# Unions forJobs Andthe 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 ofI**~i)t:omotive** Engineers and Trainmen. IRT Brotherhood ofMaintenance ofWay Employees Division. IBT International Association ofBridge. 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 ofJourneymen and Apprentices ofthe Plumbing and Pipe Fining Industry ofthe United States and Canada United Mine Workers ofAmerica United Transportation Union Utility Workers Union ofAmerica President Jim Hunter. II3EW Vice-President John Risch, UTU Secretary-Treasurer Bill Cunningham General Counsel Gene Trisko Statement ofBill Cunningham Secretary-Treasurer Unions forJobs and theEnvironment(UJAE) EPAHearingon Proposed StandardsofPerformancefor Greenhouse Gas Emissions forNew Stationary Sources: Electric Utility GeneratingUnits May24,2012 My name is Bill Cunningham. Iam 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 otherenergy-related industries. Thejobsand 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 ofthe key negotiating sessions including Kyoto, Bali, Copenhagen and Durban. UJAE members have carefully followed the development ofthe technology that can, now and in the future, be applied to coal fired powerplants, including the development ofCarbon 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 ofCCS. CCS shows great promise, but has not reached the stage ofdemonstration at a commercial scale. One ofthe most advanced efforts was the pilot at the AEP Mountaineer plant in West Virginia, which closed down because ofthe failure ofstate regulators to approve cost recovery. The Federal government did not step up its support in the face ofthe lackofresolve ofstate regulators. UJAE believes that the use ofcoal, and the ability to build new, more efticient plants, is vital tothe economic future and security ofthe U.S

.. The cost and availability ofelectricity will be affected ifthe use ofcoal continues to decline and new coal-fired powerplants cannotbe builtto replace olderplants that are closing. Theelectric powerindustry has been built on the basis ofnot ''putting all ofyour eggs in one basket." As the cost and availability ofone fuel resource changes, others are available to help lessen the impact on consumers. The use ofcoal, natural g11s, and nuclear have been important tomitigate price increases and availability ofbase load fuels. Ofthese fuels, coal has shown the least cost variability and the most reliable availability over time. Planning for powerplants 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 ofnatural gas is belowthe cost of production, which means that natural gas prices are simply unsustainable. And the uses ofnatural 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 ofaction that will be supported by state and local governments that are under pressure to reduce emissions from the growing number ofautomobiles on the road. Consumers can see the opportunity to reduce the cost ofdriving by switching to natural gas powered vehicles. Exportofnatural gas can also tighten supplies and raise prices. Currently, gas producing companies are planning to convert importterminals to export and to build new exporttacilities. The approval ofan LNG export facility in Louisiana is expected to be followed by a numberof otherregulatory approvals according to Fitch Ratings. In this area, Dominion has asked for approval to convertthe 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 exportdue to the much higher natural gas prices in Asiaand 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 ofnatural gas will increase the competitiveness ofcoal fired plants, a factor that powercompanies should be able to act on to keep electricity prices affordable and reliable. Natural gas is an important part ofthefuel mix for electricity production, but it is not a fuel to tavor based on decisions aboutcarbon 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 professorat 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 ofClimatic Change Letters. The problem, he pointed out, is the accompanyingrelease ofmethane during drilling, tracturing, and transportation. Aton of methane has a carbon dioxide equivalent many times that ofaton ofcarbon dioxide.
A second study pointing outthat carbon dioxide equivalent emissions from natural gas are much higherthan previously thought was authored by Tom Wigley, a seniorresearch associate at the National Centerfor Atmospheric Research (NCAR). Wigley believes that "Relying more on natural gas would reduce emissions ofcarbon 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 wouldjustbe making a difference around the edges."
In view ofthese findings, it makes little sense to tavorthe use ofnatural gas over coal trom the standpoint ofclimate change. In the future, the construction ofcoal ornatural gas plants should be based on the same principles as in the past- on the cost-effectiveness ofthe plant and onthe need for a diversified electricity production base (don't put all your eggs in one basket).

2In ourview (UJAE), the EPA proposed New Source standard would entirelyrule outthe construction ofnew coal plants regardless ofthe price ofcompeting fuels and the costeffectiveness ofgenerating electricity with coal. The problem is that EPA assumes that CCS will be available, an assumption that is unwarranted given the shutdown ofthe Mountaineer CCS pilot plant, the prospect ofbudget cuts for energytechnology 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 ofCCS 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. Thecurrent agreementby 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 ofthe Kyoto Protocol in that it would include major developing countries as well as industrial countries. The absence ofcoverage of developing countries was a major problem preventing acceptance ofthe Kyoto Protocol in the 

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.. Greater coverage by the treaty would make offsets available in developing countries which would considerably reduce the cost ofcompliance. The price to offset a ton ofcarbon dioxide could be as little as $10 compared to the $70 perton (orgreater) cost ofCCS.
EPA'sproposed NSPS rules out new coal power plant construction because it assumes that CCS will be economically available for the construction ofa new power plant. That is an assumption that no utility orcontractor will make in the absence ofa cost-effective, commercial-size demonstration.
To ensure an affordable and reliable energy supply and make possible the construction ofnew, 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 otherrules that EPA has proposed toregulate emissions from new sources underthe Clean Air Act.

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