates of potential job losses due to retirements provided here will understate the employment losses. 26 Retirement estimates are based on IPM System Summary Reports. Where applicable, data from IPM parsed outputs were adjusted to account for partial retirements reported in the parsed outputs. 27 The same specific sources as cited before, however, used workers and total payroll.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 8 affect those that are directly working at the plant (i.e., plant operators), but would also affect administrative and other “back - office” workers for those utilities and their support organizations. This appendix assumes that the FOM costs related to retiring plants are a good proxy for these types of job losses. **Table 6A.**  **5: Annual Job Losses due to Coal Capacity Retirements for 2015** FOM Decrease from Retirements (million) $353 Workers Per Million$ in payroll 8.7 **Workers lost due to retirements (job -** **year): 3,060**  Results indicate there could potentially be about 3,000 job losses (measured in job - years for 2015, but any net job losses under this category are likely to be permanent), due to coal retirements. However, two mitigating factors could reduce the negative employment impacts due to retirements. First, many of the retiring units are at plants that are likely to have other units operating under the policy scenario. In such cases, some of the excess labor pool at the retiring units could well be absorbed at o ther units within the same firm. Second, as Table 6A - 4 indicates, utilities are expected to have the need to fill near three thousand additional job slots to operate the pollution controls needed to meet the requirements of the final MATS. If workers wit h experience at existing coal facilities become available through plant retirements, some of these workers could be absorbed in operating these new pollution controls. 6A.2.2. 2 Employment Changes due to Changes in Fuel Use Employment impacts due to proje cted fuel use changes (coal and natural gas production shifts) were estimated using EPA’s modeling results. First, employment losses due to reductions in coal demand were estimated using an approach similar to EPA’s coal employment analyses under Title IV of the Clean Air Act Amendments. 28 Using this approach, EPA’s projected coal demand changes (in short tons) for various coal supplying regions were

28 Impacts of the Acid Rain P rogram on Coal Industry Employment. EPA 430 - R - 01 - 002 March 2001 .***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 9 converted to job - years using EIA data on regional coal mining productivity (in short tons per employee hour ), using 2008 labor productivity estimates. 29 , 30 Results of the coal employment impacts of the final MATS are presented in Table 6A - 6 below. **Table 6A.**  **6: Annual Employment Due To Changes in Coal Use for 2015 Coal by Region**  **Change in Coal Demand (MM Tons) Labor Productivity**  **Job -** **year Change** Appalachia (11.3) 2.91 (1,860) Interior 19.8 4.81 1,980 West (18.3) 19.91 ( 440) Waste Coal (0.7) 5.96 (60) **Net Total (10.5)**  **-- (380)**  Notes: Used US national coal productivity for waste coal Totals may not add due to rounding For natural gas production, labor productivity per unit of natural gas was unavailable, unlike coal labor productivities used above. Most secondary data sources (such as Census and EIA) provide estimates for the combined oil and gas extraction sector. Thi s appendix thus uses an adjusted labor productivity estimate for the combined oil and gas sector that accounts for the relative contributions of oil and natural gas in the total sector output (in terms of the value of energy output in MMBtu). This estimat e of labor productivity is then used with the incremental natural gas demand for the final MATS to estimate the job - years for 2015.

29 From US Energy Information Administration (EIA) Annual Energy Review, Coal Mining Productivity Data. Used 2008. 30 Unlike the labor productivity estimates for various equipment resources which were forecasted to 2015 using BLS average growth rates, we used the most recent historical productivity estimates for fuel sectors. In general, labor productivity for the fuel sectors (both coal and natural gas) showed a significantly higher degree of variability in recent years than the manufacturing sectors, which would have introduced a high degree of uncertainty in forecasting productivity growth rates for future years.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 10 **Table 6A.**  **7: Annual Employment Impact due to Changes in Fuel Use (2015) Fuel Type**  **Employment Coal Job Years Lost**  **(380) Natural Gas**  Incremental Natural Gas Use (MMBtu) 178,279,223 Labor Productivity (MMBtu/job - year) 261,840 **Job -** **years gained 680**  **Net Employment Effects of Fuel use changes 300**  Note: Totals may not add due to rounding Thus, about 380 job losses in the coal mining sector are likely to be offset by about 680 job gains in the natural gas production related sectors, for a net effect of about 300 job - year gains due to the changes in fuel use. **6A.3 Results Summary**  Overall , the final MATS is expected to provide an increase to short - term employment resulting from substantial investments in new pollution control equipment. For 2015 the results indicate the final MATS could support or create around 51,000 job - years driven by the need to design and construct the needed equipment (including both the onetime as well as ongoing job - years). While there could be some employment losses due to coal retirements that will likely have a negative effect on some utilities and the coal min ing sector, employment gains in pollution control operation activities and the natural gas sector are likely to partially offset some of those losses. As previously discussed, this assessment does not account for the long run economy- wide effects of the f inal MATS.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 11 **6A.4 Detailed Methodology**  This section provides more details on the data and approaches used to estimate the employment impacts discussed above. The section also details the sources for individual data elements. **6A.4.1 Pollution**  **Control Equipment Labor** 6A.4.1.2 Installation Labor **Table 6A.**  **8: Installation Labor Requirement Pollution**  **Control Type Incremental GW** 

**Installed Man**  ****

**hours/MW Boilermakers (%)**  **Engineers (%) Others (%)**  **FGD** 15 1730 40 20 40 **ACI** 92 10 50 17 33 **DSI** 45 55 50 17 33 **FF** 88 780 45 7 48 Source: Engineering and Economic Factors affecting the Installation of Control Technologies – An Update, Andover Technology Partners, 2011 Installation labor is estimated by using the incremental GW installed for each pollution control type from EPA’s modeling using IPM. This was then converted into total man - hours needed for installation using estimates of man - hours/MW primarily from EPA’s 2011 update on pollution control technology,. Total man - hours for each pollution control type were then converted into man - years assuming 2,080 working hours per year. Total man - years for each pollution control type were then broken down into various sec tors using the percentages, shown in Table 6A - 8. These percentages were estimated from the 2002 study, updated from the 2011 study, where applicable.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 12 6A.4.1.3 Operating Resource Labor **Table 6A.9**  **: Resources Needed for Operation Pollution**  **Control Type**  **Incremental**

**Total GW (Includes**  **Existing Units) Resource** 

**(Units in parenthesis)**  **Usage**

**Estimates Price** 

**($/unit) Industry Assumed** 

**for Productivity Calculations**  **Productivity***

**FGD** 12.3 Lime (Tons/MWh) 0.013 95 Lime Manufacturing 2.0 **ACI** 133 Activated Carbon (Tons/MWh) 0.00025 1,500 Other Chemical Product Manufacturing 1.6 **DSI** 45 Trona (Tons/MWh) 0.033 150 Potash Soda and Borate Mineral Mining 2.0

**FF** 106 Bag - house Resources *Resource Labor

determined Using VOM cost for FFs Plastics Material and Resin Manufacturing 0.6 *Workers/$Million in Output, Forecasted to 2015 Sources: Usage:  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Mercury Control Cost Development Methodology FINAL”, March 2011, Project 12301 - 009, Perrin Quarles Associates, Inc.  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Dry Sorbent Injection Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc.  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies SDA FGD Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc. Labor related to resources used in operating pollution control equipment was estimated using the total incremental GW of pollution control capacity which was first converted to total MWh of incremental capacity assuming 85 percent capacity factor. For eac h pollution control type, the next step involved choosing the primary operating resource . This approach is consistent with prior EPA’s analyses on similar topics. The next step involved estimating the resource needs by each control type, generally in tons of material using the resource usage estimates as shown in Table 6A - 9 .Using the total usage for each pollution control input (in tons) and associated average prices, total expenditure by each resource type was then calculated. This total expenditure was then converted to labor using workers per $Million in total output for the industry associated with producing each respective input material. 31

31 Fabric filters follow a different pattern. Instead of a resource usage estimate, we used the VOM cost for FFs and converted this to jobs using the workers per million dollars output for the relevant manufacturing industry sector.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 13 6A.4.1.4 Operating Labor **Table 6A.10**  **: Operating Labor Assumptions** Incremental FOM from IPM Parsed ($ Billion) 2.31 FF and other Capital Costs Included in FOM ($ Billion) 1.99 Remaining FOM used to find O&M Labor ($ Million) 319.4 Productivity* 8.7 *Workers per $Million in Payroll for Electricity Generating Sector, Forecast to 2015 Sources: Productivity from 2007 Economic Census and Growth Rate from BLS. Labor requirement to operate the controls is estimated for all equipment types combined, using the incremental FOM costs from IPM. The IPM incremental FOM cost estimate included capital costs for fabric filt ers and scrubber improvement costs, which were first subtracted to obtain the true FOM costs ($319.4 million). Resulting FOM cost estimate was then converted to labor needs using the workers/$ Million in total payroll for t he Electric Generating Sector. **6A4.2 Retirement Labor**  **Table 6A.11**  **: Inputs to Labor from Retirements** Capacity of Incremental Retirements in SSR (MW) 5,498 O&M Decrease scaled to SSR Retirements ($MM) (To account for Partial Retirements) 352.5 Workers Per $Million in payroll, forecast to 2015 8.7 Sources: Productivity from 2007 Economic Census and Growth Rate from BLS. Retirement labor was estimated by first identifying the retiring units from EPA’s modeling using IPM parsed outputs (using incremental retirements in the policy case). The next step involved estimating the capacity of incremental retirements as well as th e change in the FOM costs due to these retirements. Because of the discrepancies between partial retirements in EPA’s parsed outputs and System Summary Reports (SSR), FOM costs were scaled proportionately to reflect the lower SSR - based estimates, as shown in Table 6A- 1 1 above. FOM cost decreases were then converted to job - years lost due to retirements using workers per $Million in payroll.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 14 **6A.4.3 Fuel Use Labor**  **Table 6A.12 : Inputs to Labor for Fuel Use**  **Coal by Region 2015 Incremental Fuel USE (Tons)**  **2008 Short Tons/Employee hour Appalachia**  - 11,270,000 2.9 **Interior** 19,810,000 4.8 **West** - 18,340,000 19.9 **Waste Coal** - 700,000 6.0 **Natural Gas** EIA Total Natural Gas Production 2007 (TCF) 24.664 EIA Total Crude Oil Production 2007 (Barrels) 1,848,450,000 EIA Natural Gas Heat Content 2007 (Btu/cf) 1,027 EIA Petroleum Heat Content (MMBtu/Barrel) 6.151 Total Crude Oil and Natural Gas Production (MMBtu) 36,699,744,000 Economic Census 2007 Oil and Gas Extraction Employees 140,160 MMBtu per Man - year for Oil and Gas Extraction 261,842 Incremental Natural Gas from IPM (TCF) 0.174 Incremental Natural Gas from IPM (Converted to MMBtu) 178,279,223 *Workers per $Million in Payroll for Electricity Generating Sector, Forecast to 2015 Note: Heat Contents from EIA are assumed to be for fuels used in Electric Power Sector Sources: Short Tons per hour from US EIA, Coal Industry Annual. Total Production from 2009 EIA Annual Energy Review. Heat Contents from EIA, Heat Content of Natural Gas Consumed an d 2009 Annual Energy Review. Employment Data from 2007 Economic Census. Fuel use related employment impacts were estimated by using IPM results for incremental changes in coal and natural gas use (policy case over the base case). For coal, estimates of coal use in tons by region from IPM were used in conjunction with labor pr oductivity estimates from the EIA for each region (in short tons/ employee hour), to calculate the change in job - hours needed. These were then converted to job - years, assuming 2,080 working hours per year. As discussed in the main report above, because o f the high variability in coal mining labor productivity in recent years, no attempt was made to forecast coal (and natural gas, for consistency) productivities, instead the most recent historical estimates were used in this appendix (which was the 2008 la bor productivity for coal).***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 15 For natural gas, the first step was estimating labor productivity since such information was not available directly from any reliable source. EIA production data from the Annual Energy Review for natural gas and crude oil (in TCF and barrels, respectively ), along with EIA heat content estimates were used to find total crude oil and natural gas production in MMBtu for 2007. Labor productivity in MMBtu per job - year for the Oil and Gas Extraction sector was then estimated using data from the Census on oil an d gas extraction employment. Then, the incremental natural gas demand from IPM (in TCF) was converted to MMBtu of natural gas demand using EIA data on natural gas heat content. This was then used with the labor productivity estimated above to calculate t he total job - years needed for increased natural gas demand for the final MATS.***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 16 **6A.5 References**  Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Mercury Control Cost Development Methodology FINAL”, March 2011, Proj ect 12301 - 009, Perrin Quarles Associates, Inc. Sargent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies Dry Sorbent Injection Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc. S argent & Lundy, “IPM Model – Revisions to Cost and Performance for APC Technologies SDA FGD Cost Development Methodology FINAL”, August 2010, Project 12301 - 007, Perrin Quarles Associates, Inc. Staudt, Jim. Email Communication with Andover Technology Partne rs. Feb 7, 2011. United States Department of Labor. Bureau of Labor Statistics. Industry Labor Productivity and Cost Data Tables, Annual Percent Changes. 2010. US Census Bureau. 2007 and 2002 Economic Census, 2000 Annual Survey of Manufacturers, Manufactu ring and Mining: Detailed Statistics by Industry for the US and Utilities: Summary Statistics for the US. US Energy Information Administration (EIA). Annual Energy Review 2009, Assorted Data for Coal, Natural Gas, and Petroleum. 2009. US Energy Informatio n Administration (EIA). Natural Gas 2009, Heat Content of Natural Gas Consumed 2009. US EPA. Clear Skies Act, Technical Package, Section D. “Projected Impacts on Generation and Fuel Use”. 2003. US EPA. Clean Air Interstate Rule, Technical Support Document . “Boilermaker Labor Analysis and Installation Timing.” OAR - 2003 - 0053 (March, 2005). US EPA. “Impacts of the Acid Rain Program on Coal Industry Employment.” EPA 430 - R - 01 - 002 (March, 2001).***E.O. 12866 Review– Draft– Do Not Cite, Quote, Or Release During Review ***

6A - 17 US EPA, Office of Research and Development. “Engineering and Eco nomic Factors Affecting the Installation of Control Technologies for Multi - pollutant Strategies.” EPA - 600/R - 02/073 (October, 2002). US EPA, Engineering and Economic Factors Affecting the Installation of Control Technologies: An Update. Prepared by Andover Technology Partners and ICF International. October 2011.