Unions for Jobs 

And the Environment 

Address: PO Box 56173. Washington. DC 20040M6173 Voice and Fax: 301-585-5828 Email: ujaeU~rcn.com Website: VV\V\v.ujae.org 

Member Unions 

Brotherhood of I ~i)t:omotive 

Engineers and Trainmen. IRT 

Brotherhood of Maintenance of Way 

Employees Division. IBT 

International Association of Bridge. 

Structural, Ornamental and 

Reinforcing Iron Workers Union 

International Brotherhood of 

Boilermakers. Iron Ship Builders, 

Blacksmiths, Forgers and Helpers 

International Brotherhood of 

Electrical Workers 

International Brotherhood of 

Teamsters 

Marine Engineers Rcncficial 

Association 

Rail Conference, IUT 

Sheet Metal Workers International 

Association 

Transportation • Communications 

International Union 

United Association of Journeymen 

and Apprentices of the Plumbing 

and Pipe Fining Industry ofthe 

United States and Canada 

United Mine Workers of America 

United Transportation Union 

Utility Workers Union of America 

President 

Jim Hunter. II3EW 

Vice-President 

John Risch, UTU 

Secretary-Treasurer 

Bill Cunningham 

General Counsel 

Gene Trisko 

Statement of Bill Cunningham 

Secretary-Treasurer 

Unions for Jobs and the Environment (UJAE) 

EPA Hearing on Proposed Standards of Performance for Greenhouse 

Gas Emissions for New Stationary Sources: 

Electric Utility Generating Units 

May 24,2012 

My name is Bill Cunningham. I am representing Unions for Jobs and the 

Environment (UJAE), an organization of 14 unions with more than 3.2 

million workers in electric power, transportation, coal mining, construction, 

and other energy-related industries. The jobs and incomes ofUJAE 

members will be strongly affected by the decisions EPA makes on the 

standards for new power plant carbon dioxide emissions. 

UJAE is involved in both domestic and international discussions on climate 

change. UJAE is recognized as an NGO by the United Nations Convention 

on Climate Change and has participated in all of the key negotiating 

sessions including Kyoto, Bali, Copenhagen and Durban. 

UJAE members have carefully followed the development of the technology 

that can, now and in the future, be applied to coal fired power plants, 

including the development of Carbon Capture and Storage (CCS). Our 

members were involved in the EPA Work Group on Advanced Coal 

Technologies, and UJAE supported legislative and DOE initiatives to create 

programs for the large-scale demonstration of CCS. CCS shows great 

promise, but has not reached the stage of demonstration at a commercial 

scale. One of the most advanced efforts was the pilot at the AEP 

Mountaineer plant in West Virginia, which closed down because of the 

failure of state regulators to approve cost recovery. The Federal government 

did not step up its support in the face of the lack of resolve of state 

regulators. 

UJAE believes that the use of coal, and the ability to build new, more 

efticient plants, is vital to the economic future and security of the U.S .. The 

cost and availability of electricity will be affected if the use of coal 

continues to decline and new coal-fired power plants cannot be built to 

replace older plants that are closing. 

The electric power industry has been built on the basis of not ''putting all of your eggs in one 

basket." As the cost and availability of one fuel resource changes, others are available to help 

lessen the impact on consumers. The use of coal, natural g11s, and nuclear have been important to 
mitigate price increases and availability of base load fuels. Of these fuels, coal has shown the 

least cost variability and the most reliable availability over time. 

Planning for power plants takes place over several decades, so it is important not to base future 

energy policy on the hope that natural gas prices will stay low. There are several reasons to 

believe that natural gas prices will rise. Currently, the price of natural gas is below the cost of 

production, which means that natural gas prices are simply unsustainable. And the uses of natural 

gas are expected to expand into transportation and the LNG export market which will tighten the 

supply. 

Automobiles engines can be converted to natural gas use, a course of action that will be 

supported by state and local governments that are under pressure to reduce emissions from the 

growing number of automobiles on the road. Consumers can see the opportunity to reduce the 

cost of driving by switching to natural gas powered vehicles. 

Export of natural gas can also tighten supplies and raise prices. Currently, gas producing 

companies are planning to convert import terminals to export and to build new export tacilities. 

The approval of an LNG export facility in Louisiana is expected to be followed by a number of 

other regulatory approvals according to Fitch Ratings. In this area, Dominion has asked for 

approval to convert the tacility at Cove Point, Maryland for export. Originally built for importing 

natural gas, it is connected to the three major Mid-Atlantic natural gas transmission systems. 

Given the possibility for natural gas use in transportation, and the potential for export due to the 

much higher natural gas prices in Asia and Europe, it is easy to see the likelihood for higher and 

more volatile natural gas prices in the tuture. A substantial rise in the price of natural gas will 

increase the competitiveness of coal fired plants, a factor that power companies should be able to 

act on to keep electricity prices affordable and reliable. 

Natural gas is an important part ofthe fuel mix for electricity production, but it is not a fuel to 

tavor based on decisions about carbon dioxide emissions and global warming. The tirst warning 

about the carbon dioxide equivalent emissions from natural gas production and use came from 

Robert Howarth, a professor at Cornell, who wrote that electric generation based on natural gas 

trom shale can do more to aggravate global warming than coal-based generation. His study was 

published in the May 2011 issue of Climatic Change Letters. The problem, he pointed out, is the 

accompanying release of methane during drilling, tracturing, and transportation. A ton of 

methane has a carbon dioxide equivalent many times that of a ton of carbon dioxide. 

A second study pointing out that carbon dioxide equivalent emissions from natural gas are much 

higher than previously thought was authored by Tom Wigley, a senior research associate at the 

National Center for Atmospheric Research (NCAR). Wigley believes that "Relying more on 

natural gas would reduce emissions of carbon dioxide, but it would do little to help solve the 

climate problem ... It would be many decades before it would slow down global warming at all, 

and even then it would just be making a difference around the edges." 

In view of these findings, it makes little sense to tavor the use of natural gas over coal trom the 

standpoint of climate change. In the future, the construction of coal or natural gas plants should 

be based on the same principles as in the past- on the cost-effectiveness of the plant and on the 

need for a diversified electricity production base (don't put all your eggs in one basket). 

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In our view (UJAE), the EPA proposed New Source standard would entirely rule out the 

construction of new coal plants regardless of the price of competing fuels and the costeffectiveness of generating electricity with coal. The problem is that EPA assumes that CCS will 

be available, an assumption that is unwarranted given the shutdown of the Mountaineer CCS 

pilot plant, the prospect of budget cuts for energy technology programs and the inability to pass 

climate change legislation, such as Waxman-Markey, or another mechanism that would set a 

price for carbon and foster the construction of CCS facilities. 

An important consideration in reducing and offsetting carbon dioxide and other greenhouse gas 

emissions is the negotiation process at the UN. Following the disappointing negotiations in 

Copenhagen, further progress was made in Durban on proposals for a new global treaty to 

replace the Kyoto Protocol. 

The current agreement by the UN Ad hoc Working Group on Long-term Cooperative Action 

under the Convention is that a new treaty be negotiated by 2015 that would go into effect in 

2020. A new treaty would rectify a major shortcoming of the Kyoto Protocol in that it would 

include major developing countries as well as industrial countries. The absence of coverage of 

developing countries was a major problem preventing acceptance of the Kyoto Protocol in the 

u.s .. 

Greater coverage by the treaty would make offsets available in developing countries which 

would considerably reduce the cost of compliance. The price to offset a ton of carbon dioxide 

could be as little as $10 compared to the $70 per ton (or greater) cost ofCCS. 

EPA's proposed NSPS rules out new coal power plant construction because it assumes that CCS 

will be economically available for the construction of a new power plant. That is an assumption 

that no utility or contractor will make in the absence of a cost-effective, commercial-size 

demonstration. 

To ensure an affordable and reliable energy supply and make possible the construction of new, 

more etTtcient, coal plants will require EPA to re-propose the rule with separate standards for 

coal steam units and natural gas combined cycle units. This would be in conformity with all 

other rules that EPA has proposed to regulate emissions from new sources under the Clean Air 

Act. 

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